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ITC

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FY2021 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, 2021

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*	*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 Act). Yes ☐ No þ
The aggregate market value of the registrant’s common stock held by non-affiliates on June 30, 2021 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 the registrant’s common stock, no par value, outstanding as of 
February 10, 2022.

None.

DOCUMENTS INCORPORATED BY REFERENCE

Table of Contents

ITC Holdings Corp.

Form 10-K for the Fiscal Year Ended December 31, 2021 

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.

Properties

Legal Proceedings

Mine Safety Disclosures

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

Item 6.
Item 7.

[Reserved]
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

Item 9C. Disclosure Regarding Foreign Jurisdictions That Prevent Inspections

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

23

23

23

23
23

23

38

41

84

84

84

84

84

84

88

116

117

118

119

119

131

132

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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;

• “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;

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

subsidiary of Fortis in which GIC has an indirect, passive, non-voting minority ownership interest;

• “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;

• “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;

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

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• “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 Amended and Restated Shareholders’ Agreement, dated 
as  of  January  28,  2021  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;

• “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

ITC  Holdings  provides  safe  and  reliable  electric  transmission  service  to  connect  consumers  to  more 
sustainable and cost-effective energy resources. ITC Holdings continues to make investments in a modernized 
grid  to  maintain  reliability  and  accommodate  future  demands  as  our  economy  and  lifestyles  become 
increasingly dependent on electricity.

Our  business  consists  primarily  of  the  electric  transmission  operations  of  our  Regulated  Operating 
Subsidiaries.  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.

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.

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” as well as in Note 5 to the consolidated financial statements.

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, passive, non-voting equity interest of 19.9%.

Development of Business

As  we  move  toward  a  cleaner,  sustainable  and  electrified  economy,  the  power  grid  will  need  to  be 
transformed and modernized. Technology deployment and innovation are occurring at an accelerated rate within 
our  industry,  so  we  are  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  $4.0  billion  from  2022  through  2026  at  our  Regulated  Operating 
Subsidiaries.  Included  in  this  amount  are  capital  expenditures  to:  (1)  maintain  and  replace  our  current 
transmission  infrastructure  to  enhance  system  reliability  and  accommodate  load  growth;  (2)  interconnect  new 
renewable  generation  resources;  (3)  upgrade  physical  and  technological  grid  security  to  protect  critical 
infrastructure;  and  (4)  expand  access  to  electricity  markets  to  reduce  the  overall  cost  of  delivered  energy  to 
customers.

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 

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residential,  commercial  and  industrial  end-use  consumers.  The  operations  performed  by  our  Regulated 
Operating Subsidiaries fall into the following categories:

• asset planning;

• engineering;

• asset protection and performance;

• cyber security operations center; and

• real time operations.

Asset Planning

The Asset  Planning  group  performs  the  role  of  detailing  the  required  transmission  infrastructure  needed  to 
support system changes and economic opportunities. System changes can arise from different points of origin 
including  load  growth,  load  shifts,  or  new  points  of  interconnection;  generation  retirements  or  additions; 
operational  needs;  and  system  dynamic  stability  needs.  Likewise,  the  Asset  Planning  group  explores 
opportunities  to  better  utilize  the  transmission  system  through  economic  planning  by  providing  access,  via 
transmission  expansion  projects,  to  lower  cost  energy.  However,  the  core  responsibility  of  the Asset  Planning 
group  is  proactively  anticipating  the  future  demands  placed  upon  the  transmission  system  and  developing 
corrective  action  plans  for  any  deficiencies.  Corrective  action  plans  are  developed  to  ensure  compliance  with 
NERC’s  reliability  standards.  Additionally,  the  Asset  Planning  group  seeks  opportunities  to  further  develop  a 
resilient transmission system.

Transmission  infrastructure  plans  are  submitted  as  discrete  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 projects 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 the 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.

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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 
to  not  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.

Cyber Security Operations Center

The Cyber Security Operations Center protects ITC’s reputation and brand by securing critical infrastructure, 
data,  and  computing  systems  from  threat  actors.  We  protect  vital  infrastructure  by  developing,  refining,  and 
continually  delivering  a  comprehensive  cyber  security  program  while  helping  our  stakeholders  meet  their 
business objectives. As the threat landscape becomes increasingly sophisticated and expansive, we continue to 
evolve our defensive strategy. We improve this strategy by deploying new technology, continuing education of 
our  user  community,  and  advancing  our  protections  against  ongoing  cyber  threats.  We  leverage  threat 
intelligence  and  external  industry  practices  for  continuous  improvement  and  refinement  of  our  cyber  security 
program.

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 
that 
ITCTransmission  and  DTE  Electric.  The  MOA 
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.

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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.

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.

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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 
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.

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. 

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 
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.

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 

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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.

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.

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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 
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.

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Principal Customers

Our  principal  transmission  service  customers  are  DTE  Electric,  Consumers  Energy  and  IP&L,  which 
accounted for approximately 21.5%, 23.5% and 24.7%, respectively, of our consolidated billed revenues for the 
year  ended  December  31,  2021.  One  or  more  of  these  customers  together  have  consistently  represented  a 
significant  percentage  of  our  operating  revenue.  This  portion  of  total  billed  revenues  of  DTE  Electric, 
Consumers  Energy  and  IP&L  include  the  collection  of  2019  revenue  accruals  and  deferrals  and  exclude  any 
amounts for the 2021 revenue accruals and deferrals that were included in our 2021 operating revenues but will 
not be billed to our customers until 2023. 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.  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. 

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, 2021, we had 705 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.

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 us in the top decile among comparable electric utilities.

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.

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  continuing  to  enhance  our 
supplier diversity program. This effort will further diversify our supplier base through the recruitment and growth 
of businesses owned by minorities, women and veterans. 

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Environmental Matters

See “Environmental Matters” in Note 17 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 
and RTO participation, 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. See “Rate of 
Return on Equity Complaints” in Note 17 to the consolidated financial statements for detail on ROE matters.

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 
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;

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•

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 financial condition, results of operations and cash flows.

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.

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.

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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, 
financial condition, results of operations, 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, public health authorities, OSHA, and/or the states served by 
our  transmission  systems  may  issue  orders  that  can  place  restrictions  on  and/or  result  in  the  temporary 
shutdown  of  operations  of  businesses  that  use  our  transmission  systems.  The  impact  of  efforts  to  limit  the 
spread  of  COVID-19  on  our  business,  financial  condition  and  results  of  operations  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  intend  to  comply  with  applicable  obligations  that  require  broad  categories  of  employees  and 
subcontractors to be vaccinated against COVID-19 or test regularly. Complying with such vaccine and/or testing 
requirements  poses  the  risk  of  workforce  disruption  that  could  impact  business  continuity,  including  the 
quarantine/isolation of employees, the possibility of resignations by unwilling employees and/or subcontractors, 
and difficulty in satisfying future labor needs. Significant workforce disruptions could have a material impact on 
our business, financial condition, results of operations and cash flows.

COVID-19 could disrupt the supply chains that provide services and equipment to us as part of our capital 
expenditures  or  maintenance  efforts.  If  our  supply  chains  are  disrupted,  we  may  be  unable  to  perform 
necessary maintenance, which could result in increased costs as we implement contingency plans to allow us to 
continue to operate. Supply chain interruptions may also increase the cost of capital expenditures or result in 
the  delay  or  cancellation  of  planned  projects,  any  of  which  could  have  a  material  adverse  impact  on  our 
business, financial condition, results of operations and cash flows.

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, financial condition, results of operations, 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 

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a  timely  manner.  Additionally,  a  significant  amount  of  the  land  on  which  our  other  subsidiaries’  assets  are 
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.

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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 
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 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  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 

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acts of war, terrorist attacks 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.

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.

Effects of climate change, including natural disasters, severe weather and other related phenomena, 
and  the  regulatory  and  legislative  developments  related  to  climate  change,  may  have  a  material 
adverse effect on our business, financial condition, results of operations and cash flows.

Natural  disasters,  severe  weather,  and  other  related  phenomena  due  to  climate  change  may  negatively 
affect  our  business  and  financial  condition  through  increased  costs  from  repairs  to  our  transmission  facilities 
and  implementation  of  contingency  plans  for  continued  operations  as  repairs  are  underway.  We  could  also 
experience disruptions to our supply chain, as our suppliers may face similar challenges to their operations from 
severe weather-related events due to climate change. Furthermore, prolonged power outages to customers and 
business interruptions from delays in storm restoration efforts could damage our reputation, which may have a 
material adverse effect on our business, financial condition, results of operations and cash flows.

Moreover,  federal,  regional  or  state  legislative  or  regulatory  initiatives  may  attempt  to  control  or  limit  the 
causes  of  climate  change,  including  greenhouse  gas  emissions,  such  as  carbon  dioxide  and  methane.  Such 
laws  or  regulations  could  impose  costs  tied  to  greenhouse  gas  emissions,  operational  requirements  or 
restrictions, or additional charges to fund energy efficiency activities. They could also provide a cost advantage 
to  alternative  energy  sources  or  result  in  other  costs  or  requirements,  such  as  costs  associated  with  the 
adoption  of  new  infrastructure  and  technology  to  respond  to  new  mandates. The  occurrence  of  the  foregoing 
events  could  put  upward  pressure  on  costs,  adversely  affecting  our  business,  financial  condition,  results  of 
operations and cash flows.

Changes in tax laws or regulations may negatively affect our financial condition, results of operations, 
net income, 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 financial 
condition, results of operations, net income, 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 

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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. 

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, results of operations and cash flows.

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

would increase the leverage-related risks described above.

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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 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;

• 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  15  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 676 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.

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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  9  to  the 
consolidated  financial  statements  for  more  information  on  the  outstanding  debt  of  our  Regulated  Operating 
Subsidiaries.  As  of  December  31,  2021,  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 
such  proceedings.  We  regularly  review  legal  matters  and  record  provisions  for  claims  that  are  considered 
probable of loss. 

Refer  to  Notes  5  and  17  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 $232 million and $330 million to our parent, ITC Investment Holdings, during 
the years ended December 31, 2021 and 2020, respectively. ITC Holdings also paid dividends of $64 million to 
ITC Investment Holdings in January 2022. 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. 

[Reserved]

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” 

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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 are 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, 2021 and 2020 and provides year-to-year comparisons 
between  the  years  ended  December  31,  2021  and  2020.  Discussions  of  such  information  for  the  year  ended 
December 31, 2019 and year-to-year comparisons between the years ended December 31, 2020 and 2019 that 
are  not  included  in  this  Form  10-K  can  be  found  in  “Management’s  Discussion  and  Analysis  of  Financial 
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, 2020.

Overview

ITC  Holdings  provides  safe  and  reliable  electric  transmission  service  to  connect  consumers  to  more 
sustainable and cost-effective energy resources. ITC Holdings continues to make investments in a modernized 
grid  to  maintain  reliability  and  accommodate  future  demands  as  our  economy  and  lifestyles  become 
increasingly dependent on electricity.

Our  business  consists  primarily  of  the  electric  transmission  operations  of  our  Regulated  Operating 
Subsidiaries.  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.

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.

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 5 to the consolidated financial statements.

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

year ended December 31, 2021 or that may affect future results include:

• Our capital expenditures of $834 million at our Regulated Operating Subsidiaries during the year ended 

December 31, 2021, as described below under “— Capital Investment and Operating Results Trends;”

• Debt  issuances,  borrowings,  repayments,  and  interest  rate  swaps  as  described  in  Note  9  to  the 

consolidated financial statements;

• The  FERC  orders  related  to  the  MISO  ROE  Complaints,  as  described  in  Note  17  to  the  consolidated 

financial statements, that are currently under appeal at the D.C. Circuit Court; and

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• Issuance of a NOPR by the FERC on March 20, 2020 and issuance of a supplemental NOPR on April 15, 
2021, that include a proposal to update the transmission incentives policy, as described below under “ — 
Recent Developments.”

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  5  to  the  consolidated  financial 
statements for further discussion of our Formula Rates and see “Rate of Return on Equity Complaints” in Note 
17 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 17 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 Network 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,  economic  conditions  and  other  significant  factors, 
including  the  effects  of  COVID-19,  and  is  seasonally  shaped  with  higher  load  in  the  summer  months  when 
cooling demand is higher. We are unable to predict the possible future impacts of weather, economic conditions, 
including  COVID-19,  and  other  factors  on  monthly  network  peak  loads  at  our  MISO  Regulated  Operating 
Subsidiaries.

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 

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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 
revenues  and  earnings  have  been  impacted  by  changes  in  our  ROE  and  required  refunds  resulting  from  the 
resolution of the incentive adders complaints and MISO ROE Complaints, as described in Note 5 and Note 17 
to  the  consolidated  financial  statements.  Our  revenues  and  earnings  may  be  impacted  by  future  increases  or 
decreases to our rates for incentive adders and base ROE.

During  2021,  our  MISO  Regulated  Operating  Subsidiaries  filed  revised  depreciation  rates  for  their  assets 
which  were  approved  by  the  FERC  in  December  2021.  The  overall  depreciation  expense  at  our  MISO 
Regulated Operating Subsidiaries increased beginning on January 1, 2022. This increase is expected to result 
in higher revenue from customers in the near term due to an overall increase in the rates at which we record 
depreciation expense. Based on December 31, 2020 asset balances used in the filing, we estimate an increase 
in 2022 in depreciation expense of approximately $35 million to $40 million resulting from our MISO Regulated 
Operating Subsidiaries’ new depreciation rates.

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  to  enhance  system  reliability  and  accommodate  load  growth;  (2) 
interconnect  new  renewable  generation  resources;  (3)  upgrade  physical  and  technological  grid  security  to 
protect critical infrastructure; and (4) expand access to electricity markets to reduce the overall cost of delivered 
energy to customers. To date, COVID-19 has not had a material impact on our forecasted capital expenditures. 
However,  we  continue  to  evaluate  and  monitor  the  potential  impacts  of  COVID-19,  including  potential  supply 
chain  disruptions,  on  our  forecasted  capital  expenditures. 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, 2021
$ 

834  $ 

2022 — 2026
4,004 

(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.

A comprehensive effort by MISO is underway to identify and construct the regional transmission required in 
the  MISO  region  to  support  the  ongoing  evolution  of  the  electric  industry.  MISO  is  currently  requesting  FERC 
authorization  for  cost  allocation  and  finalizing  planning  for  an  initial  tranche  of  long  range  transmission  plan 
projects. 

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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 challenges to businesses and facilities in various industries around the 
world, including our customers, and disruptions to the global economy and supply chains. To date, COVID-19 
has not had a material impact on our net income. However, for 2020, we utilized 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  for  our  customers  that  were  collected  through  our 
Formula Rates.

