note 7 – REgulatory Matters

Unitil’s Regulatory matters are described in Note 8 to the Financial Statements in Item 8 of Part II of Unitil Corporation’s Form 10-K for December 31, 2025 as filed with the Securities and Exchange Commission on February 9, 2026.

Rate Case Activity

Northern Utilities - Base Rates - Maine - On June 1, 2026, Northern Utilities’ Maine Division filed for an increase in distribution base rates with the MPUC. The Company is seeking an increase in base rates of approximately $10.4 million, or 7.4% above total annual revenue at present rates. The Company requested an effective date of June 1, 2027. This matter remains pending

Northern Utilities - Base Rates - New Hampshire - On April 1, 2026, Northern Utilities’ New Hampshire Division filed for an increase in distribution base rates with the NHPUC. The Company is seeking an increase in base rates of approximately $9.8 million or 9.6% above total annual revenue at present rates. The filing includes a proposed multi-year rate plan, continuation of a revenue decoupling mechanism, and other tariff and rate changes. Northern Utilities also requested implementation of temporary rates for service rendered on and after June 1, 2026, and until a final order on permanent rates is issued. As provided by statute, once a final

order on permanent rates is issued, the permanent rate level is reconciled back to the effective date of the temporary rates. The Company requested a temporary rate increase in annual revenues of $6.1 million, or a 5.9% increase above total annual revenue at present rates. On May 1, 2026, a settlement agreement between the Company, the New Hampshire Department of Energy (NH DOE) and the Office of the Consumer Advocate reflecting a temporary rate level of $5.5 million, or 5.4% increase above total annual revenue at present rates was filed with the NHPUC. On May 29, 2026 the NHPUC approved the settlement agreement.

Unitil Energy - Base Rates - On April 27, 2026, the NHPUC issued a procedural Order and issued its full Order on May 28, 2026 in the distribution base rate case filed with the NHPUC on May 1, 2025 by Unitil Energy. The Orders approve the settlement agreement filed on February 24, 2026 between the Company, the NH DOE and the Community Power Coalition of New Hampshire in its entirety.

In addition to authorizing an increase to permanent distribution rates of approximately $13.0 million effective May 1, 2026, the settlement agreement included: (1) a proposed multi-year rate plan, including two annual Step Adjustments to rates on September 1, 2026 and September 1, 2027, to recover total prudent investments completed and placed into service in 2025 and 2026 respectively, subject to a cap 2.50 percent of the Company’s prior year total revenue; (2) a continuation of its revenue decoupling mechanism; (3) an update to the previously approved suite of proposed time of use rates including rates for electric vehicles; (4) resiliency programs to further the Company’s commitment to reliability; (5) an Arrearage Management Program for financial hardship customers; and (6) other rate design and tariff changes. This distribution base rate case reflects the Company’s operating costs and investments in utility plant for a test year ended December 31, 2024 as adjusted for known and measurable changes. The Order provides for an overall cost of capital of 9.32% including a 9.45% return on equity. The increase in permanent rates will be reconciled back to July 1, 2025, the effective date of temporary rates previously approved in this docket, which will begin to be recovered effective August 1, 2026. Unitil Energy recorded a net increase to pretax income of $1.7 million in the second quarter of 2026 reflecting the difference between the temporary and permanent rates.

On February 27, 2026, Unitil Energy filed a petition for its step adjustment effective September 1, 2026 requesting a revenue requirement increase of $3.2 million. This matter remains pending.

Fitchburg - Base Rates - Electric - Fitchburg’s base rates are decoupled and subject to an annual revenue decoupling adjustment mechanism, which includes a cap on the amount that rates may be increased in any year.

