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106
Item 9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosure
No events that would be described in response to this item have occurred with respect to NU, CL&P, NSTAR Electric, PSNH or WMECO.
Item 9A. Controls and Procedures
Management, on behalf of NU, CL&P, NSTAR Electric, PSNH and WMECO, is responsible for the preparation, integrity, and fair presentation of
the accompanying Consolidated Financial Statements and other sections of this combined Annual Report on Form 10-K. NU's internal controls over
financial reporting were audited by Deloitte & Touche LLP.
Management, on behalf of NU, CL&P, NSTAR Electric, PSNH and WMECO, is responsible for establishing and maintaining adequate internal
controls over financial reporting. The internal control framework and processes have been designed to provide reasonable assurance regarding the
reliability of financial reporting and the preparation of financial statements for external purposes in accordance with GAAP. There are inherent
limitations of internal controls over financial reporting that could allow material misstatements due to error or fraud to occur and not be prevented or
detected on a timely basis by employees during the normal course of business. Additionally, internal controls over financial reporting may become
inadequate in the future due to changes in the business environment. Under the supervision and with the participation of the principal executive
officer and principal financial officer, an evaluation of the effectiveness of internal controls over financial reporting was conducted based on criteria
established in -(2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission
(COSO). Based on this evaluation under the framework in COSO, management concluded that internal controls over financial reporting at NU,
CL&P, NSTAR Electric, PSNH and WMECO were effective as of December 31, 2014.
Management, on behalf of NU, CL&P, NSTAR Electric, PSNH and WMECO, evaluated the design and operation of the disclosure controls and
procedures as of December 31, 2014to determine whether they are effective in ensuring that the disclosure of required information is made timely
and in accordance with the Securities Exchange Act of 1934 and the rules and regulations of the SEC. This evaluation was made under
management's supervision and with management's participation, including the principal executive officer and principal financial officer as of the end
of the period covered by this Annual Report on Form 10-K. There are inherent limitations of disclosure controls and procedures, including the
possibility of human error and the circumventing or overriding of the controls and procedures. Accordingly, even effective disclosure controls and
procedures can only provide reasonable assurance of achieving their control objectives. The principal executive officer and principal financial officer
have concluded, based on their review, that the disclosure controls and procedures of NU, CL&P, NSTAR Electric, PSNH and WMECO are effective
to ensure that information required to be disclosed by us in reports filed under the Securities Exchange Act of 1934 (i) is recorded, processed,
summarized, and reported within the time periods specified in SEC rules and regulations and (ii) is accumulated and communicated to management,
including the principal executive officer and principal financial officer, as appropriate to allow timely decisions regarding required disclosures.
During the third quarter of 2014, we implemented a new general ledger system resulting in a material change in internal controls over financial
reporting. This new system, which went live effective August 1, 2014, standardized the financial systems for the merged companies and allows for a
common set of accounting processes, practices and data structures across all operating companies. Pre-implementation testing and post-
implementation reviews were conducted by management to ensure that internal controls surrounding the system implementation process, the
applications, and the closing process were properly designed to prevent material financial statement errors. Such procedures included the review of
required documents, user acceptance testing, change management procedures, access controls, data migration strategies and reconciliations,
application interface testing and other standard application controls.
There have been no other changes in internal controls over financial reporting for NU, CL&P, NSTAR Electric, PSNH and WMECO during the
quarter ended December 31, 2014 that have materially affected, or are reasonably likely to materially affect, internal controls over financial reporting.
Item 9B. Other Information
No information is required to be disclosed under this item as of December 31, 2014, as this information has been previously disclosed in applicable
reports on Form 8-K during the fourth quarter of 2014.