We are unable to predict the ultimate effects of COVID-19 on the U.S. or global economy or our operations. 
We continue to monitor developments affecting our workforce, customers, suppliers, and operations. The extent 
of the impact of COVID-19 will depend on its duration, actions by government authorities, and impacts on our 
customers,  employees,  or  vendors.  These  developments  are  continuously  evolving,  and  we  cannot  predict 
whether COVID-19 will have a material impact on our financial condition, results of operations or cash flows.

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 FERC has issued multiple orders in 
these proceedings, and there are appeals to these orders pending in the D.C. Circuit Court. See Rate of Return 
on  Equity  Complaints  in  Note  17  to  the  consolidated  financial  statements  for  a  summary  of  the  MISO  ROE 
Complaints. See also the risk factor “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.” in Item 1A. Risk Factors.

Challenges to Incentive Adders for Transmission Rates

The  FERC  issued  a  NOPR  on  March  20,  2020,  and  issued  a  supplemental  NOPR  on  April  15,  2021, 

proposing to update its transmission incentives policy. Among other things, the rulemaking proposals would:

•

•

grant  incentives  to  transmission  projects  based  upon  benefits  to  customers  ensuring  reliability  and 
reducing the cost of delivered power by reducing transmission congestion, and

eliminate the ROE adders for independent transmission ownership and for RTO participation.

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. As of December 31, 2021, 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. For ITC Great 
Plains,  each  10  basis  point  change  in  authorized  ROE  would  impact  annual  consolidated  net  income  by  less 
than $1 million.

Complaints  were  previously  filed  with  the  FERC  under  section  206  of  the  FPA  challenging  the  adders  for 
independent transmission ownership that are in transmission rates charged by our MISO Regulated Operating 
Subsidiaries  and  ITC  Great  Plains. The  FERC  issued  orders  in  these  proceedings,  setting  revised  adders  for 
independent  transmission  ownership  for  each  of  the  MISO  Regulated  Operating  Subsidiaries  and  ITC  Great 
Plains  to  25  basis  points,  and  the  FERC  orders  were  subsequently  appealed  in  the  D.C.  Circuit  Court.  On 
February  19,  2021,  the  appeal  of  the  FERC  order  in  the  proceedings  for  the  MISO  Regulated  Operating 
Subsidiaries was denied. On March 4, 2021, the appeals of the FERC orders in the proceedings for ITC Great 
Plains  were  dismissed  following  a  motion  for  voluntary  dismissal  by  ITC  Great  Plains.  See  Note  5  to  the 
consolidated financial statements for a summary of incentive adders for transmission rates and these matters.

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See  also  the  risk  factor  “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.” 
in Item 1A. Risk Factors.

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.

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.

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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,

2021

2020

Increase
(Decrease)

Percentage
Increase
(Decrease)

Year Ended
December 31,
2019

Increase
(Decrease)

Percentage
Increase
(Decrease)

Transmission and other services

$ 

1,358  $ 

1,290  $ 

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

(9) 

1,349 

8 

1,298 

108 

128 

232 

133 

(1) 

600 

749 

251 

(30) 

(5) 

216 

533 

127 

87 

115 

219 

124 

— 

545 

753 

240 

(27) 

(3) 

210 

543 

136 

NET INCOME

$ 

406  $ 

407  $ 

Operating Revenues

68 

(17) 

51 

21 

13 

13 

9 

(1) 

55 

(4) 

11 

(3) 

(2) 

6 

(10) 

(9) 

(1) 

 5 % $ 

1,286  $ 

 (213) %  

41 

 4 %  

1,327 

 24 %  

 11 %  

 6 %  

 7 %  

n/a  

 10 %  

 (1) %  

113 

138 

203 

118 

— 

572 

755 

 5 %  

224 

 11 %  

 67 %  

 3 %  

 (2) %  

 (7) %  

(29) 

— 

195 

560 

132 

4 

(33) 

(29) 

(26) 

(23) 

16 

6 

— 

(27) 

(2) 

16 

2 

(3) 

15 

(17) 

4 

 — % $ 

428  $ 

(21) 

 — %

 (80) %

 (2) %

 (23) %

 (17) %

 8 %

 5 %

n/a

 (5) %

 — %

 7 %

 (7) %

n/a

 8 %

 (3) %

 3 %

 (5) %

Year ended December 31, 2021 compared to year ended December 31, 2020 

The  following  table  sets  forth  the  components  of  and  changes  in  operating  revenues  for  the  years  ended 
December  31,  2021  and  2020  which  included  revenue  accruals  and  deferrals  as  described  in  Note  5  to  the 
consolidated financial statements:

(In millions of USD)

Network revenues (a)

Regional cost sharing revenues (a)

Point-to-point

Scheduling, control and dispatch (a)

Other

Remeasurement of liabilities for ROE 

Complaints

Total

____________________________

2021

2020

Amount

Percentage

Amount

Percentage

Increase
(Decrease)

Percentage
Increase
(Decrease)

$ 

929 

358 

17 

19 

26 

— 

 69 % $ 

 27 %  

 1 %  

 1 %  

 2 %  

 — %  

852 

362 

13 

20 

19 

32 

 66 % $ 

 28 %  

 1 %  

 2 %  

 1 %  

 2 %  

$  1,349 

 100 % $  1,298 

 100 % $ 

77 

(4) 

4 

(1) 

7 

 9 %

 (1) %

 31 %

 (5) %

 37 %

(32) 

51 

 (100) %

 4 %

(a) Includes a portion of the Formula Rate true-up of $(9) million and $8 million for the years ended December 

31, 2021 and 2020, respectively.

Operating  revenues  increased  primarily  due  to  a  higher  rate  base  associated  with  higher  balances  of 
property,  plant  and  equipment  in-service  and  increased  recoverable  operating  expenses  in  2021  due  to 
temporary  cost  saving  measures  utilized  in  2020,  which  was  partially  offset  by  a  favorable  base  ROE 
adjustment in 2020 related to prior periods as a result of the May 2020 Order.

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Operating Expenses

Operation and maintenance expenses

Year ended December 31, 2021 compared to year ended December 31, 2020

Operation and maintenance expense increased primarily due to higher expenses associated with substation 
and overhead line maintenance activities, as well as higher vegetation management requirements, primarily due 
to temporary cost saving measures that were utilized in 2020 as a result of the COVID-19 pandemic.

General and administrative expenses

Year ended December 31, 2021 compared to year ended December 31, 2020

General and administrative expenses increased due to higher compensation-related expenses, primarily due 

to an increase in share-based compensation expense.

Depreciation and amortization expenses

Year ended December 31, 2021 compared to year ended December 31, 2020

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

property, plant and equipment in-service additions.

Taxes other than income taxes

Year ended December 31, 2021 compared to year ended December 31, 2020

Taxes other than income taxes increased due to higher property tax expenses primarily due to our Regulated 
Operating Subsidiaries’ 2020 capital additions and higher millage rates, which are included in the assessments 
for 2021 property taxes.

Other Expenses (Income)

Interest Expense, Net

Year ended December 31, 2021 compared to year ended December 31, 2020

Interest expense, net increased due to higher debt balances and higher amortization of interest as a result of 
losses on interest rate swaps terminated in 2020. Additionally, the May 2020 Order resulted in a reduction in our 
previously recorded refund obligations, as well as a corresponding reduction in interest expense in 2020. See 
Note  17  to  the  consolidated  financial  statements  for  information  regarding  the  May  2020  Order  and  the 
associated impacts of MISO ROE Complaints.

Income Tax Provision

Year ended December 31, 2021 compared to year ended December 31, 2020

Our  effective  tax  rates  for  the  years  ended  December  31,  2021  and  2020  were  23.8%  and  25.0%, 
respectively.  Our  effective  tax  rate  as  of  December  31,  2021  exceeded  our  21%  statutory  federal  income  tax 
rate  primarily  due  to  state  income  taxes,  partially  offset  by AFUDC  equity  and  a  change  in  our  amortization 
method associated with excess deferred tax  liabilities. The amount of income tax expense relating to AFUDC 
equity and excess deferred tax was recognized as a regulatory asset and regulatory liability, respectively, and is 
not  included  in  the  income  tax  provision.  See  Note  10  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 9 to the consolidated financial statements). In addition, we may from time to time secure 
debt  funding  (including  debt  to  finance  or  refinance  portfolios  of  eligible  projects  based  on  the  green  bond 
framework established by ITC Holdings) 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 

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to  time  repurchase  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 17 to the consolidated 
financial  statements)  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 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  5  and  17  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  (within 
twelve  months)  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 (within twelve months) cash requirements. As 
of  December  31,  2021,  we  had  consolidated  indebtedness  under  our  revolving  credit  agreements  of  $329 
million,  with  unused  capacity  under  our  revolving  credit  agreements  of  $571  million.  ITC  Holdings  had  $155 
million of commercial paper issued and outstanding, net of discount, as of December 31, 2021, with the ability to 
issue  an  additional  $245  million  under  the  commercial  paper  program.  In  2021,  we  paid  $4  million  of  interest 
and commitment fees under our revolving 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, 2021, 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  $3.9  billion  as  of  December  31,  2021,  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 9 
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, 2021 
and 2020.

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 17 to the 
consolidated financial statements 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;

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•

•

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

liabilities to refund deposits from generators for transmission network upgrades.

We  have  exposure  to  LIBOR  through  the  revolving  credit  agreements  of  ITC  Holdings  and  certain  of  our 
Regulated  Operating  Subsidiaries.  Certain  tenors  of  LIBOR  began  being  phased  out  in  late  2021,  with  full 
discontinuation planned for mid-2023. We believe the rate selected as the preferred alternative to LIBOR will be 
an  acceptable  replacement  rate  when  LIBOR  is  fully  discontinued.  However,  we  plan  to  continue  using  the 
available LIBOR tenors until 2023 and as such 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

_____________________

S&P

Moody’s

Rating

Outlook (a)

Rating

Outlook

BBB+
A-2

A

A

A

A

Stable
Stable

Stable

Stable

Stable

Stable

Baa2
Prime-2

A1

A1

A1

A1

Stable
Stable

Stable

Stable

Stable

Stable

(a) On  April  1,  2021,  S&P  reaffirmed  the  ratings  of  ITC  Holdings  and  certain  of  our  Regulated  Operating 

Subsidiaries and revised all outlooks from negative to stable.

Covenants

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, 2021, 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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Table of Contents

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, 2021 compared to year ended December 31, 2020

Year Ended December 31,

2021

2020

2019

$ 

406  $ 

407  $ 

428 

232 

219 

203 

52 
127 
(32)   
785 

(834)   
15 
(5)   
(824)   

(47)   
138 
(85)   
632 

(885)   
2 
5 
(878)   

(55) 
135 
(82) 
629 

(865) 
10 
1 
(854) 

294 
(232)   

561 
(330)   

463 
(250) 

(21)   
— 
(1)   
40 

50 
(23)   
(12)   
246 

1 
6 
7  $ 

— 
6 
6  $ 

11 
— 
(3) 
221 

(4) 
10 
6 

Net cash provided by operating activities was $785 million and $632 million for the years ended December 
31, 2021 and 2020, respectively. The increase in cash provided by operating activities was due primarily to an 
increase in cash received from operating revenues of $162 million compared to the year ended December 31, 
2020 and lower net payments related to the MISO ROE Complaints of $26 million, including interest, refunded 
to  customers.  This  increase  was  partially  offset  by  higher  operation  and  maintenance  expenses  and  general 
and administrative expenses during the year ended December 31, 2021 compared to the year ended December 
31, 2020.

Cash Flows From Investing Activities

Year ended December 31, 2021 compared to year ended December 31, 2020

Net cash used in investing activities was $824 million and $878 million for the years ended December 31, 
2021 and 2020, respectively. The decrease in cash used in investing activities was primarily due to a decrease 
in  capital  expenditures  of  $51  million  and  an  increase  in  contributions  in  aid  of  construction  of  $13  million 
received during the year ended December 31, 2021 compared to the year ended December 31, 2020.

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Cash Flows From Financing Activities

Year ended December 31, 2021 compared to year ended December 31, 2020

Net cash provided by financing activities was $40 million and $246 million for the years ended December 31, 
2021  and  2020,  respectively.  The  decrease  in  cash  provided  by  financing  activities  was  due  primarily  to  a 
decrease  in  issuances  of  long-term  debt  of  $955  million  and  an  increase  in  net  repayments  of  refundable 
deposits for transmission network upgrades of $71 million during the year ended December 31, 2021 compared 
to the year ended December 31, 2020. This decrease was partially offset by a decrease in retirement of long-
term debt of $35 million, an increase in net borrowings under our revolving credit agreements of $232 million, a 
decrease in net repayments under our term loan credit agreements of $200 million, an increase in net issuances 
of  commercial  paper  of  $221  million,  a  decrease  in  dividend  payments  of  $98  million  and  a  decrease  in 
settlement of interest rate swaps of $23 million during the year ended December 31, 2021 compared to the year 
ended  December  31,  2020.  See  Note  9  to  the  consolidated  financial  statements  for  additional  discussion  on 
debt and interest rate swaps.

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  6  to  the  consolidated  financial  statements,  we  had  regulatory  assets  and  liabilities  of  $211 
million  and  $633  million,  respectively,  as  of  December  31,  2021.  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 $26 million relating to 
intangible assets at December 31, 2021 that are described in Note 8 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 6 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

See Note 2 to the consolidated financial statements for a description of the policy for estimating contingent 
obligations.  The  adequacy  of  liabilities  recorded  for  contingent  obligations  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  17  to  the  consolidated  financial  statements  for  discussion  on  contingencies,  including  the 

MISO ROE Complaints.

Pension and Postretirement Benefit Plan Assumptions

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. 
Key assumptions include:

• Discount rates used to determine obligations,

• Expected long-term returns on plan assets,

• Rate of salary increases,

• Mortality, and

• Rate of increase in health care costs.

Discount Rates

Benefit obligations, service cost and interest cost are determined by separately discounting projected benefit 
payments using a yield curve of high-quality corporate bonds. As of December 31, 2021, the weighted-average 
single  equivalent  discount  rate  for  the  benefit  obligation  was  2.86%  and  3.14%  for  our  pension  and 
postretirement benefit plans, respectively. 

Expected Long-Term Rate of Return on Plan Assets

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. For the 

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year ended December 31, 2021, we assumed that our pension and postretirement benefit plans’ assets would 
generate weighted-average long-term rates of return of 5.70% and 4.30%, respectively.

Salary Increases

As of December 31, 2021, we used an annual rate of salary increases of 4.00% to determine our pension 

and postretirement plan obligations.