On August 17, 2023, Fitchburg filed a petition with the MDPU seeking approval for a $6.8 million increase to base distribution rates, with new rates to be effective July 1, 2024. On June 28, 2024, the MDPU issued an Order providing for a $4.7 million increase to base rates, effective July 1, 2024, approving a performance-based ratemaking (PBR) plan for up to a five-year term and continuing the Company’s revenue decoupling mechanism. The Order also provided for a return on equity of 9.4% and a capital structure reflecting 52% equity and 48% long-term debt. Additionally, the MDPU found that allowing the Company to recover pension and PBOP expense through its Pension/PBOP Adjustment mechanism is no longer warranted and that these expenses should be recovered in base distribution rates. On July 18, 2024, the Company filed a Motion for Reconsideration and Recalculation requesting that the MDPU reconsider its decision to require the Company to absorb $1.4 million in negative excess accumulated deferred income taxes (ADIT) because the effect of the Order was to inappropriately claw back amounts that were previously approved by the MDPU for recovery from customers. The amount of $1.4 million is disaggregated between the Company’s gas division ($0.6 million) and the electric division ($0.8 million). The MDPU denied the motion, and on December 9, 2024, the Company filed an appeal with Massachusetts Supreme Judicial Court. This appeal is pending.

Fitchburg - Performance Base Rate Adjustment - Electric - On February 27, 2026, Fitchburg filed its second Performance Based Revenue Adjustment (PBRA) for rates effective July 1, 2026. The calculated PBRA adjustment resulted in a distribution revenue increase of $1.1 million. The filing was approved by the MDPU on June 30, 2026.

Fitchburg - Base Rates - Gas - On August 17, 2023, Fitchburg filed a petition with the MDPU seeking approval for a $10.9 million increase to base distribution rates, with new rates anticipated to be effective July 1, 2024. On June 28, 2024, the MDPU issued an Order providing for a $10.1 million increase to base rates, effective July 1, 2024 approving a PBR plan for up to a five-year term and approving a continuation of the Company’s revenue decoupling mechanism subject to certain changes. The Order also provided for a return on equity of 9.4% and a capital structure reflecting 52% equity and 48% long-term debt. Additionally, the MDPU found that allowing the Company to recover pension and PBOP expense through its Pension/PBOP Adjustment mechanism is no longer warranted and that these expenses should be recovered in base distribution rates. On July 18, 2024, the Company filed a Motion for Reconsideration and Recalculation. The MDPU denied the motion and on December 9, 2024, the Company filed an appeal with Massachusetts Supreme Judicial Court. This appeal is pending.

Fitchburg - Performance Base Rate Adjustment - Gas - On February 27, 2026, Fitchburg filed its second PBRA for rates effective July 1, 2026. The calculated PBRA adjustment resulted in a distribution revenue increase of $1.7 million. The filing was approved by the MDPU on June 30, 2026.

Fitchburg - Gas System Enhancement Program - Pursuant to statute and MDPU order, Fitchburg has an approved Gas System Enhancement Plan (GSEP) tariff through which it may recover certain gas infrastructure replacement and safety related investment costs, subject to an annual cap. Under the plan, the Company is required to make two annual filings with the MDPU: a forward-looking filing for the subsequent construction year, to be filed on or before October 31; and a filing, submitted on or before May 1, of final project documentation for projects completed during the prior year, demonstrating substantial compliance with its plan in effect for that year and showing that project costs were reasonably and prudently incurred. The Company filed its most recent forward-looking cumulative revenue requirement filing on October 31, 2025, requesting recovery of approximately $5.4 million with an additional $1.0 million in prior deferrals for a total of approximately $6.4 million to be recovered. On April 30, 2026, the MDPU issued an order approving the filing, in part for rates effective May 1, 2026. The MDPU reduced the revenue cap from 2.5 percent to 2.0 percent, which reduced the Company’s requested recovery of prior deferrals from $1.0 million to $0.7 million. On May 1, 2026, the Company submitted its final project documentation for projects completed in 2025 and requested recovery of the remaining deferral effective November 1, 2026. These matters remain pending.

