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United States securities and exchange commission logo
May 15, 2024
Robert Hoglund
Chief Financial Officer
Consolidated Edison, Inc.
4 Irving Place
New York, New York, 10003
Re: Consolidated
Edison, Inc.
Form 10-K for the
Fiscal Year ended December 31, 2023
Filed February 15,
2024
File No. 001-14514
Dear Robert Hoglund:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year ended December 31, 2023
Introduction , page 7
1. We note that columns
utilized to present annual information in your reconciliations
for non-GAAP measures
on page 10 and within the various tables on pages 18 through 28
sequence from the
earliest to most recent periods, reading left to right, which is not
consistent with the
sequence utilized in presenting tabular information throughout your
financial statements
and in recent earnings releases.
Please modify your
tabulations of numerical data either within the financial statements or
outside of the
financial statements as necessary to utilize a consistent chronological
ordering of data to
adhere to the guidance in SAB Topic 11:E.
Robert Hoglund
Consolidated Edison, Inc.
May 15, 2024
Page 2
Financial Statements
Note B Regulatory Matters
Other Regulatory Matters, page 128
2. We note your disclosure regarding the inadvertent understatement of
federal income tax
expense for ratemaking purposes, indicating the Utilities accumulated
significant income
tax regulatory assets that were not reflected in rate plans for
various periods and therefore
reduced the amount of revenue collected from customers.
You disclose that the regulatory asset was $1,113 million and $18
million for CECONY
and O&R, respectively, as of December 31, 2023, and that the Utilities
have not accrued
any liability related to this matter.
Please expand your disclosures as necessary to address the following
points.
Indicate the extent to which the understatement for ratemaking
purposes correlates
with an understatement in your calculation of federal income
taxes due;
Provide management's view on the likelihood of recovering the
understatement
of federal income tax expense through higher future rates;
Explain how the understatement is reflected in the regulatory
assets for CECONY
and O&R, referenced from your disclosure above;
Describe the circumstances that would cause you to record a
liability or impair any
portion of the regulatory assets associated with the
understatement;
Clarify whether the understatement for ratemaking purposes is
encompassed within
any of the uncertain tax positions disclosed on page 152.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Please contact John Cannarella at 202-551-3337 or Jenifer Gallagher at
202-551-3706
with any questions.
FirstName LastNameRobert Hoglund Sincerely,
Comapany NameConsolidated Edison, Inc.
Division of
Corporation Finance
May 15, 2024 Page 2 Office of
Energy & Transportation
FirstName LastName