Mortality

The  Pri-2012  mortality  table  projected  forward  generationally  from  2012  with  the  MP-2020  mortality 
improvement  scale  was  used  to  determine  pension  and  postretirement  plan  obligations  as  of  December  31, 
2021.

Rate of Increase in Healthcare Costs

We used a current year healthcare cost trend rate of 6.00% for 2021 grading down to a 5.00% ultimate rate 
in 2025 in valuing our postretirement benefit obligation as of December 31, 2021. These rates are based on a 
review of recent and expected future experience.

Sensitivity Analysis

The  below  table  displays  the  effect  on  our  costs  and  obligation  of  a  1%  change  to  our  assumptions  as  of 

December 31, 2021:

(in millions of USD)
Change to Pension Plans
Discount Rate
Long-Term Rate of Return on Plan Assets
Change to Postretirement Plan
Discount Rate
Long-Term Rate of Return on Plan Assets
Healthcare Cost Trend Rate

Effect on Costs

Effect on Obligation

1% Increase

1% Decrease

1% Increase

1% Decrease

$—
(1)

(4)
(1)
$4

$2
1

2
1
$(5)

$(17)
N/A

(22)
N/A
$24

$21
N/A

28
N/A
$(19)

See  Note  11  to  the  consolidated  financial  statements  for  further  details  regarding  our  pension  and 

postretirement benefit plan costs and obligations.

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.

Recent Accounting Pronouncements

We have considered all new accounting pronouncements issued by the FASB and determined that it is not 
likely  that  any  of  the  recently  issued  accounting  guidance  will  have  a  material  impact  on  our  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.

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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  $6,995  million  and  $7,119  million  at  December  31,  2021  and  2020, 
respectively. 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 
$6,179  million  and  $6,097  million  at  December  31,  2021  and  2020,  respectively.  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,  2021  and  2020. An 
increase  in  interest  rates  of  10%  (from  5.0%  to  5.5%,  for  example)  at  December  31,  2021  and  2020  would 
decrease the fair value of debt by $217 million and $213 million, respectively, and a decrease in interest rates of 
10% at December 31, 2021 and 2020 would increase the fair value of debt by $231 million and $227 million, 
respectively, at that date.

Revolving Credit Agreements 

At December 31, 2021 and 2020, we had a consolidated total of $329 million and $198 million, respectively, 
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,  2021  and  2020  would  increase  or  decrease  interest 
expense  by  less  than  $1  million  for  an  annual  period  with  a  constant  borrowing  level  of  $329  million  and 
$198 million, respectively.

Commercial Paper

At December 31, 2021 and 2020, ITC Holdings had $155 million and $67 million, respectively, 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  $155  million  and  $67  million  at 
December 31, 2021 and 2020, respectively.

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. 

As  of  December  31,  2021,  we  held  5-year  interest  rate  swap  contracts  with  a  notional  amount  of  $375 
million, which manages interest rate risk associated with the forecasted future issuance of fixed-rate debt at ITC 
Holdings,  the  proceeds  of  which  will  be  used  for  the  expected  repayment  of  the  ITC  Holdings  2.70%  Senior 
Notes, due November 15, 2022. See Note 9 to the consolidated financial statements for further discussion on 
these  interest  rate  swaps.  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  21.5%,  23.5%  and  24.7%,  respectively,  or  $300  million,  $327  million  and  $344  million, 
respectively,  of  our  consolidated  billed  revenues  for  the  year  ended  December  31,  2021. This  portion  of  total 
billed revenues of DTE Electric, Consumers Energy and IP&L include the collection of 2019 revenue accruals 
and deferrals and exclude any amounts for the 2021 revenue accruals and deferrals that were included in our 
2021 operating revenues but will not be billed to our customers until 2023. 

For the year ended December 31, 2020, our credit risk was 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.  These  percentages  and 
amounts  of  total  billed  revenues  of  DTE  Electric,  Consumers  Energy  and  IP&L  include  the  collection  of  2018 

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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 “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 (PCAOB ID No. 34)

Consolidated Statements of Financial Position as of December 31, 2021 and 2020

Consolidated Statements of Comprehensive Income for the Years Ended December 31, 2021, 2020 and 2019

Consolidated Statements of Changes in Stockholder’s Equity for the Years Ended December 31, 2021, 2020 and 
2019

Consolidated Statements of Cash Flows for the Years Ended December 31, 2021, 2020 and 2019

Notes to Consolidated Financial Statements

Schedule I — Condensed Financial Information of Registrant

Page

42

43

45

46

47

48

49

126

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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 consolidated 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, 2021.

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REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Directors and Stockholders 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,  2021  and  2020,  the  related  consolidated  statements  of 
comprehensive  income,  shareholders'  equity,  and  cash  flows  for  each  of  the  three  years  in  the  period  ended 
December 31, 2021, 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, 2021 and 2020, and the results of its operations and 
its cash flows for each of the three years in the period ended December 31, 2021, 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.

Regulatory Matters — Impact of rate regulation on the financial statements – Refer to Notes 2, 5, and 6 
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 

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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 and evaluated 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 10, 2022

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  $2,199  and 

$2,055, respectively)

Other assets

Goodwill

Intangible assets (net of accumulated amortization of $49 and $46, 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 5 and 17)

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, 2021 and 2020

Retained earnings

Accumulated other comprehensive loss

Total stockholder’s equity

December 31,

2021

2020

$ 

5  $ 

128 

45 

21 

18 

217 

4 

114 

42 

52 

12 

224 

9,961 

9,327 

950 

26 

190 

101 

950 

29 

212 

83 

1,267 

1,274 

$ 

11,445  $ 

10,825 

$ 

127  $ 

130 

72 

56 

64 

14 

44 

654 

16 

1,047 

52 

1,161 

619 

28 

55 

6,009 

55 

55 

61 

14 

37 

67 

18 

437 

59 

1,013 

612 

65 

50 

6,295 

8,971 

8,531 

892 

1,584 

(2) 

2,474 

892 

1,410 

(8) 

2,294 

TOTAL LIABILITIES AND STOCKHOLDER’S EQUITY

$ 

11,445  $ 

10,825 

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 INCOME (LOSS)

Derivative instruments, net of tax (Note 13)

TOTAL OTHER COMPREHENSIVE INCOME (LOSS), NET OF TAX 

Year Ended December 31,

2021

2020

2019

$ 

1,358  $ 

1,290  $ 

(9) 

1,349 

8 

1,298 

1,286 

41 

1,327 

108 

128 

232 

133 

(1) 

600 

749 

251 

(30) 

(5) 

216 

533 

127 

406 

6 

6 

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 

TOTAL COMPREHENSIVE INCOME

$ 

412  $ 

392  $ 

431 

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, 2018

Net income

Dividends to ITC Investment Holdings

Other comprehensive income, net of tax (Note 13)

BALANCE, DECEMBER 31, 2019

Net income

Dividends to ITC Investment Holdings

Other comprehensive loss, net of tax (Note 13)

BALANCE, DECEMBER 31, 2020

Net income

Dividends to ITC Investment Holdings

Other comprehensive income, net of tax (Note 13)

BALANCE, DECEMBER 31, 2021

$ 

$ 

$ 

$ 

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 

— 

— 

— 

406 

(232) 

— 

— 

— 

6 

406 

(232) 

6 

892  $ 

1,584  $ 

(2)  $ 

2,474 

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

Accounts payable

Accrued interest
Accrued compensation

Accrued taxes

Net refund settlements 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 issuance (repayment) 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,

2021

2020

2019

$ 

406  $ 

407  $ 

428 

232 

52 

127 

(30) 

34 

6 

(18) 

(3) 

1 
(3) 

3 

(5) 

(17) 

785 

219 

(47) 

138 

(27) 

25 

4 

— 

4 

7 
(14) 

(3) 

(65) 

(16) 

632 

203 

(55) 

135 

(29) 

32 

10 

(10) 

(11) 

(2) 
10 

3 

(82) 

(3) 

629 

(834) 

(885) 

(865) 

15 

(5) 

2 

5 

10 

1 

(824) 

(878) 

(854) 

75 

1,175 

— 

88 

— 

1,030 

1,495 

275 

(133) 

(35) 

(1,044) 

(1,596) 

— 

(232) 
18 

(39) 
— 
(1) 

40 

1 

6 

(475) 

(330) 
60 

(10) 
(23) 
(12) 

246 

— 

6 

175 

1,090 

200 

200 

(203) 

(999) 

— 

(250) 
19 

(8) 
— 
(3) 

221 

(4) 

10 

6 

CASH, CASH EQUIVALENTS AND RESTRICTED CASH — End of period

$ 

7  $ 

6  $ 

See notes to consolidated financial statements.

48

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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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, passive, non-voting 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 cost-based rates 
regulated  by  the  FERC.  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 
outbreak of COVID-19 have resulted in challenges to businesses and facilities in various industries around the 
world, including our customers, and disruptions to the global economy and supply chains. To date, COVID-19 
has not had a material impact on our net income. However, for 2020, we utilized 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  for  our  customers  that  were  collected  through  our 
Formula Rates.

We are unable to predict the ultimate effects of COVID-19 on the U.S. or global economy or our operations. 
We continue to monitor developments affecting our workforce, customers, suppliers, and operations. The extent 
of the impact of COVID-19 will depend on its duration, actions by government authorities, and impacts on our 
customers,  employees,  or  vendors.  These  developments  are  continuously  evolving,  and  we  cannot  predict 
whether COVID-19 will have a material impact on our financial condition, results of operations or cash flows.

2.  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 

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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,  2021,  2020  and  2019  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 $223 million, $209 million and $194 million for 2021, 2020 and 2019, 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 
rates. Periodically we perform depreciation studies of the assets at our Regulated Operating Subsidiaries. 
The results of these studies are submitted to, and require approval from the FERC prior to changing our 
depreciation  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  2021,  2020  and  2019. 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 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  $8 
million, $7 million and $8 million for 2021, 2020 and 2019, respectively.

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 

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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  15.  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 11. Gains and losses associated 
with our mutual funds as described in Note 12 are recorded in earnings.

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. At December 31, 2021 and 2020, 
we  had  goodwill  balances  recorded  at  ITCTransmission,  METC  and  ITC  Midwest  of  $173  million,  $454 
million and $323 million, respectively.

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, 2021 and 
determined  that  no  impairment  exists.  There  were  no  events  subsequent  to  October  1,  2021  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 8 for additional discussion on our 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 

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amortized over the life of the debt. 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.  We  recorded  $5  million  during  the  years  ended 
December  31,  2021,  2020  and  2019  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. Our asset retirement obligations as of December 31, 
2021 and 2020 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 
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 9 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, 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.  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, 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.

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 

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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  5  under  “Cost-Based  Formula  Rates 
with  True-Up  Mechanism”  and  Note  3  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.

Refer to Note 14 for additional discussion of the plans.

Comprehensive Income (Loss) — Comprehensive income (loss) is the change in 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, 2021, 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 2017 to 2020. 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  6  and  10  for 
additional discussion on income taxes.

3.  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.

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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  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.

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 
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 4 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 $6 million, $5 million and $7 million for the years ended December 31, 2021, 2020 and 2019, 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 5 for more information on our 
Formula Rates.

4.  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

December 31,

2021

2020

2019

2018

$ 

3  $ 

2  $ 

2  $ 

116 

9 
128  $ 

102 

10 

102 

13 

114  $ 

117  $ 

$ 

2 

92 

8 
102 

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5.  REGULATORY MATTERS

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  17  for  detail  on  ROE  matters  for  our  MISO  Regulated  Operating  Subsidiaries  and  "Incentive Adders  for 
Transmission Rates" discussed 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.

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, 2021:

(In millions of USD)

Net regulatory assets as of December 31, 2020

Net collection of 2019 revenue deferrals and accruals, including accrued interest

Net revenue deferral for the year ended December 31, 2021

Net regulatory liabilities as of December 31, 2021

Total

50 

(43) 

(9) 

(2) 

$ 

$ 

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 (liabilities) assets

December 31,

2021

2020

$ 

20  $ 

10 

(13)   

(19)   

$ 

(2)  $ 

44 

19 

(1) 

(12) 

50 

Incentive Adders for Transmission Rates

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. On March 20, 2020, the FERC 
issued a NOPR and on April 15, 2021, the FERC issued a supplemental NOPR that was a proposal to update 
the transmission incentives policy. As of December 31, 2021, no final determination had been made on these 
NOPRs and we cannot predict whether this will have a material impact on us.

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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. At the time of the complaint, 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. On September 11, 2019, the MISO Regulated Operating Subsidiaries filed an 
appeal of the FERC’s order in the D.C. Circuit Court and on February 19, 2021, the appeal was denied. As a 
result,  the  FERC’s  October  18,  2018  order  was  upheld  without  further  impact  on  our  financial  condition, 
consolidated results of operations or cash flows.

For each of the years ended December 31, 2021, 2020 and 2019, the authorized incentive adders for the 
MISO  Regulated  Operating  Subsidiaries  included  a  25  basis  point  adder  for  independent  transmission 
ownership and a 50 basis point adder for RTO participation. See Note 17 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 adder 
for independent transmission ownership that is included in the transmission rate charged by 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. 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  Rate.  In  addition,  the  order  directed  ITC  Great  Plains  to  provide  refunds,  with  interest,  for  the 
period from June 11, 2019 through July 16, 2020. During the fourth quarter of 2020, refunds of $4 million were 
made to settle the refund liability. ITC Great Plains filed appeals in the D.C. Circuit Court for the various FERC 
orders in the proceedings for ITC Great Plains. On March 4, 2021, these appeals were dismissed following a 
motion for voluntary dismissal by ITC Great Plains in response to the denial of the appeal of the FERC’s order 
to  reduce  the  adder  for  independent  transmission  ownership  for  each  of  the  MISO  Regulated  Operating 
Subsidiaries.  The  dismissal  of  the  appeals  did  not  result  in  additional  impacts  to  our  consolidated  results  of 
operations, cash flows or financial condition.

Prior to the issuance of the FERC order on July 16, 2020, 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, the 
authorized ROE used by ITC Great Plains was revised to 11.41% and is currently 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 17 for a discussion of the MISO ROE Complaints.