Granite State - Base Rates - On October 4, 2024, Granite State filed an uncontested rate settlement with the FERC which provides for an increase in annual revenues of $3.0 million, effective November 1, 2024. The Settlement Agreement permits the filing of limited Section 4 rate adjustments for capital cost projects eligible for cost recovery in 2025, 2026, and 2027, and sets forth an overall cap of $29.9 million on the capital costs recoverable under such filings. Under the Settlement Agreement, Granite State may not file a new general rate case earlier than April 30, 2028 with rates to be effective no earlier than September 1, 2028 based on a test year ending no earlier than December 31, 2027. On November 25, 2024, the FERC approved Granite State’s filing. As authorized by the Settlement Agreement, on July 29, 2025, Granite State filed a limited Section 4 rate adjustment for an annual revenue increase of $1.2 million, effective September 1, 2025. On August 13, 2025, the FERC approved this filing. Granite State filed its second limited Section 4 rate adjustment on July 30, 2026 for an annual revenue increase of $1.3 million, effective September 1, 2026. This matter remains pending.

Other Matters

Massachusetts Inquiry into Gas and Electric Delivery Charge and Bill Redesign - On December 15, 2025, the MDPU opened an investigation to conduct a comprehensive review of gas and electric delivery rates and charges with the aims of containing customer costs, reducing utility bill volatility, and increasing utility bill transparency and accessibility. As directed, on February 13, 2026, each Distribution Company submitted a report including certain requested information regarding delivery related reconciling mechanisms and costs. Written comments from the Distribution Companies and other interested stakeholders responding to a list of questions regarding delivery related reconciling charges were filed on April 14, 2026. Public comments were filed on April 30, 2026. Reply comments were filed on May 14, 2026. On June 26, 2026, a hearing officer memorandum was issued providing an update on the status of the MDPU’s review in this investigation, setting forth procedural next steps, and requesting further input from parties regarding changes to existing processes to enable a more transparent and holistic understanding of each utility’s annual reconciling rate changes. The gas and electric utilities filed a reporting template for cost and rate information on July 31, 2026. Stakeholder comments are due August 14, 2026.

Massachusetts Solar Massachusetts Renewable Target Program (SMART) 3.0 - On November 21, 2025, the EDCs jointly filed a new tariff (the SMART 3.0 Tariff) with the MDPU to implement the SMART 3.0 Program regulations 225 C.M.R. 28.00, which were filed with the Secretary of State on September 12, 2025 (SMART Regulations). The SMART Program, which was first implemented in 2017, establishes a voluntary statewide solar incentive program under the direction of the Massachusetts Department of Energy Resources (DOER). In 2020, the DOER revised its SMART Program regulations, 225 C.M.R. 20.00 -- an update commonly referred to as SMART 2.0. The SMART Program relies on the EDCs to issue incentive payments and alternative on-bill credits to participating customers. Accordingly, the EDCs are seeking approval of revised SMART Tariffs. SMART 3.0 replaces the structure of the initial SMART Program, a declining block incentive program, with a program that contains capacity targets and incentive rates adjusted annually by the DOER. SMART 3.0 Program incentives will be paid over a 20-year term and will vary based on a project’s category and capacity. On January 9, 2026, the EDCs supplemented their filing to provide updated program costs estimates reflecting SMART 3.0 applications received in program year 2025 and assuming full enrollment of all available capacity in program year 2026. Because program year 2025 application levels were significantly lower than the maximum capacity quantities across the EDCs, this resulted in a decrease in estimated maximum statewide costs from $6.7 billion to $4.5 billion over 20 years. Fitchburg’s estimated maximum cost is $191 million over 20 years. The cost projections are illustrative and intended to give the MDPU a sense of scale of the potential long-term costs of the SMART 3.0 Program. The EDCs are not seeking approval of specific costs at this time. The EDCs recover SMART Program costs from all distribution customers through the SMART factor, which is set forth in its current SMART tariff and is updated annually. At the MDPU’s direction, on March 13, 2026, the EDCs filed a revised proposed SMART 3.0 Tariff. On May 19,

2026, the MDPU issued a Phase I Order approving the EDCs’ model SMART 3.0 Tariff and directed the EDCs to file company-specific tariffs. On July 8, 2026, the MDPU approved Fitchburg’s tariff.