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6.  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 less than $1 and $2 as of 
December 31, 2021 and 2020, respectively) (a)
Amounts recoverable related to the Initial Complaint (including accrued interest 
of less than $1 and $2 as of December 31, 2021 and 2020, respectively) (b)

Total current

Non-current:

Revenue accruals (including accrued interest of less than $1 as of December 
31, 2021 and 2020) (a)
ITCTransmission ADIT deferral (net of accumulated amortization of $57 and $54 
as of December 31, 2021 and 2020, respectively)
METC ADIT deferral (net of accumulated amortization of $35 and $33 as of 
December 31, 2021 and 2020, respectively)
METC regulatory deferrals (net of accumulated amortization of $12 and $11 as 
of December 31, 2021 and 2020, respectively)

Income taxes recoverable related to AFUDC equity
ITC Great Plains start-up, development and pre-construction (net of 
accumulated amortization of $9 and $7 as of December 31, 2021 and 2020, 
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,

2021

2020

$ 

20  $ 

1 

21 

10 

4 

8 

3 

114 

4 

20 

6 

21 

190 

$ 

211  $ 

44 

8 

52 

19 

7 

10 

4 

106 

6 

30 

6 

24 

212 

264 

(a) Refer  to  discussion  of  revenue  accruals  in  Note  5  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 in Note 17 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  2021,  2020  and  2019,  which  is 
included  in  depreciation  and  amortization  in  our  consolidated  statements  of  comprehensive  income  and 
recovered through ITCTransmission’s cost-based Formula Rate template.

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 

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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  2021,  2020 
and 2019, 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 2021, 2020 and 2019, 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,  the 
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 amortizes them 
over  a  10-year  period,  that  began  in  the  second  quarter  of  2015.  The  amortization  expense  is  recorded  to 
general  and  administrative  expenses  in  our  consolidated  statements  of  comprehensive  income  and  is 
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 
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.

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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 $1 and less than $1 as of 
December 31, 2021 and 2020, respectively) (a)
Refund related to the Initial Complaint (including accrued interest of $1 as of 
December 31, 2020) (b)

Other

Total current 

Non-current:

Revenue deferrals (including accrued interest of less than $1 as of December 
31, 2021 and 2020) (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,

2021

2020

$ 

13  $ 

— 

1 

14 

19 

70 

3 

495 

31 

1 

619 

$ 

633  $ 

1 

13 

— 

14 

12 

73 

3 

507 

16 

1 

612 

626 

(a) Refer  to  discussion  of  revenue  deferrals  in  Note  5  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 in Note 17 under “Rate of Return on Equity Complaints.”

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 
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 

59

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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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,  we  were  required  to  revalue  our  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.  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 requires the use of either the ARAM or the alternative method, RSGM, for assets related to public utility 
property.  Prior  to  2021,  the  ARAM  method  was  used  for  the  return  of  excess  deferred  taxes  to  customers 
associated with public utility property. Beginning in 2021, we began using RSGM for the return of all remaining 
categories  of  excess  deferred  taxes  to  customers,  pursuant  to  the  interpretation  of  recent  released  revenue 
procedures  and  private  letter  rulings.  During  the  years  ended  December  31,  2021  and  2020,  we  recorded  $8 
million  and  $2  million,  respectively,  of  amortization  related  to  the  excess  deferred  taxes  under  RSGM  and 
ARAM. 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.

7.  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,

2021

2020

Property, plant and equipment in service

$ 

11,434  $ 

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

529 

96 

87 

14 

12,160 

(2,199)   

$ 

9,961  $ 

523 

103 

81 

14 

11,382 

(2,055) 

9,327 

Additions  to  property,  plant  and  equipment  in-service  and  construction  work  in  progress  during  2021  and 
2020 were due primarily to projects to upgrade or replace existing transmission plant and 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.  Additionally,  in  2020,  we 
made asset acquisitions which added to our in-service property, plant and equipment.

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8. 

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  6.  The  carrying  amounts  of  the  intangible  asset  for  the  METC  Regulatory 
Deferrals and the METC ADIT Deferral were $10 million and $3 million (net of accumulated amortization of $30 
million  and  $16  million),  respectively,  as  of  December  31,  2021,  and  $12  million  and  $4  million  (net  of 
accumulated  amortization  of  $28  million  and  $15  million),  respectively,  as  of  December  31,  2020.  The 
amortization  periods  for  the  METC  Regulatory  Deferrals  and  the  METC ADIT  Deferral  are  20  and  18  years, 
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 (net of accumulated amortization of $3 million) as of 
both December 31, 2021 and 2020. The amortization period for these intangible assets is 50 years, beginning 
March 31, 2011.

We recognized $3 million, $4 million, and $3 million of amortization expense for our intangible assets during 
the years ended December 31, 2021, 2020 and 2019, 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, 2021 to be as follows:

(In millions of USD)

2022

2023

2024

2025

2026

2027 and thereafter

Total

$ 

$ 

3 

4 

3 

2 

2 

12 

26 

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9.  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,

2021

2020

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 (a)

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

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

ITC Holdings Revolving Credit Agreement, due October 18, 2024

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 18, 2024

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 2.90% Senior Secured Notes, Series A, due August 3, 2051

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

METC Revolving Credit Agreement, due October 18, 2024

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

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 18, 2024

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

ITC Great Plains Revolving Credit Agreement, due October 18, 2024

Other

Total principal

Unamortized deferred financing fees and discount

Total debt

____________________________

250 

400 

300 

400 

500 

500 

700 

39 

155 

100 

285 

100 

225 

75 

88 

50 

75 

150 

200 

50 

50 

75 

150 

30 

175 

75 

100 

100 

225 

200 

175 

180 

139 

150 

33 

3 

200 

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 

— 

6,702 

(39) 

$ 

6,663  $ 

6,405 

(43) 

6,362 

(a) As of December 31, 2021 and 2020 there was $654 million and $67 million, respectively, net of unamortized 
deferred  financing  fees  and  discount,  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, 2021 are as follows:

(In millions of USD)

2022

2023

2024

2025

2026

2027 and thereafter

Total

ITC Holdings

Senior Unsecured Notes

$ 

$ 

655 

250 

804 

— 

400 

4,593 

6,702 

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.

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, 
2021,  ITC  Holdings  had  $155  million  of  commercial  paper,  net  of  discount,  issued  and  outstanding  under  the 
program, with a weighted-average interest rate of 0.2% and weighted average remaining days to maturity of 32 
days. The amount outstanding as of December 31, 2021 was classified as debt maturing within one year in the 
consolidated  statements  of  financial  position.  As  of  December  31,  2020,  ITC  Holdings  had  $67  million  of 
commercial paper issued and outstanding.

ITCTransmission

First Mortgage Bonds

On  January  14,  2022,  ITCTransmission  issued  $130  million  of  aggregate  principal  amount  of  2.93%  First 
Mortgage  Bonds,  Series  J  due  January  14,  2052.  The  proceeds  were  used  to  repay  existing  indebtedness 
under the revolving credit agreement and intercompany loan agreement and will also be used to partially fund 
capital expenditures and for general corporate purposes. ITCTransmission also issued an additional $20 million 
of aggregate principal amount of 2.93% First Mortgage Bonds, Series I due January 14, 2052, the proceeds of 
which  are  expected  to  fund  or  refinance  a  portfolio  of  eligible  renewable  energy  projects  based  on  the  green 
bond framework established by ITC Holdings. 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 August 3, 2021, METC issued $75 million of 2.90% Series A Senior Secured Notes, due August 3, 2051. 
The proceeds from the Series A Senior Secured Notes are expected to fund or refinance a portfolio of eligible 
renewable  energy  projects  based  on  the  green  bond  framework  established  by  ITC  Holdings.  METC  has  an 
additional $75 million delayed draw of 3.05% Series B Senior Secured Notes in May 2022 with a due date 30 
years  from  the  date  of  issuance.  The  proceeds  from  the  Series  B  Senior  Secured  Notes  are  expected  to  be 
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.

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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. 

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

We have entered into interest rate swaps to manage interest rate risk associated with the forecasted future 
issuance of fixed-rate debt at ITC Holdings, the proceeds of which will be used for the expected repayment of 
the ITC Holdings 2.70% Senior Notes, due November 15, 2022. At December 31, 2021, ITC Holdings had the 
following interest rate swaps:

Interest Rate Swaps
(in millions of USD, except 
percentages)

Notional 
Amount

Weighted Average 
Fixed Rate

Original Term

Effective Date

July 2021 swap

$ 

November 2021 swap

November 2021 swap

November 2021 swap

November 2021 swap

December 2021 swap

December 2021 swap

December 2021 swap

45 

45 

45 

45 

50 

50 

50 

45 

1.113%

1.581%

1.492%

1.497%

1.544%

1.560%

1.489%

1.475%

5 years

November 2022

5 years

November 2022

5 years

November 2022

5 years

November 2022

5 years

November 2022

5 years

November 2022

5 years

November 2022

5 years

November 2022

Total

$ 

375 

1.471%

The 5-year term interest rate swaps call for ITC Holdings to receive interest quarterly at a variable rate equal 
to  LIBOR  and  to  pay  interest  semi-annually  at  various  fixed  rates  effective  for  the  5-year  period  beginning 
November 15, 2022. The weighted-average interest  rate of the interest rate swaps was 1.471% at December 
31, 2021. The agreements include a mandatory early termination provision and will be terminated no later than 
the  effective  date  of  the  interest  rate  swaps  of  November  15,  2022.  The  interest  rate  swaps  have  been 
determined  to  be  highly  effective  at  offsetting  changes  in  the  fair  value  of  the  forecasted  interest  cash  flows 
associated with the debt issuance, resulting from changes in benchmark interest rates from the trade date of the 
interest rate swaps to the issuance date of the debt obligation. 

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The  interest  rate  swaps  qualify  for  cash  flow  hedge  accounting  treatment,  whereby  any  gain  or  loss 
recognized  from  the  trade  date  to  the  effective  date  is  recorded  net  of  tax  in  AOCI.  This  amount  will  be 
accumulated  and  amortized  as  a  component  of  interest  expense  over  the  life  of  the  forecasted  debt.  As  of 
December  31,  2021,  the  fair  value  of  the  derivative  instruments  of  $2  million  was  recorded  in  other  current 
assets  in  the  consolidated  statements  of  financial  position. The  interest  rate  swaps  do  not  contain  credit-risk-
related contingent features. Refer to Note 12 for additional fair value information. As of December 31, 2020, ITC 
Holdings did not have any interest rate swaps outstanding.

Revolving Credit Agreements

On May 17, 2021, ITC Holdings, ITCTransmission, METC, ITC Midwest and ITC Great Plains amended their 
respective revolving credit agreements each dated October 23, 2017, as previously amended and restated on 
January 10, 2020. The amendments extend the maturity date of the revolving credit agreements from October 
2023 to October 2024. The determination of the applicable interest rates and commitment fee rates in the new 
agreements  is  consistent  with  the  previous  agreements  and  remains  subject  to  adjustment  based  on  the 
borrower’s  credit  rating.  At  December  31,  2021,  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  $ 

39  $ 

361  (d)

100 

100 

225 

75 

88 

30 

139 

33 

12 

70 

86 

42 

$ 

900  $ 

329  $ 

571 

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 
$206 million as of December 31, 2021.

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10.  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,

2021

2020

2019

Income tax expense at 21% federal statutory rate

$ 

112  $ 

114  $ 

State income taxes (net of federal benefit)

AFUDC equity

Revaluation of deferred federal income taxes (a)

Valuation allowance

Other, net

Total income tax provision

____________________________

24 

(5)   

(9)   

4 

1 

28 

(4)   

(2)   

— 

— 

118 

22 

(5) 

(2) 

— 

(1) 

$ 

127  $ 

136  $ 

132 

(a) Amount  for  the  year  ended  December  31,  2021  is  related  to  the  change  in  our  amortization  method 
associated  with  excess  deferred  tax  liabilities.  Refer  to  discussion  in  Note  6  under  “Income  Taxes 
Refundable Related to Implementation of the TCJA”.

Components of the income tax provision were as follows:

(In millions of USD)

Current income tax benefit

Deferred income tax expense

Total income tax provision

Year Ended December 31,

2021

2020

2019

$ 

$ 

—  $ 

(2)  $ 

127 

138 

127  $ 

136  $ 

(3) 

135 

132 

For  the  years  ended  December  31,  2021,  2020  and  2019,  our  effective  tax  rates  were  23.8%,  25.0%  and 

23.6%, respectively.

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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

Regulatory liability gross up — TCJA

Pension and postretirement liabilities

State income tax NOLs (net of federal benefit) 

True-up adjustment principal & interest

Valuation allowance

Other, net

Net deferred tax liabilities 

Gross deferred income tax liabilities

Gross deferred income tax assets

Valuation allowance

Net deferred tax liabilities

____________________________

(a) Described in Note 6

December 31,

2021

2020

$ 

(1,274)  $ 

(1,156) 

49 

(3)   

(3)   

(145)   

131 

22 

57 

— 

(4)   

9 

85 

(4) 

(5) 

(139) 

134 

20 

58 

(14) 

— 

8 

$ 
$ 

(1,161)  $ 
(1,434)  $ 

(1,013) 
(1,333) 

277 

(4)   

320 

— 

$ 

(1,161)  $ 

(1,013) 

We  had  federal  income  tax  NOLs  as  of  December  31,  2021.  We  expect  to  use  our  NOLs  prior  to  their 
expirations starting in 2036. We also had state income tax NOLs as of December 31, 2021. While we expect to 
utilize the majority of these state NOLs prior to their expiration, we believe that it is more likely than not that the 
benefit from certain state NOL carryforwards will not be realized. In recognition of this risk, we have provided a 
valuation allowance of $4 million on the deferred tax assets related to these state NOL carryforwards.

11.  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 2021, 2020, and 2019. We expect to contribute $3 million to the retirement plan in 
2022.

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 $54 million and 
$56 million at December 31, 2021 and 2020, 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, 2021, 2020, and 2019, we contributed $3 million, $3 million, and $1 million, 
respectively, to these supplemental benefit plans.

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We provide certain postretirement health care, dental, and life insurance benefits for eligible employees (the 
“postretirement benefit plan”). We contributed $8 million, $10 million, and $9 million to the postretirement benefit 
plan in 2021, 2020, and 2019, respectively. We expect to contribute $8 million to the postretirement benefit plan 
in 2022.