Fitchburg - Grid Modernization - On November 20, 2024, the MA Legislature enacted the 2024 Climate Act that requires, among other things, the EDCs to jointly establish a centralized data repository in a cost-effective manner as approved by the MDPU, to allow customers and third parties, including competitive suppliers, access to detailed Advanced Metering Infrastructure (AMI) customer data in near-real time, subject to customer approval and protections. The EDCs jointly proposed an AMI data access protocol implementation plan on February 18, 2026. The Company also submitted a proposal supporting cost recovery of prudent and necessary expenses for the implementation of the repository. This matter is ongoing. On March 12, 2026, the MDPU opened an investigation into the use of AMI interval data to settle load with ISO-NE. On April 23, 2026, parties filed initial comments. This matter also remains pending.

Fitchburg - Grid Modernization Cost Recovery Factor - On April 15, 2025, Fitchburg filed its Grid Modernization Factor (GMF) rate adjustment and reconciliation filing for recovery of the costs incurred as a result of implementing the Company’s 2022-2025 GMP and continued recovery of meter-related costs. This filing seeks recovery of $1.4 million associated with its 2024 GMP revenue requirement as well as $1.5 million associated with its 2024 meter-related costs, effective June 1, 2025. On May 30, 2025, the MDPU issued an order approving the Company’s proposed rate changes effective June 1, 2025 subject to further investigation and reconciliation. On April 15, 2026, Fitchburg filed its GMF rate adjustment and reconciliation filing for recovery of the costs incurred as a result of implementing the Company’s 2022-2025 GMP and continued recovery of meter-related costs. This filing seeks recovery of $1.9 million associated with its 2025 GMP revenue requirement as well as $2.0 million associated with its 2025 meter-related costs, effective June 1, 2026. On May 29, 2026, the MDPU issued an order approving the Company’s proposed rate changes effective June 1, 2026 subject to further investigation and reconciliation. This matter remains pending.

Fitchburg - Investigation into the role of gas LDCs to achieve Commonwealth 2050 climate goals - On December 6, 2023, the MDPU issued an Order announcing a regulatory framework intended to set forth its role and that of the LDCs in helping the Commonwealth achieve its target of net-zero GHG emissions by 2050. The MDPU emphasized that the Order is not intended to jeopardize the rate recovery of existing investments in natural gas infrastructure by Fitchburg. The MDPU ordered the LDCs to submit individual Climate Compliance Plans (CCP) every five years beginning in 2025, and to propose climate compliance performance metrics in upcoming performance-based regulation filings, ensuring a proactive approach to achieving climate targets.

On February 5, 2025, the MDPU issued a memorandum setting a draft line extension policy that would require customers seeking new gas service to pay the entire cost of connecting to the distribution system. On August 8, 2025, the MDPU issued an Interlocutory Order setting forth a revised Straw Proposal that would require customers seeking new gas service to pay the entire cost of connecting to the distribution system, subject to certain exceptions and requiring the LDCs to submit model tariffs incorporating the revised policy. On September 5, 2025, the MDPU clarified that the Interlocutory Order is not a final decision, and that the LDCs and line extension allowance issues would be litigated in the CCP proceedings.

On April 1, 2025, Fitchburg filed its first CCP. The Company’s plan presents a portfolio of initiatives that will help the Commonwealth meet its decarbonization goals over the next five-to-ten years, while maintaining a focus on customers’ long-term interests in safety, reliability, affordability, and equity. Fitchburg also filed a model CCP Tariff to establish a cost recovery mechanism for the development and implementation of the CCP, including costs associated with assessing and implementing NPAs. This matter remains pending. Hearings occurred in early March 2026.

In its D.P.U. 20-80-B Order, the MDPU directed each LDC to work with the relevant EDC to study the feasibility of piloting a targeted electrification project in its service territory, and to propose at least one demonstration project for decommissioning an area of its system through targeted electrification. On March 16, 2026, Fitchburg filed its proposed Targeted Electrification Pilot Project and Targeted Electrification Pilot Provision in compliance with the Order. The Company proposed implementing its pilot on Maryland Avenue in Fitchburg, MA on a segment of main serving eight customers. The identified segment is scheduled for replacement in 2029. This matter remains pending.

Fitchburg - Electric Sector Modernization Plan - Pursuant to M.G.L. c. 164 § 92B, Fitchburg submitted a draft Electric Sector Modernization Plan (ESMP) to the statutorily created Massachusetts Grid Modernization Advisory Council (Council) for the Council’s review, input, and recommendations. The ESMP is a plan intended to upgrade the Company’s distribution system to enable and accommodate increased distributed energy resources (DERs) and electrification technologies, improve grid reliability and resiliency, and assist the Commonwealth in achieving climate goals, among other objectives. On August 29, 2024, the MDPU issued a final order approving the Company’s ESMP. On March 31, 2026, the Company submitted its Biannual Report summarizing its progress on ESMP investments in the preceding year.

Following a stakeholder process related to long term system planning, Fitchburg and other EDCs submitted a draft Long-Term System Planning Proposal (LTSPP) for MDPU review and approval. On December 16, 2025, the MDPU issued an Order establishing a phased approach to investigate the LTSPP jointly proposed by the electric distribution companies and stakeholders. The MDPU intends to establish a uniform LTSPP for the Distribution Companies to proactively upgrade their respective electric power systems to enable increased, timely interconnection of new distributed generation (DG), which will support the Commonwealth’s energy and climate policies. To expedite the cost-effective deployment and interconnection of DG, Phase I will focus on the establishment of a framework for the LTSPP and other necessary elements for the Distribution Companies to make the first LTSPP filings. The MDPU will investigate additional topics in Phase II, in parallel with Phase I, to ensure effective LTSPP implementation following the MDPU’s review of proposed LTSPP investments. Fitchburg and the other Massachusetts EDCs submitted joint Phase I initial testimony in support of their LTSPP proposal on April 10, 2026. Discovery and additional testimonies were filed in May and June, and the EDCs filed a revised LTSPP Framework and Model Tariff on July 22, 2026. This matter remains pending.

Fitchburg - Electric Vehicle (EV) Proceedings - On December 31, 2025, Fitchburg submitted to the MDPU a petition for approval of a right-of-way and pole-mounted electric vehicle supply equipment (EVSE) proposal as required by the 2024 Climate Act (Chapter 239, Section 134 of the Acts of 2024). The Company proposes to leverage the program modifications approved on October 17, 2025 to continue to promote public EVSE through its currently approved EV program, which will extend through 2027. This matter remains pending.

Maine Natural – Cost Recovery Associated with IRS Normalization - On June 4, 2026, Maine Natural requested recovery of the deferred costs agreed to in the May 19, 2025 Stipulation in Docket No. 2025-00060. The Stipulation permitted Maine Natural to defer and recover over a three-year period the cost of the tax benefit that the customers received but did not fund totaling $2.8 million, including carrying costs. Maine Natural has proposed that the annual recovery of $0.9 million become effective September 1, 2026. This matter remains pending.

Unitil Corporation – Merger of Aquarion Water Companies - On May 6, 2025, Unitil announced that it had entered into a definitive agreement to acquire Aquarion Water Company of Massachusetts Inc., Aquarion Water Company of New Hampshire, Inc., and Abenaki Water Co., Inc. from the Aquarion Water Authority (AWA), a quasi-public corporation chartered by the Connecticut General Assembly in 2024 to acquire Aquarion and to operate as a water authority. Unitil’s acquisition of the Aquarion Companies is contingent upon the initial sale of Aquarion by Eversource Energy (Eversource) to the AWA (Initial Transaction), which will then simultaneously convey the Aquarion Companies to Unitil. On March 25, 2026, PURA issued a Final Decision approving the application.