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

follows:

(In millions of USD)

2021

2020

2019

2021

2020

2019

Pension Plans

Years Ended December 31,

Postretirement Benefit Plan

 Years Ended December 31,

9 

4 

(4) 

— 

9 

Service cost

Interest cost

Expected return on plan assets

Amortization of unrecognized loss  

$ 

9  $ 

8  $ 

7  $ 

11  $ 

11  $ 

3 

(6)   

1 

4 

(6)   

1 

5 

(5)   

1 

3 

(6)   

— 

4 

(5)   

— 

Net benefit cost

$ 

7  $ 

7  $ 

8  $ 

8  $ 

10  $ 

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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,

2021

2020

2021

2020

Beginning projected benefit obligation

$ 

(162)  $ 

(141)  $ 

(122)  $ 

(113) 

(11) 

(4) 

2 

3 

1 

— 

95 

16 

10 

(1) 

120 

(2) 

N/A

N/A

— 

(2) 

— 

— 

(2) 

(14) 

(2) 

(16) 

Service cost

Interest cost

Plan amendments

Actuarial net gain/(loss)

Benefits paid

Settlements

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)/overfunded

Accumulated benefit obligation:

Retirement plan

Supplemental benefit plans

Total accumulated benefit obligation 

Amounts recorded as:

Funded Status:

(9)   

(3)   

— 

5 

7 

2 

(8)   

(4)   

— 

(16)   

7 

— 

(11)   

(3)   

— 

8 

1 

— 

(160)   

(162)   

(127)   

(122) 

107 

10 

4 

(4)   

117 

91 

15 

4 

(3)   

107 

120 

13 

8 

(1)   

140 

(43)  $ 

(55)  $ 

13  $ 

(99)  $ 

(54)   

(95) 

(60) 

N/A

N/A

(153)  $ 

(155)  $ 

—  $ 

$ 

$ 

$ 

Accrued pension and postretirement liabilities

$ 

(52)  $ 

(57)  $ 

—  $ 

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

$ 

$ 

$ 

13 

(4)   

6 

(4)   

13 

— 

(43)  $ 

(55)  $ 

13  $ 

19  $ 

1 

20  $ 

30  $ 

— 

30  $ 

(29)  $ 

(2)   

(31)  $ 

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 6. 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,  2021  and  2020  does  not  reflect  the  potential  receipt  of  any 
subsidies under the Medicare Prescription Drug, Improvement and Modernization Act of 2003.

The  net  actuarial  gains  for  the  year  ended  December  31,  2021  within  the  change  in  benefit  obligation  for 
both the pension plans and postretirement benefit plan are primarily the result of increases in the discount rates 
and actual returns on plan assets greater than expected.

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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,

2021

2020

$ 

(56)  $ 

— 

(61) 

— 

(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,

2021

2020

$ 

(54)  $ 

— 

(60) 

— 

(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,

2021

2.86%

4.00%

4.00%

N/A

N/A

N/A

N/A

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

Postretirement Benefit Plan

December 31,

2021

2020

2019

3.14%

2.94%

3.61%

N/A

4.00%

5.75%

5.00%

2025

N/A

4.00%

6.00%

5.00%

2025

N/A

4.00%

6.25%

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,

2021

2020

2019

2021

2020

2019

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

2.77%

3.47%

4.42%

3.20%

3.80%

4.58%

1.93%

4.00%

4.00%

N/A

N/A

N/A

2.91%

4.00%

4.00%

N/A

N/A

N/A

3.99%

4.50%

4.00%

N/A

N/A

N/A

2.50%

3.30%

4.28%

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

5.70%

6.00%

6.60%

4.30%

4.50%

5.00%

At December 31, 2021, 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)

2022

2023

2024

2025

2026

2027 through 2031

Pension Plans

$ 

8  $ 

9 

9 

10 

10 

63 

Postretirement 
Benefit Plan

2 

2 

2 

3 

3 

22 

Investment Objectives and Fair Value Measurement

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, 2021 and 2020, 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

2021

2021

2020

2021

2020

 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, 2021 and 2020, there were no transfers between levels.

For  the  years  ended  December  31,  2021  and  2020,  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,

2021

2020

2021

2020

$ 

47  $ 
12 
58 

43  $ 
11 
53 

67  $ 

3 
70 

$ 

117  $ 

107  $ 

140  $ 

57 
3 
60 
120 

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  2021, 
$6 million in 2020, and $5 million in 2019.

12.  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, 2021 and 2020, there were no transfers between levels.

Our assets measured at fair value subject to the three-tier hierarchy at December 31, 2021, 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)

$ 

$ 

51  $ 

—  $ 

12 

— 

— 

2 

63  $ 

2  $ 

— 

— 

— 

— 

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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  $ 

—  $ 
— 
— 
—  $ 

— 
— 
— 
— 

As of December 31, 2021 and 2020, 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 11. 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, 2021, the assets related to derivatives consist of interest rate swaps as discussed in 
Note 9. 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, 2021 and 2020. Refer to Note 8 
for additional information on our 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 credit agreements and commercial paper, was $6,995 
million  and  $7,119  million  at  December  31,  2021  and  2020,  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  credit 
agreements  and  commercial  paper,  was  $6,179  million  and  $6,097  million  at  December  31,  2021  and  2020, 
respectively.

Revolving Credit Agreements

At December 31, 2021 and 2020, we had a consolidated total of $329 million and $198 million, respectively, 
outstanding under our revolving 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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13. 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

Derivative Instruments

Reclassification of net loss relating to interest rate cash flow hedges 

from AOCI to earnings (net of tax of $2 for the year ended December 
31, 2021, $1 for the year ended December 31, 2020 and less than 
$1 for the year ended December 31, 2019) (a)

Gain (loss) on interest rate swaps relating to interest rate cash flow 

hedges (net of tax of $1 for the year ended December 31, 2021, $8 
for the year ended December 31, 2020 and $1 for the year ended 
December 31, 2019)

Total other comprehensive income (loss), net of tax
Balance at the end of period

____________________________

Year Ended December 31,

2021

2020

2019

$ 

(8)  $ 

7  $ 

4 

4 

2 

6 
(2)  $ 

$ 

3 

(18)   

(15)   

(8)  $ 

1 

2 

3 
7 

(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, 2022 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.

14.  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,

2021

2020

2019

$ 

$ 

$ 

2  $ 

2  $ 

32 

9 

23 

7 

43  $ 

32  $ 

9  $ 

8  $ 

2 

30 

8 

40 

8 

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

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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, 2021:

PBUs at December 31, 2020

Granted

Vested and paid out

Forfeited

PBUs at December 31, 2021

Number of

Performance

Based Units

900,951 

314,940 

(291,325) 

(25,474) 

899,092 

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,

2021

2020

$ 

$ 

28  $ 

25 

53  $ 

20 

22 

42 

The  aggregate  fair  value  of  PBUs  as  of  December  31,  2021  and  2020  was  $72  million  and  $59  million, 
respectively. At December 31, 2021, $19 million of total unrecognized compensation cost related to PBUs not 
yet vested is expected to be recognized over the remaining weighted-average period of 1.7 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, 2021:

SBUs at December 31, 2020

Granted
Vested and paid out
Forfeited

SBUs at December 31, 2021

Number of

Service

Based Units

687,710 
247,181 
(219,605) 
(25,474) 
689,812 

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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,

2021

2020

$ 

$ 

11  $ 

11 

22  $ 

9 

10 

19 

The  aggregate  fair  value  of  SBUs  as  of  December  31,  2021  and  2020  was  $32  million  and  $28  million, 
respectively. At December 31, 2021, $10 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 1.7 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, 2021, 2020, and 2019 was less than $1 
million, respectively.

15.  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 2. We have investments in jointly owned utility 
assets as shown in the table below as of December 31, 2021:

(In millions of USD)

ITCTransmission (b)

METC (c)

ITC Midwest (d)

ITC Great Plains (e)

Total

____________________________

Net Investments (a)

Substations

Lines

$ 

$ 

—  $ 

17 

49 

10 

76  $ 

29 

41 

103 

23 

196 

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

interest amounts of other parties.

(b) ITCTransmission has a 49.6% joint ownership in 345 kV transmission lines with a municipal power agency. 

(c) METC  has  joint  ownership  in  several  assets  within  various  substations  and  several  345  kV  transmission 
lines  with  various  parties  including  Consumers  Energy.  As  of  December  31,  2021,  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, 2021. In addition to the jointly held plant in-
service,  ITC  Midwest  has  $71  million  of  construction  work  in  progress  for  jointly  held  plant  in  the 
consolidated statements of financial position as of December 31, 2021. 

(e) ITC Great Plains has a 51.0% joint ownership in a transmission project with an electric cooperative.

16.  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 

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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 $2 million and less than $1 
million at December 31, 2021 and December 31, 2020, respectively, and intercompany payables to Fortis and 
such subsidiaries of less than $1 million at December 31, 2021 and December 31, 2020. 

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,  2021,  2020  and 
2019 of $10 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 each of the years ended December 
31, 2021 and 2020, and less than $1 million for the year ended December 31, 2019.

Dividends

We paid dividends of $232 million, $330 million and $250 million during the years ended December 31, 2021, 
2020 and 2019, respectively, to ITC Investment Holdings. ITC Holdings also paid dividends of $64 million to ITC 
Investment Holdings in January 2022.

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 did not have a 
material impact on our consolidated financial condition, results of operations or cash flows.

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. During the year 
ended December 31, 2021, we did not make or receive any tax-related payments with ITC Investment Holdings. 
During year ended December 31, 2020, we paid $2 million to ITC Investment Holdings for matters related to the 
State of Michigan income taxes. During the year ended December 31, 2019 we did not make or receive any tax-
related payments with ITC Investment Holdings.

During  each  of  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.

17.  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,  require  reporting  of  emissions  from  certain  equipment, 
establish standards for the management, treatment, storage, transportation and disposal of hazardous materials 
and  of  solid  and  hazardous  wastes,  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 would increase our costs for such compliance in a manner 
that  would  be  expected  to  have  a  material  adverse  effect  on  our  financial  condition,  results  of  operations  or 
liquidity.

Our  assets  and  operations  also  involve  the  use  of  materials  classified  as  hazardous,  toxic  or  otherwise 
dangerous. Some 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 above ground 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 

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contained  PCBs.  Some  of  our  facilities  and  electrical  equipment  may  also  contain  asbestos  containing 
materials. Our facilities and equipment are often situated close to or on property owned by others so that, if they 
are  the  source  of  contamination,  the  property  of  others  may  be  affected.  For  example,  above  ground  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, including wetlands and habitat for threatened 
and endangered species.

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 a 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 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 

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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.

November 2019 Order

On  November  21,  2019,  the  FERC  issued  an  order  in  the  MISO  ROE  Complaints  which  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, in 2019, we reversed the aggregate estimated current liability we had previously 
recorded for the Second Complaint. 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.  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 
asserted 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 of the November 2019 Order 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, the 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. On October 
8, 2020, the FERC granted an extension to September 23, 2021 and on August 2, 2021 the FERC granted a 
second extension to February 28, 2022. On December 16, 2021, MISO requested a third extension to May 31, 
2022, and that remains pending. 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, 2021, we had recorded an aggregate current regulatory asset and liability of $1 million 
and  less  than  $1  million,  respectively,  and  as  of  December  31,  2020,  we  had  recorded  an  aggregate  current 
regulatory  asset  and  liability  of  $8  million  and  $13  million,  respectively,  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, 2021, we refunded net settlement payments of 
$5  million  due  to  customers  related  to  this  ROE  matter  and  during  the  year  ended  December  31,  2020,  we 
refunded net settlement payments of $31 million due to customers related to this ROE matter.

Although the November 2019 Order and May 2020 Order dismissed the Second Complaint with no refunds 
required, it is possible upon resolution of the pending appeals that our MISO Regulated Operating Subsidiaries 
could be required to provide material refunds related to the Second Complaint.

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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  5  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
Estimated net income increase

Year Ended December 31,

2021

2020

2019

$ 

—  $ 
— 
— 

32  $ 
(3)   
25 

69 
(12) 
61 

As  of  December  31,  2021,  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, 2021, we had purchase obligations of $126 million representing commitments for materials, 
services  and  equipment  that  had  not  been  received  as  of  December  31,  2021,  primarily  for  construction  and 
maintenance projects for which we have an executed contract. Of these purchase obligations, $107 million is 
expected to be paid in 2022, 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.

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  21.5%,  23.5%  and  24.7%,  respectively,  or  $300  million,  $327  million  and  $344  million, 

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respectively,  of  our  consolidated  billed  revenues  for  the  year  ended  December  31,  2021. This  portion  of  total 
billed revenues of DTE Electric, Consumers Energy and IP&L include the collection of 2019 revenue accruals 
and deferrals and exclude any amounts for the 2021 revenue accruals and deferrals that were included in our 
2021  operating  revenues  but  will  not  be  billed  to  our  customers  until  2023.  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.

18.  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,

2021

2020

2019

2018

5  $ 

4  $ 

4  $ 

6 

2 

7  $ 

2 

6  $ 

2 

6  $ 

4 

10 

$ 

$ 

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 
as well as amounts liquidated to make benefit payments related to our supplemental benefit plans.

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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,

2021

2020

2019

$ 

237  $ 

236  $ 

228 

— 

— 

140 

30 

— 
3 

2 

2 

135 

27 

— 
— 

— 

3 

92 

29 

5 
— 

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
Other

____________________________

(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, 2021, 
2020 or 2019, respectively, but will be or have been included as a cash outflow from investing activities for 
expenditures for property, plant and equipment or repayments of contributions in aid of construction when 
paid.

19.  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.

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.

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2021

(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

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

$ 

1,386  $ 

1  $ 

(38)  $ 

1,349 

231 

123 

691 

173 

518 

9,954 

950 

11,317 

841 

1 

129 

(158)   

(46)   

406 

7 

— 

6,134 

— 

— 

(1)   

— 

— 

(518)   

— 

— 

232 

251 

533 

127 

406 

9,961 

950 

(6,006)   

11,445 

(7)   

834 

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 

(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,  2021  that  have  materially  affected,  or  are  reasonably  likely  to  materially  affect,  our  internal 
control over financial reporting.

ITEM 9B.   OTHER INFORMATION.

None.

ITEM 9C.   DISCLOSURE REGARDING FOREIGN JURISDICTIONS THAT PREVENT INSPECTIONS.

Not Applicable.

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.

The  Board  must  consist  of  the  Chief  Executive  Officer  of  the  Company  (Ms.  Apsey),  a  minority  of 
representatives  of  Fortis  (Mr.  Hutchens  and  Ms.  Perry)  and  a  majority  of  directors  who  are  independent  of 
Fortis. Mr. Laurito previously served as a Fortis representative until his retirement from Fortis on December 31, 
2021. Due to Mr. Laurito’s affiliation with Fortis, he will remain a non-independent director for at least 3 years 
from his retirement from 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, 52. 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 

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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 
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.  The  Board  selected  Ms. Apsey  to  serve  as  a  director  due  to  her  position  as  President  and 
Chief Executive Officer of the Company.

Leanne  M.  Bell,  61.  Ms.  Bell  became  a  director  of  the  Company  in  February  2022.  Ms.  Bell  is  a  retired 
financial and power infrastructure expert with a portfolio of board work spanning the infrastructure space in both 
the  United  States  and  Europe.  She  has  overseen  the  investment  of  more  than  $6  billion  in  global  power 
infrastructure  projects  and  companies.  Before  committing  full  time  to  non-executive  board  roles  in  2014,  Ms. 
Bell was Chief Financial Officer of Synergy Renewables LLC, Managing Director of Tiger Infrastructure Partners 
(formerly  Lehman  Brothers  Global  Infrastructure  Partners)  and  Managing  Director  of  GE  Energy  Financial 
Services.  She  currently  sits  on  the  boards  of  Ventient  Energy  Services  Limited,  Nassau  Financial  Group  and 
Third  Coast  Midstream,  LLC.  She  previously  served  on  the  board  of  Onward  Energy  Services  from  2018  to 
2020 and John Laing Group from 2020 to 2021. The Board selected Ms. Bell to serve as a director due to her 
expansive career in the financial and energy industries. Ms. Bell serves on the Audit and Risk Committee.

Robert A. Elliott, 66. 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 has been 
a  board  member  of  UNS  Energy  Corporation,  a  subsidiary  of  Fortis,  since  2014,  serving  as  the  Chair  of  the 
Board until 2021 . Mr. Elliott currently serves on the board of directors of AAA Mountain West Group and has 
served since 2016. He is the Chair of the board of directors of AAA Auto Club Partners. He previously served on 
the  board  of  directors  of  AAA  Arizona  Inc.  from  2007  to  2016.  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. Mr. Elliott serves as Chairperson of the Audit and 
Risk Committee, and the Board has determined that Mr. Elliott is an “audit committee financial expert,” as that 
term is defined under applicable SEC rules.

Debora M. Frodl, 56. 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.  Ms.  Frodl  serves  on  the  Governance  and  Human  Resources 
Committee.

Lt. Gen. Ronnie Hawkins, Jr., USAF, Retired, 66. 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 
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. Mr. Hawkins serves on the Governance and Human Resources Committee.

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David G. Hutchens, 55. 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. The Board selected Mr. Hutchens to serve based on his relevant 
business and leadership experience and because he is a director representative of Fortis. Mr. Hutchens serves 
on the Governance and Human Resources Committee.

James  P.  Laurito,  65.  Mr.  Laurito  became  a  director  of  the  Company  in  October  2016.  Mr.  Laurito  retired 
from Fortis in December 2021. He previously served as Fortis’ Executive Vice President, Business Development 
since April 2016 and as Chief Technology Officer from 2018 until his retirement. 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 served as a board member of Fortis’ Central Hudson Gas 
&  Electric  Corporation  subsidiary  from  2014  to  2021.  He  has  been  Chairman  of  the  Hudson  Valley  Economic 
Development  Corporation  since  January  2015  and  currently  serves  on  the  board  of  Belize  Electricity  Co.  Ltd. 
and  Bowman  Consulting  Group,  also  serving  as  the  Chair  of  the  Compensation  Committee  of  Bowman 
Consulting  Group.  The  Board  selected  Mr.  Laurito  to  serve  due  to  his  expansive  background  in  the  utility 
industry  and  his  regulatory  knowledge.  Mr.  Laurito  serves  on  the  Governance  and  Human  Resources 
Committee. 

Jocelyn H. Perry, 51. Ms. Perry became a director of the Company in January 2022. Ms. Perry has served 
as  Fortis’  Executive  Vice  President  and  Chief  Financial  Officer  since  2018.  Previously,  Ms.  Perry  was  the 
President and Chief Executive Officer of Fortis’ Newfoundland Power subsidiary from 2017 to 2018 and as its 
Chief  Operating  Officer  from  2016  to  2017.  Ms.  Perry  currently  serves  on  the  boards  of  Fortis’  subsidiaries 
FortisBC and UNS Energy Corporation. The Board selected Ms. Perry to serve based on her relevant business 
and leadership experience and because she is a director representative of Fortis. Ms. Perry serves on the Audit 
and Risk Committee. 

Sandra E. Pierce, 63. 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, 66. 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.  Mr.  Prust  serves  on  the  Audit  and  Risk 
Committee and the Board has determined that Mr. Prust is an “audit committee financial expert,” as that term is 
defined under applicable SEC rules.

A.  Douglas  Rothwell,  65.  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 

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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. Mr. Rothwell serves as the Chair of the Governance and Human Resources Committee.

EXECUTIVE OFFICERS

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. 

Linda H. Apsey, 52. Ms. Apsey’s background is described above under “Directors.”

Gretchen L. Holloway, 47. 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,  55.  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,  49.  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, 47. Ms. Tanner has served as our Senior Vice President and Chief Business 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. In addition, she is responsible for federal regulatory and legislative 
affairs  and  marketing  and  communications.  Ms.  Tanner  joined  the  Company  in  November  2014  where  she 

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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.  Prior  to  working  at  Alliant  Energy,  Ms.  Tanner  was  a  state  regulatory 
commissioner on the Iowa Utilities Board from 2007 - 2011. 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 
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,  2021.  We  refer  to  these  individuals  collectively  as  the 
“named executive officers” or “NEOs.”

The Company’s named executive officers for 2021 were:

Name

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

Christine Mason Soneral
Krista Tanner

Executive Summary

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

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 2021:

• Base  salary  increases.  Base  salary  increases  were  provided  to  each  of  our  NEOs  in  2021  to  reward 

individual performance and to remain competitive and aligned with market.

• Annual  cash  incentive  bonuses.  The  NEOs  earned  cash  incentive  bonuses  for  2021  performance  of 
approximately 163% of target. This was based on achieving 100% of the performance targets established 
under  the  annual  corporate  performance  bonus  plan  in  early  2021  and  achievement  of  certain 
performance  factors  which  resulted  in  a  bonus  multiplier  of  1.63.  See  “Compensation  Discussion  and 

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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 
2021. 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:

• 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  equity  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  2021,  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  its  own  analysis  and  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  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 

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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  2020,  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 
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,  and  in  some  cases  exceeds,  the  targeted  competitive  position. 
Current  positioning  reflects  median  base  salaries  and  above  median  target  bonus  and  long-term  equity 
incentive  opportunities.  The  Committee  continues  to  monitor  and  balance  competitive  practices,  talent  needs 
and cost considerations when setting compensation.

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 
to understand the impact and result of any such recommendations. The Committee uses market data 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  2021  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.  In  addition  to  the  market  data, 
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.

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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.

The 2021 base salaries for the NEOs, including any year-over-year change, were:

NEO

2020 Base 
Salary

2021 Base 
Salary

Percent 
Increase

Linda H. Apsey

Gretchen L. Holloway

Jon E. Jipping

Christine Mason Soneral

Krista Tanner

$ 

816,000  $ 

840,500 

397,800 

585,800 

393,900 

339,600 

411,700 

597,500 

399,800 

354,900 

 3.0 %

 3.5 %

 2.0 %

 1.5 %

 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. 

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  designed  to  be  challenging  to  meet,  while 
remaining achievable.

For  2021,  the  ACBP  consisted  of  four  primary  measurement  categories:  Financial,  Safety  &  Compliance, 
System Performance and Capital Project Plan. 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.

Target  levels  for  the  corporate  performance  goals  were  determined  based  on  our  annual  and  long-term 
strategic plans, historical performance, expectations for future growth and desired improvement over time. 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 2021, 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

Financial

20% 
Maximum 
Potential 
Payout

Adjusted Net Income (1)

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

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

Target is consistent 
with the approach used 
in 2020 and based on 
the 2021 Board-
approved budget.

Non-Field O&M and 
G&A expense at or 
under budget of 
$168M.
Target based on the 
2021 Board-approved 
budget.

Adjusted Net Income 
at or above $504M to 
achieve 10%; 
Adjusted Net Income 
at or above $479M to 
achieve 5%.

Potential 
Payout

2021 
Results
 10 % $142M

Actual 
Payout

10%

5% - 10% $518M

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 %

2021 Results
0

Actual 
Payout

5%

 5 %

1

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 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.

Safety & 
Compliance

20% Maximum 
Potential Payout

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 unchanged 
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 
2021 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 %

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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.

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

2021 Results
 15 % ITCTransmis

Actual 
Payout

15%

sion - 12

METC - 15

ITC Midwest 
- 47/36

 15 % All high 

15%

priority Field 
O&M 
initiatives 
completed 
under budget 
at $89M

15 - 30% $876M

30%

Rationale for Target

Target unchanged from prior 
year for ITCTransmission, 
reduced from prior year for 
METC and 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 (23 or fewer, representing 
top decile performance);

ITC Midwest (59 or fewer, 
representing top decile 
performance, no more than 48 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 2021 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 $92M.
Target is based on accrued 
capital investment. 

The maximum payout represents 
the risk-adjusted capital 
investment plan for 2021, with a 
threshold level also established.

Complete $751M of the 2021 
Capital Project Plan to achieve 
30%; Complete $711M to 
achieve 15%.

Total Bonus (as a percent of target bonus level)

____________________________

 60 %

 100 %

60%

100%

(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 with adjustments under $1 million.

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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 
ACPB  payouts  may  be  increased  for  outperformance  by  as  much  as  100%  based  on  multiple  measures,  as 
follows:

Measure
Capital Project Plan
Adjusted Consolidated 
Net Income (1)
Strategic Plan 
Objectives
Inclusion & Diversity 
Plan
Bonus Multiplier

Threshold
$790M

$398M
Create 6 
Objectives

Create Plan

____________________________

Maximum Achievement  Multiplier
$876M

$853M

2.00x

Weight
30%

Result
0.60x

$418M
Achieve 4 
Objectives
Achieve 5 
Goals

$407M
Achieved 1 
Objective
Achieved 5 
Goals

1.50x

1.25x

2.00x

30%

30%

10%

0.45x

0.38x

0.20x
1.63x

(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

Adjusted Consolidated Net Income

$ 

$ 

2021

406 
1 
407 

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% to a maximum of 200% of target. Achievement against performance scales related to each of the above 
metrics  produced  an  executive  bonus  multiplier  of  1.63x.  This  performance  factor  was  applied  to  each 
executive’s ACPB factor of 100% to produce a final payment of approximately 163% 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 2021 were 100% of base salary for each NEO. 

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  2021,  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  ITC  cumulative  consolidated  net  income,  over  the  three-year 
performance  period.  The  PBU  metrics  were  selected  as  Total  Shareholder  Return  aligns  with  the  Fortis 
shareholder experience and cumulative consolidated net income measures our sustained growth (organic and 
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  2021  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 shareholders. Total value 
for the award for each grantee was determined based on a percentage of salary. For the NEOs, when the 2021 
awards were made, the award values were targeted to be:

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Ms. Apsey
Ms. Holloway
Mr. Jipping
Ms. Mason Soneral
Ms. Tanner

NEO

Grant Value 
Percent of 
Salary

 250 %
 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.

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 4 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 

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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. As of December 31, 
2021, each of the NEOs was 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

RONNIE D. HAWKINS, JR.      

DAVID G. HUTCHENS      

JAMES P. LAURITO  

 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  applicable  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)

$ 

843,732  $ 

2,086,868  $ 

1,370,015  $ 

184,341  $ 

100,652  $ 

4,585,608 

819,630 

794,692 

413,284 

399,570 

388,115 

599,799 

589,347 

578,000 

401,377 

396,285 

389,469 

356,265 

339,797 

2,036,614 

2,061,860 

715,560 

695,003 

703,598 

1,038,492 

1,023,422 

1,046,405 

694,865 

688,169 

703,598 

616,837 

593,288 

1,151,376 

1,352,000 

671,071 

561,296 

659,100 

973,925 

826,564 

980,200 

651,674 

555,793 

659,100 

578,487 

479,176 

359,039 

322,636 

101,514 

181,670 

147,032 

211,095 

522,326 

568,493 

94,802 

200,948 

170,742 

94,877 

123,653 

84,625 

55,516 

36,871 

36,936 

36,362 

38,499 

38,199 

38,169 

38,746 

35,950 

36,500 

4,451,284 

4,586,704 

1,938,300 

1,874,475 

1,934,207 

2,861,810 

2,999,858 

3,211,267 

1,881,464 

1,877,145 

1,959,409 

36,113 

1,682,579 

34,620 

1,570,534 

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

Year

(b)

2021

2020

2019

2021

2020

2019

2021

2020

2019

2021

2020

2019

2021

2020

____________________________

(1)  The amounts reported in this column represent the grant date 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.  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 2021 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

$ 

2,782,565 

954,115 

1,384,709 

926,514 

822,480 

(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 2021, 2020 and 
2019. For information regarding the corporate goals for 2021, see “Compensation Discussion and Analysis - 
Key Components of Our NEO Compensation Program - Annual Corporate Performance Bonus." 

(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 

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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 3.44% in 2019, 
2.74% for 2020 and 3.01% for 2021. In 2020, the mortality assumption was changed at year-end 2020 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 2021, 2020 and 2019 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

401(k) Match

Personal Use of 
Company 
Aircraft

Other Benefits

Total

$ 

17,400  $ 

54,461  $ 

28,791 

$ 

100,652 

17,100 

16,800 

15,550 

15,450 

15,100 

17,400 

17,100 

16,800 

15,550 

15,450 

15,100 

14,659 

14,120 

40,440 

19,777 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

27,085 

18,939 

21,321 

21,486 

21,262 

21,099 

21,099 

21,369 

23,196 

20,500 

21,400 

21,454 

20,500 

84,625 

55,516 

36,871 

36,936 

36,362 

38,499 

38,199 

38,169 

38,746 

35,950 

36,500 

36,113 

34,620 

Year

2021

2020

2019

2021

2020

2019

2021

2020

2019

2021

2020

2019

2021

2020

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. 

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Grants of Plan-Based Awards

The following table sets forth information concerning each grant of an award made to a NEO during 2021.

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)

$ 

—  $ 

—  $ 

— 

— 

— 

17,036  $  695,586 

— 

— 

— 

840,000 

  1,680,000 

— 

— 

— 

— 

411,700 

  823,400 

— 

— 

— 

— 

597,500 

  1,195,000 

— 

— 

— 

— 

399,800 

  799,600 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

17,038 

34,075 

68,150 

— 

— 

— 

— 

— 

— 

5,842 

11,684 

23,368 

— 

— 

— 

— 

— 

— 

8,479 

16,957 

33,914 

— 

— 

— 

— 

— 

— 

5,673 

11,346 

22,692 

— 

— 

— 

— 

— 

— 

5,036 

10,072 

20,144 

— 

— 

  1,391,282 

— 

5,841 

  238,502 

— 

— 

  477,058 

— 

8,478 

  346,138 

— 

— 

  692,354 

— 

5,673 

  231,608 

— 

— 

  463,257 

— 

5,035 

  205,597 

— 

— 

  411,240 

— 

Name

(a)

Linda H. Apsey

Gretchen L. 
Holloway

Jon E. Jipping

Christine Mason 
Soneral

Krista Tanner

(b)

1/1/2021

1/1/2021

1/1/2021

1/1/2021

1/1/2021

1/1/2021

1/1/2021

1/1/2021

1/1/2021

1/1/2021

SBU

PBU

ACPB

SBU

PBU

ACPB

SBU

PBU

ACPB

SBU

PBU

ACPB

SBU

PBU

ACPB

354,900 

  709,800 

— 

— 

— 

____________________________

(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,  including  the  bonus 
multiplier, 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 2021 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, 2021. The SBUs and 
PBUs reflected here are recorded at fair value at the date of grant, which was $40.83 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 
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.