On May 8, 2025, Eversource, the AWA, and Unitil submitted an amended and restated petition to the MDPU for approval of a change of control of Aquarion Water Company of Massachusetts, Inc. (AWC-MA). On December 12, 2025, the MDPU issued an Order approving the stock sale of Aquarion by Eversource to AWA, and, in turn, AWA’s simultaneous sale of AWC-MA to Unitil. The approval is subject to certain conditions, including a two-year rate case filing moratorium. The MDPU also declined to rule on the issue raised by the MA Attorney General's Office, of ratemaking treatment of the gain on sale of certain assets that occurred under Eversource ownership. On January 2, 2026, Unitil, Eversource, and AWA filed a motion for reconsideration and clarification of the MDPU’s Order with respect to the rate case moratorium and ratemaking treatment of the gain on sale. The MDPU denied the motion for reconsideration on March 30, 2026.

On May 8, 2025, Unitil, Eversource, AWC-NH, Abenaki and AWA filed a motion to amend the petition originally filed on April 10, 2025 by Eversource. AWC-NH, Abenaki and AWA, requesting that the NHPUC approve the acquisition of AWC-NH and Abenaki by Unitil. On August 28, 2025, the Joint Petitioners and the NH DOE submitted a settlement agreement to the NHPUC recommending approval of the proposed acquisition subject to certain conditions, including a rate case stay-out through June 1, 2026. On October 7, 2025, the NHPUC issued an Order approving the settlement agreement.

On June 30, 2026, Unitil closed on the acquisition of AWC-NH and Abenaki, which are now wholly owned subsidiaries of Unitil.

Maine Inquiry Into the Future of Gas - On May 13, 2025, the MPUC initiated an inquiry to explore the implications of Maine’s decarbonization goals for natural gas utilities and their customers and solicit information from stakeholders. Specifically, the MPUC opened the inquiry with the goal of: 1) developing a consistent methodology or framework to incorporate and evaluate the GHG emissions impact in the MPUC’s decision-making around gas infrastructure investments and contractual commitments for supply or capacity needed to serve customers; 2) evaluating the consistency of these investments with state goals; and 3) assisting in evaluation of a broader path for the future of natural gas in Maine. Initial comments on the scope of the inquiry were submitted on June 17, 2025. On December 18, 2025, the MPUC issued a Procedural Order scheduling a workshop on January 21, 2026 to explore issues raised in comments. The Company submitted a second round of comments on March 20, 2026. This matter remains pending.

Reconciliation Filings - Fitchburg, Unitil Energy, Northern Utilities, Bangor and Maine Natural each have a number of regulatory reconciling accounts that require annual or semi-annual filings with the MDPU, NHPUC and MPUC, respectively, to reconcile revenues and costs, and to seek approval of any rate changes. These filings include: annual electric reconciliation filings by Fitchburg and Unitil Energy for a number of items, including default service, stranded cost changes and transmission charges; costs associated with energy efficiency programs in New Hampshire and Massachusetts, as directed by the NHPUC and MDPU; recovery of the ongoing costs of storm repairs incurred by Unitil Energy and Fitchburg; and the actual wholesale energy costs for electric power and gas incurred by each of the five companies. Fitchburg, Unitil Energy, Northern Utilities, Bangor and Maine Natural have been, and remain in full compliance with all directives and orders regarding these filings. The Company considers these to be routine regulatory proceedings, and there are no material issues outstanding.