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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 2021 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, 2021 (the “PBU Grant Date”) (each a 
“PBU Agreement”) provide generally that the award will vest on January 1, 2024 (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

103% of 
Target

200% of 
TSR Target 
Units
200% of 
CCNI 
Target Units

The performance period for the award is January 1, 2021 through December 31, 2023 (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  2021  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.

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

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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  at  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. See “Compensation Discussion and Analysis - Key Components of 
Our  NEO  Compensation  Program  -  Annual  Corporate  Performance  Bonus"  for  a  reconciliation  of  Adjusted 
Consolidated Net Income to Net Income.

If  the  grantee  ceases  to  be  employed  before  the  PBU  Vesting  Date  due  to  death,  disability  or 
“Retirement” (as defined below), 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 on 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.

Service-Based Unit Award Agreements

The SBU award agreements entered into with each NEO on January 1, 2021 (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, 2024 (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 

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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, the 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 2021 held by the NEOs.

Name

(a)

Linda H. Apsey

Gretchen L. Holloway

Jon E. Jipping

Christine Mason Soneral

Krista Tanner

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)

17,617 (2) $ 

17,688 (4)  

6,012 (2)  

6,065 (4)  

8,853 (2)  

8,802 (4)  

5,953 (2)  

5,890 (4)  

5,132 (2)  

5,228 (4)  

850,365 

853,796 

290,187 

292,749 

427,329 

424,866 

287,342 

284,287 

247,731 

252,360 

70,464 (3) $ 

70,757(5)  

24,046 (3)  

24,262 (5)  

35,409 (3)  

35,211 (5)  

23,810 (3)  

23,560 (5)  

20,527 (3)  

20,915 (5)  

3,401,317 

3,415,454 

1,160,721 

1,171,128 

1,709,180 

1,699,658 

1,149,290 

1,137,249 

990,821 

1,009,551 

____________________________

(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, 2021 ($48.27).

(2) 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.

(3) 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. 

(4) These unvested SBUs were granted in 2021 and generally vest on January 1, 2024. These SBU numbers 

include the original SBU grant plus dividend equivalent units earned.

(5) These unvested PBUs were granted in 2021 and generally vest on January 1, 2024. 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.

The  PBU  grants  made  to  NEOs  were  made  pursuant  to  the  Executive  Omnibus  Plan  and  the  SBU  grants 

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made to NEOs 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.

Stock Vested

The  following  table  provides  information  with  respect  to  SBUs  and  PBUs  held  by  the  NEOs  that  vested 

during 2021:

Linda H. Apsey

Gretchen L. Holloway

Jon E. Jipping

Christine Mason Soneral

Krista Tanner

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)

22,252 (2) $ 

83,223 (3)  

7,593 (2)  

28,399 (3)  

11,293 (2)  

42,236 (3)  

7,593 (2)  

28,399 (3)  

4,520 (2)  

16,904 (3)  

994,825 

3,720,645 

339,478 

1,269,649 

504,896 

1,888,217 

339,478 

1,269,649 

202,068 

755,729 

____________________________

(1) Value  is  based  on  the  5-day  volume  weighted  average  price  of  common  stock  on  the  Toronto  Stock 
Exchange on the vesting date, converted from Canadian Dollars to US Dollars using the “Award Conversion 
Rate” defined in the 2017 Omnibus Plan, which is $44.7608.

(2) Amounts  reported  reflect  the  vesting  of  SBUs  granted  March  6,  2019  and  associated  dividend  equivalent 

units.

(3) Amounts  reported  reflect  the  vesting  of  PBUs  granted  March  6,  2019  and  associated  dividend  equivalent 
units. The award contains performance conditions established by the Committee. The performance period 
ended  on  December  31,  2021.  The  Committee  certified  the  achievement  of  187%  of  the  applicable 
performance goals on February 1, 2022. 

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.

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Pension Benefits Table

Name

(a)

Linda H. Apsey

Gretchen Holloway

Jon E. Jipping

Christine Mason Soneral

Krista Tanner

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

Number of Years 
Credited Service 
(#)(1)

Present Value of 
Accumulated 
Benefit ($)(2)

Payments During 
Last Fiscal Year 
($)

(c)

(d)

(e)

27.58  $ 

N/A  

18.83 

17.95 

6.91 

31.03 

16.92 

14.29 

14.28 

7.14 

7.14 

484,463 

39,019 

523,482 

2,299,303 

342,794 

342,794 

504,904 

2,155,602 

2,155,602 

1,824,457 

336,173 

336,173 
903,985 

156,244 

156,244 

356,793 

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,  2021  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.

(2)  The  “Present  Value  of Accumulated  Benefit”  is  the  estimated  lump-sum  equivalent  value  measured  as  of 
December  31,  2021  (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,  2021.  The  rate  at  which  future 
expected benefit payments were discounted in calculating present values was 3.01%, the same rate used 
for  fiscal  year-end  2021  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 1.94% for 2022 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.

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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 
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  $290,000  in  2021  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 2021).

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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: 

Age 55:  

Age 50:  

100%

85%

             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:  

Age 50:  

             71%

             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: 

Age 60:               

100%

58%

Age 55:  

Age 50:  

             36%

             23%

Mr. Jipping’s annual accrued benefit payable in monthly installments as an annuity for his lifetime, beginning 

at age 60, is approximately $130,000. 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  applied  under  the 
traditional component of the Qualified Plan ($290,000 in 2021). 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.

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 2021 is approximately $467,000, Ms. Holloway’s is approximately $315,000, Ms. Mason Soneral’s is 
approximately $315,000, Ms. Tanner is approximately $145,000. 

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 ACPB. 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 

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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 2021, although previous shifts have continued to earn interest credits. As of year-
end 2021, her ESRP shift balance was approximately $38,000.

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 ACPB. 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,  2021,  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

$ 

2,214,807 

464,356 

1,823,110 

846,109 

329,977 

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. 

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 2020 and 
his deferral was withheld in 2021. Mr. Jipping also elected to participate in 2021, and his deferral will be made in 
2022  due  to  his  2021  bonus  payment  occurring  in  2022.  Mr.  Jipping  is  the  only  NEO  that  participated  in  the 
Executive  Deferred  Compensation  Plan  in  2021.  The  following  table  reports  amounts  contributed  in  2021, 
together  with  aggregate  earnings  on  contributions  and  withdrawals  or  distributions  on  contributions  in  2021, 
under the plan.

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Name (in millions of USD)

Jon E. Jipping

____________________________

Executive 
Contributions 
in Last Fiscal 
Year (1)

Registrant 
Contributions 
in Last Fiscal 
Year

Aggregate 
Earnings in 
Last Fiscal 
Year

Aggregate 
Withdrawals/
Distributions

Aggregate 
Balance at Last 
Fiscal Year End 
(2)

$ 

800,226  $ 

—  $ 

412,880  $ 

—  $  3,214,206 

(1)  The  amounts  reported  in  this  column  for  each  NEO  are  reflected  as  compensation  to  such  NEO  in  the 

Summary Compensation Table.

(2)  Includes  the  total  market  value  of  deferred  compensation  program  balance  at  December  31,  2021.  The 
aggregate balance reflects a significant level of earnings on previously earned and deferred compensation.

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, 2021.

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  to  substantially  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 

109

Table of Contents

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.

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 ACPB 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  Mr.Jipping  met  the  age  and  service  eligibility  requirements  for 
participation in our Postretirement Welfare Plan. 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, 2021.

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Table of Contents

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:

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)

$ 

—  $ 

—  $ 

1,681,000  $ 

4,129,329  $ 

—  $ 

— 

— 

— 

840,500 

840,500 

1,370,015 

1,370,015 

— 

— 

— 

— 

1,704,161 

1,704,161 

1,704,161 

1,701,974 

3,408,386 

3,408,386 

25,000 

25,000 

31,592 

31,592 

775,824 

775,824 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

$ 

—  $ 

—  $ 

3,883,431  $ 

9,737,895  $ 

5,953,047  $ 

5,953,047 

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)

$ 

—  $ 

—  $ 

823,400  $ 

2,018,961  $ 

—  $ 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

411,700 

411,700 

671,071 

671,071 

— 

— 

582,936 

582,936 

582,936 

581,738 

1,165,924 

1,165,924 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

25,000 

25,000 

10,596 

10,596 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

$ 

—  $ 

—  $ 

1,530,067  $ 

3,890,302  $ 

2,160,560  $ 

2,160,560 

111

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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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:

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)

$ 

—  $ 

—  $ 

1,195,000  $ 

2,972,455  $ 

—  $ 

— 

— 

— 

852,195 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

597,500 

597,500 

973,925 

973,925 

— 

— 

852,195 

852,195 

852,195 

852,195 

852,485 

1,704,419 

1,704,419 

— 

— 

— 

— 

— 

25,000 

25,000 

22,128 

22,128 

776,225 

776,225 

— 

— 

— 

— 

— 

— 

— 

— 

$ 

852,195  $ 

—  $ 

3,844,473  $ 

6,474,413  $ 

3,154,114  $ 

3,154,114 

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)

$ 

—  $ 

—  $ 

799,600  $ 

1,999,751  $ 

—  $ 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

399,800 

399,800 

651,674 

651,674 

— 

— 

571,629 

286,324 

286,324 

572,292 

191,548 

191,548 

— 

— 

25,000 

25,000 

22,115 

22,115 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

$ 

—  $ 

—  $ 

1,498,389  $ 

3,842,461  $ 

877,672  $ 

877,672 

112

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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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:

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)

$ 

—  $ 

—  $ 

709,800  $ 

1,411,238  $ 

—  $ 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

354,900 

354,900 

578,487 

578,487 

— 

— 

500,091 

249,274 

249,274 

— 

— 

— 

— 

— 

498,224 

(442,488) 

— 

— 

25,000 

25,000 

19,730 

19,730 

165,137 

165,137 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

$ 

—  $ 

—  $ 

1,333,017  $ 

2,590,282  $ 

769,311  $ 

769,311 

____________________________

(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.  Tanner  would  be  subject  to  an  excise  tax  on  the  employer 
payments  as  of  the  assumed  change  in  control  date;  therefore,  cutbacks  in  the  amount  of  $442,488  (Ms. 
Tanner) have been reflected.

(4) In the event of Mr. Jipping’s termination for death (pre-retirement), his spouse or designated beneficiary if 
not  married  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  or 
designated  beneficiary  it  not  married  and  ESRP  benefits  are  payable  to  a  designated  beneficiary.  The 
above  termination  scenarios  do  not  reflect  the  reduction  in  present  value  of  death  benefits  ($103,732  for 
Ms.  Apsey,  $68,077  for  Ms.  Holloway,  $1,066,469  for  Mr.  Jipping,  $79,399  for  Ms.  Mason  Soneral  and 
$38,559 for Ms. Tanner compared to present value in the Pension Benefits Table).

(5) 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 

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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  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  3.14%,  the  same  rate  used  for  fiscal  year-end  2021  accounting  disclosure  of  the  Postretirement 
Welfare Plan.

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.

Pay Ratio

As required by 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 2021, our last completed fiscal year:

the  median  of  the  annual  total  compensation  of  all  employees  of  the  Company  (other  than  Ms. 
Apsey), was $159,801; and

the annual total compensation of Ms. Apsey as reported in the Summary Compensation Table was 
$4,585,608.

Based  on  this  information,  Ms. Apsey’s  2021  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 

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been  three  years  since  we  had  last  identified  the  “median  employee”  for  this  analysis.  The  same  median 
employee was used to calculate the 2021 pay ratio.

Using our “median employee” and Ms. Apsey, we calculated the applicable Summary Compensation Table 

values for each according to applicable 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 2021.

Non-Employee Director Compensation Table

Leanne M. Bell (2)

Robert A. Elliott (3)

Albert Ernst (4)

Debora Frodl

Alexander I. Greenbaum (5)

Ronnie Hawkins, Jr.

David G. Hutchens

James P. Laurito 

Jocelyn H. Perry (2)

Sandra E. Pierce 

Kevin L. Prust

A. Douglas Rothwell 

Thomas G. Stephens (4)

Name

(a)

Fees Earned or 
Paid in Cash ($) (1)

(b)

$ 

—  $ 

149,518 

140,000 

140,000 

— 

140,000 

140,000 

140,000 

— 

190,000 

145,482 

155,000 

14,014 

Total ($)

(h)

— 

149,518 

140,000 

140,000 

— 

140,000 

140,000 

140,000 

— 

190,000 

145,482 

155,000 

14,014 

____________________________

(1) Includes annual Board retainer and committee chairmanship retainer, as well as a chairperson fee (for Ms. 

Pierce only).

(2) Ms. Perry joined the Board in January 2022 and Ms. Bell joined the Board in February 2022.

(3) Mr. Elliott was appointed to Chairperson of the Audit and Risk Committee in May 2021.

(4) Mr. Stephens left the Board in February 2021 and Mr. Ernst left the Board in February 2022.

(5) Mr. Greenbaum waived all compensation due to him for his service on the Board. Mr. Greenbaum left the 

Board in September 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. Mr. Laurito and Mr. Stephens participated in this plan in 2021.

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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, 2022, except as otherwise indicated, by:

•

•

•

each of our current directors;

each of the persons named in the “Summary Compensation Table” under Item 11; and

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,  2022  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
Leanne M. Bell
Robert A. Elliott
Albert Ernst
Debora Frodl
Alexander I. Greenbaum
Ronnie Hawkins
David G. Hutchens
James P. Laurito
Jocelyn H. Perry
Sandra E. Pierce
Kevin L. Prust
A. Douglas Rothwell
All current directors and executive officers as a group 
(17 persons)

Number of 
Fortis shares 
Beneficially 
Owned (#)

Percent 
of Class 
(%)

Number of 
Company 
Shares
Beneficially 
Owned (#)

—   
—   
—   
—   
—   
—   
—  
—   
—   
—   
—   
—   
—   

—   
—   
—   

Percent of 
Class (%)
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 

— 
— 
— 

(1)

53,889 
8,862 
60,000 
— 
— 
— 
—
10,274
— 
— 
— 
83,907 
48,544 
187,622 
— 
500 
— 

*
*
*
— 
— 
— 
—
*
— 
— 
— 
*
*
*
— 
*
— 

*

— 

 — %  

443,324 

* 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, 2021, there were no securities authorized for issuance under any compensation plans of 

ITC Holdings.