Fitchburg - Massachusetts Request for Proposals (RFPs) - Pursuant to Section 83 of “An Act Relative to Green Communities,” St. 2008, c. 169, as amended, the Massachusetts EDCs, including Fitchburg, have conducted numerous procurements of long-term renewable energy and environmental attributes. “An Act to Promote Energy Diversity” (2016) (the Act) added Section 83C, which required the joint procurement of 1,600 MW of offshore wind by June 30, 2027 (this target has since been increased as explained below) and Section 83D, which required the joint procurement of cost-effective long-term contracts for an annual total of 9,450,000 megawatt-hours (MWh) of clean energy (hydroelectric, solar and land-based wind) by December 31, 2022. Fitchburg’s pro rata share of the contracts resulting from these procurements is approximately one percent.

The EDCs issued the RFP for Section 83D Long-Term Contracts in March 2017, and transmission service agreements with NECEC Transmission LLC and power purchase agreements (PPAs) for 9,554,940 MWh annually of hydroelectric generation and associated environmental attributes with Hydro-Quebec Energy Services (U.S.), Inc. (together, the NECEC project) over a 20-year period, were filed for approval by the MDPU in July 2018. The MDPU approved the agreements in June 2019, including the EDCs’ proposal to sell the energy procured under the contract into the ISO-NE wholesale market and to credit or charge the difference between the contract costs and the ISO-NE market revenue to customers. The MDPU also approved the EDCs’ request for remuneration equal to 2.75% of the contract payments, as well as the EDCs’ proposal to recover costs associated with the contracts. The NECEC project achieved commercial operation on January 16, 2026.

The EDCs issued the first RFP for offshore wind energy generation pursuant to Section 83C in June 2017. In July 2018, the EDCs filed two long-term PPAs with Vineyard Wind, each for 400 MW for approval by the MDPU. In April 2019, the MDPU approved the offshore wind PPAs, including similar requirements for the EDCs to sell the energy procured and credit or charge net costs to customers including EDC remuneration of 2.75%. Vineyard Wind achieved commercial operation for both Facilities on April 24, 2026, at less than 100 percent of the project's full 800MW capacity. The developer expects to achieve full capacity in the third quarter of 2026.

The EDCs issued additional RFPs pursuant to Section 83C to procure additional offshore wind energy generation in May 2019 and in May 2021. These two procurements led to four additional PPAs for a total of 2400 MW that were approved by MDPU but were later terminated in September 2023.

The EDCs issued a fourth offshore wind RFP in August 2023 seeking to procure at least 400 MW and up to the maximum amount remaining of the statutory requirement under Section 83C of 5,600 MW of Offshore Wind Energy Generation, pursuant to “An Act Driving Clean Energy and Offshore Wind” (2022), which increased the total solicitation target (including future solicitations) for offshore wind energy generation to 5,600 MW by June 30, 2027. The EDCs received bids for offshore wind energy generation from three developers as part of a multi-state solicitation with Rhode Island and Connecticut. In September 2024, the DOER selected a portfolio of projects totaling 2,678 MW from the three projects, one of which was dependent on commitments from Connecticut. In December 2024, Connecticut withdrew from contract negotiations resulting in the termination of the conditional project. Contract negotiations with the remaining two developers have been extended to January 29, 2027.

In December 2024, the Massachusetts Legislature approved “An Act promoting a clean energy grid, advancing equity, and protecting ratepayers” which among other provisions, extends the period for long-term renewable contracts up to 30 years and directs the EDCs, under a new Section 83E, to “jointly and competitively solicit proposals for energy storage systems and enter into cost-effective long-term contracts equal to, in the aggregate, approximately 5,000 megawatts of energy storage systems not later than July 31, 2030.” Pursuant to Section 83E, the EDCs jointly issued the first RFP for energy storage systems (ESS) in July 2025 seeking environmental attributes associated with approximately 1,500 megawatts of mid-duration energy storage systems. In December 2025, the DOER selected a portfolio of battery energy storage projects that total 1,268 MW. On July 2, 2026, the EDCs filed long-term contracts for three of the four selected storage projects with the MDPU for approval. One project paused negotiations with the EDCs in order to assess the cost impacts of the most recent ISO-NE Cluster Study results. A second solicitation under Section 83E is currently being developed for release in July 2026. Fitchburg’s pro rata share of the contracts resulting from these procurements is approximately one percent.