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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.

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.

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. Bell, 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 required in its charter. 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  2021  and 

2020:

Audit fees (1)
Audit-related fees (2)
Tax fees (3)
All other fees (4)

Total fees

____________________________

$ 

2021
2,083,000  $ 
57,000   
13,000   
7,000   

$ 

2,160,000  $ 

2020
1,995,000 
56,000 
16,000 
4,000 
2,071,000 

(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  2021  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, 2021 and 2020

Consolidated Statements of Comprehensive Income for the Years Ended December 31, 2021, 2020 and 2019
Consolidated Statements of Changes in Stockholder's Equity for the Years Ended December 31, 2021, 2020 
and 2019
Consolidated Statements of Cash Flows for the Years Ended December 31, 2021, 2020 and 2019

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)

Tenth  Amended  and  Restated  Bylaws  of  ITC  Holdings  Corp.  (filed  with  Registrant’s  Form  8-K  on 
February 4, 2022)

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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4.12 

4.14 

4.17 

4.18 

4.19 

4.20 

4.24 

4.25 

4.26 

4.27 

4.28 

4.29 

4.30 

4.31 

4.32 

4.33 

4.34 

4.35 

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)

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)

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)

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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 

4.54 

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).

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).

121

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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4.55 

4.56 

*10.27

10.51 

Eleventh Supplemental Indenture, dated as of July 19, 2021, 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 August 3, 2021)

Ninth  Supplemental  Indenture,  dated  as  of  November  5,  2021,  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 2.93% First Mortgage Bonds, Series I, due 2052 and Form of 
2.93%  First  Mortgage  Bonds,  Series  J,  due  2052)  (filed  with  Registrant’s  Form  8-K  on  January  14, 
2022)

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  Form  10-K  for  the  year  ended 
December 31, 2008)

*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 (filed with Registrant’s Form 10-K for the year ended December 31, 2020)

Letter  Agreement,  dated  as  of  October  12,  2016  between  ITC  Holdings  Corp.  and  Christine  Mason 
Soneral (filed with Registrant’s Form 10-K for the year ended December 31, 2016)

*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)

122

 
 
 
 
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10.185 

10.186 

10.187 

10.188 

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 Form 10-K for the year ended December 31, 2018)

*10.191

ITC  Holdings  Corp.  Director  Deferred  Compensation  Plan,  effective  January  1,  2019  (filed  with 
Registrant’s Form 10-K for the year ended December 31, 2018)

*10.192

10.194 

10.195 

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)

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 Registrant’s Form 
8-K on January 10, 2020)

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 Registrant’s Form 8-K on January 10, 2020)

123

 
 
 
 
 
 
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10.196 

10.197 

10.198 

*10.200

*10.201

*10.202

*10.203

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 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 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  Registrant’s  Form  8-K  on 
January 10, 2020)

2017 Omnibus Plan, as amended July 10, 2017 and February 4, 2020 (filed with Registrant’s Form 10-
K for the year ended December 31, 2019)

Executive  Omnibus  Plan,  effective  February  4,  2020.  (filed  with  Registrant’s  Form  10-K  for  the  year 
ended December 31, 2019)

Form  of  Performance-Based  Unit  Award  Agreement  under  Executive  Omnibus  Plan  (January  2020). 
(filed with Registrant’s Form 10-K for the year ended December 31, 2019)

Employment Agreement between ITC Holdings Corp. and Krista K. Tanner, effective as of February 18, 
2019 (filed with Registrant’s Form 10-K for the year ended December 31, 2021)

*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)

*10.206

10.207 

10.208 

Separation  and  Release Agreement,  effective  as  of  May  18,  2020,  between  ITC  Holdings  Corp.  and 
Daniel J. Oginsky (filed with Registrant’s Form 10-K for the year ended December 31, 2020)

Amendment No. 1 to Credit Agreement, dated as of May 17, 2021, among ITC Holdings Corp., with the 
banks,  financial  institutions  and  other  institutional  lenders  listed  on  the  respective  signature  pages 
thereof, and Wells Fargo Bank, National Association, in its capacity as administrative agent (filed with 
Registrant’s Form 8-K on May 17, 2021)

Amendment No. 1 to Credit Agreement, dated as of May 17, 2021, among International Transmission 
Company,  with  the  banks,  financial  institutions  and  other  institutional  lenders  listed  on  the  respective 
signature pages thereof, and Wells Fargo Bank, National Association, in its capacity as administrative 
agent (filed with Registrant’s Form 8-K on May 17, 2021)

124

 
 
 
 
 
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10.209 

10.210 

10.211 

Amendment  No.  1  to  Credit  Agreement,  dated  as  of  May  17,  2021,  among  Michigan  Electric 
Transmission Company, LLC, with the banks, financial institutions and other institutional lenders listed 
on the respective signature pages thereof, and Wells Fargo Bank, National Association, in its capacity 
as administrative agent (filed with Registrant’s Form 8-K on May 17, 2021)

Amendment No. 1 to Credit Agreement, dated as of May 17, 2021, among ITC Midwest LLC, with the 
banks,  financial  institutions  and  other  institutional  lenders  listed  on  the  respective  signature  pages 
thereof, and Wells Fargo Bank, National Association, in its capacity as administrative agent (filed with 
Registrant’s Form 8-K on May 17, 2021)

Amendment No. 1 to Credit Agreement, dated as of May 17, 2021, among ITC Great Plains, LLC, with 
the banks, financial institutions and other institutional lenders listed on the respective signature pages 
thereof, and Wells Fargo Bank, National Association, in its capacity as administrative agent (filed with 
Registrant’s Form 8-K on May 17, 2021)

***10.212

Executive Omnibus Plan, as amended November 11, 2021

***10.213

Fortis Inc. 2020 Restricted Share Unit Plan, as amended January 1, 2022

***10.214

Employment Agreement  between  ITC  Holdings  Corp.  and  Brian  Slocum,  effective  as  of  February  14, 
2022

**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 of Chief Executive Officer and Chief Financial Officer 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, 
2021 (formatted in Inline XBRL and contained in Exhibit 101)

___________________________

*
**

***

Management contract or compensatory plan or arrangement
Filed herewith

Management contract or compensatory plan or arrangement filed herewith

125

 
 
 
Table of Contents

SCHEDULE I — Condensed Financial Information of Registrant

ITC HOLDINGS CORP.

CONDENSED STATEMENTS OF FINANCIAL POSITION (PARENT COMPANY ONLY)

December 31,

2021

2020

(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

Advances to subsidiaries

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 $17 and $21, 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, 2021 and 2020

Retained earnings

Accumulated other comprehensive loss

Total stockholder’s equity

$ 

3  $ 

$ 

$ 

20 

16 

3 

50 

92 

5,784 

142 

4 

112 

6,042 

6,134  $ 

72  $ 

23 

654 

8 

757 

52 

78 

2,773 

3,660 

892 

1,584 

(2) 

2,474 

TOTAL LIABILITIES AND STOCKHOLDER’S EQUITY

$ 

6,134  $ 

See notes to condensed financial statements (parent company only).

126

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 

5,830 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 INCOME (LOSS)

Year Ended December 31,

2021

2020

2019

$ 

3  $ 

5  $ 

(30) 

(2) 

(129) 

(158) 

(46) 

(112) 

518 

406 

6 

6 

(20) 

(1) 

(122) 

(138) 

(43) 

(95) 

502 

407 

(15) 

(15) 

5 

(25) 

(2) 

(119) 

(141) 

(44) 

(97) 

525 

428 

3 

3 

Derivative instruments (net of tax of $2 for the year ended December 31, 2021, $7 

for the year ended December 31, 2020, $1 for the year ended December 31, 2019  

TOTAL OTHER COMPREHENSIVE INCOME (LOSS), NET OF TAX

TOTAL COMPREHENSIVE INCOME

$ 

412  $ 

392  $ 

431 

See notes to condensed financial statements (parent company only).

127

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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
Share-based compensation
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,

2021

2020

2019

$ 

406  $ 

407  $ 

428 

(518) 
10 
(41) 
56 
25 
4 

(2) 
(9) 
— 
4 
(2) 
(67) 

(51) 
259 
— 
1 
209 

— 
93 
— 
88 
— 
(91) 
— 
(232) 
— 
1 
(141) 

1 

(502) 
3 
(46) 
33 
15 
2 

9 
(4) 
— 
(12) 
(3) 
(98) 

(88) 
228 
(50) 
(2) 
88 

700 
293 
200 
(133) 
— 
(290) 
(400) 
(330) 
(23) 
(7) 
10 

— 

(525) 
3 
(51) 
14 
18 
6 

9 
11 
1 
22 
— 
(64) 

(120) 
239 
— 
(1) 
118 

— 
72 
200 
200 
(203) 
(75) 
— 
(250) 
— 
— 
(56) 

(2) 

4 
2 

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 
3  $ 

2 
2  $ 

See notes to condensed financial statements (parent company only).

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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.  Certain  prior  period  amounts  in  the  financial 
statements  and  notes  have  been  reclassified  to  conform  to  the  current  period  presentation  for  comparative 
purposes.

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,  2021  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 
outbreak of COVID-19 have resulted in challenges to businesses and facilities in various industries around the 
world, including our customers, and disruptions to the global economy and supply chains. To date, COVID-19 
has not had a material impact on our net income. However, for 2020, we utilized 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  for  our  customers  that  were  collected  through  our 
Formula Rates.

We are unable to predict the ultimate effects of COVID-19 on the U.S. or global economy or our operations. 
We continue to monitor developments affecting our workforce, customers, suppliers, and operations. The extent 
of the impact of COVID-19 will depend on its duration, actions by government authorities, and impacts on our 
customers,  employees,  or  vendors.  These  developments  are  continuously  evolving,  and  we  cannot  predict 
whether COVID-19 will have a material impact on our financial condition, results of operations or cash flows.

2.   DEBT

As of December 31, 2021, the maturities of our debt outstanding were as follows:

(In millions of USD)
2022
2023
2024
2025
2026
2027 and thereafter

Total

$ 

$ 

655 
250 
439 
— 
400 
1,700 
3,444 

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Refer to Note 9 to the consolidated financial statements for additional information on the ITC Holdings Senior 
Notes, the ITC Holdings Revolving Credit Agreements, the ITC Holdings Commercial Paper Program and the 
ITC Holdings Derivative Instruments and Hedging Activities.

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 $3,516 million and $3,670 million at December 31, 2021 and 2020, respectively. The total book value of the 
ITC Holdings Senior Notes, net of discount and deferred financing fees, was $3,233 million and $3,229 million 
at December 31, 2021 and 2020, respectively. The fair values of the ITC Holdings Senior Notes represent Level 
2 under the three-tier hierarchy described in Note 12 to the consolidated financial statements. 

Revolving Credit Agreements

At  December  31,  2021  and  2020,  we  had  $39  million  and  $37  million,  respectively,  outstanding  under  our 
revolving  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 credit agreements represent Level 2 under the three-tier hierarchy 
described in Note 12 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

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.

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.

Equity Transactions

(In millions of USD)

Equity contributions to subsidiaries

Dividends from subsidiaries (a)

Return of capital from subsidiaries (a)

____________________________

Year Ended December 31,

2021

2020

2019

$ 

(51)  $ 

(88)  $ 

10 

259 

3 

228 

(120) 

3 

239 

(a) Includes ITCTransmission, MTH, ITC Midwest and other subsidiaries.

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.

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(In millions of USD)

Net income tax payments (to) from: (a)

ITCTransmission

METC

ITC Midwest

ITC Great Plains

ITC Interconnection

____________________________

Year Ended December 31,

2021

2020

2019

$ 

24  $ 

17  $ 

15 

10 

6 

1 

9 

1 

6 

— 

7 

4 

3 

(1) 

1 

(a) 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.

Intercompany Loan Agreement

On  September  21,  2020,  we  advanced  an  intercompany  loan  to  ITCTransmission  totaling  $50  million,  due 
September  21,  2022,  which  remained  outstanding  at  December  31,  2021.  On  January  14,  2022, 
ITCTransmission repaid the intercompany loan in full with proceeds from the issuance of First Mortgage Bonds 
on January 14, 2022. We received interest payments of $1 million during the year ended December 31, 2021 
from  ITCTransmission  associated  with  this  intercompany  loan. Additionally,  at  December  31,  2021  we  had  a 
$4 million intercompany loan with ITC Interconnection, due June 1, 2046. During the year ended December 31, 
2021, we received principal and interest payments of $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:

December 31,

2021

2020

2019

2018

3  $ 

2  $ 

2  $ 

— 
3  $ 

— 
2  $ 

— 
2  $ 

$ 

$ 

3 

1 
4 

Year Ended December 31,

2021

2020

2019

$ 

119  $ 
— 
— 

116  $ 
2 
2 

117 
— 
3 

(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.

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Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, as amended, 
the  registrant  has  duly  caused  this  report  to  be  signed  on  its  behalf  by  the  undersigned,  thereunto  duly 
authorized on February 10, 2022.

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,  as  amended,  this  report  has  been 
signed  below  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 10, 2022

/s/ GRETCHEN L. HOLLOWAY
Gretchen L. Holloway

Senior Vice President and Chief Financial Officer
 (principal financial and accounting officer)

February 10, 2022

/s/ SANDRA E. PIERCE
Sandra E. Pierce

/s/ ROBERT A. ELLIOTT
Robert A. Elliott

/s/ LEANNE M. BELL
Leanne M. Bell

/s/ DEBORA FRODL
Debora Frodl

/s/ RONNIE D. HAWKINS, JR
Ronnie D. Hawkins, Jr

/s/ DAVID G. HUTCHENS
David G. Hutchens

/s/ JAMES P. LAURITO
James P. Laurito

/s/ JOCELYN H. PERRY
Jocelyn H. Perry

/s/ KEVIN L. PRUST
Kevin L. Prust

/s/ A. DOUGLAS ROTHWELL
A. Douglas Rothwell

Director and Chairman

February 10, 2022

February 10, 2022

February 10, 2022

February 10, 2022

February 10, 2022

February 10, 2022

February 10, 2022

February 10, 2022

February 10, 2022

February 10, 2022

Director

Director

Director

Director

Director

Director

Director

Director

Director

132