Pursuant to Section 82 of Chapter 179 of the Acts of 2022 (An Act driving clean energy and offshore wind), the DOER is authorized to coordinate with other New England states issuing competitive solicitations for long-term clean energy generation, including nuclear power generation, associated environmental attributes, transmission or capacity for the benefit of residents of the Commonwealth and the region. If the DOER, in consultation with the EDCs and the office of the Attorney General, determines not later than December 31, 2027, that a project would satisfy the benefits listed in Section 82, the DOER may direct the EDCs to enter into cost-effective long-term contracts. The DOER and the EDCs are currently engaging with Maine and other New England states to consider participating in procurements issued by Maine and Connecticut to potentially procure environmental attributes, energy, or transmission. On September 10, 2025, Connecticut issued an Expedited Zero Carbon RRP for advanced stage solar, wind, and co-located storage projects with bids due on October 10, 2025. DOER, in consultation with the EDCs, evaluated the bids under the Section 82 beneficial determination criteria and they selected two projects for Massachusetts to enter into long-term contracts for up to 100% of the energy and RECs. The EDCs are presently in negotiations with the developers. Fitchburg’s pro rata share of the contracts resulting from the Section 82 procurements is approximately one percent.

The DOER and the EDCs are currently assessing transmission and renewable generation bids received through the Northern Maine Renewable Energy Development RFP issued on December 19, 2025. DOER and the EDCs are also evaluating bids received in the Connecticut 2026 Zero Carbon RFP for nuclear, hydropower, solar, onshore wind, and paired/co-located storage that was issued on January 30, 2026. Project selection for both procurements is expected to occur during Q3 2026. The EDCs would then initiate contract negotiations with the selected developers.

FERC Transmission Formula Rate Proceedings- Pursuant to Section 206 of the Federal Power Act, there are several pending proceedings before the FERC concerning the justness and reasonableness of the Return on Equity (ROE) component of the ISO-New England, Inc. Participating Transmission Owners’ (PTOs) Regional Network Service and Local Network Service formula rates. In August 2013, FERC had found that the Transmission Owners' existing ROE was unlawful, and set a new ROE. On April 14, 2017, the U.S. Court of Appeals for the D.C. Circuit issued an opinion vacating and remanding FERC’s decision, finding that FERC had failed to articulate a satisfactory explanation for its orders. The ROE set in the vacated order was to remain in place until FERC took further action. On November 21, 2019, the FERC issued an order in EL14-12, Midcontinent Independent System Operator ROE, in which FERC outlined a new methodology for calculating the ROE. The New England Transmission Owners (NETOs) thereafter filed a motion to reopen the record in their pending ROE dockets, which was granted. On March 19, 2026, the FERC issued Opinion No. 594 in Docket No. EL 11-66 reducing the ROE from 10.57% to 9.57% effective October 1, 2011 and established refund periods of October 1, 2011 to December 31, 2012 and October 16, 2014 to March 19, 2026. Fitchburg recorded a charge of $0.9 million in the three months ended March 31, 2026 related to the refund periods. A ROE of 9.57% will be used to calculate transmission revenue requirements effective for the remainder of 2026 and going forward.

The NETOs were directed to file refund reports by April 18, 2026. On April 2, 2026, the NETOs filed a motion to extend the refund deadline and requested an expedited comment period. The motion was granted on April 14, 2026 and set a refund date of May 20, 2027. Refund reports are due June 4, 2027. On April 20, 2026, the NETOs timely sought rehearing of Opinion No. 594, which FERC denied on May 21, 2026. The NETOs appealed FERC Opinion No. 594 to the U.S. Court of Appeals, DC Circuit on June 17, 2026. This appeal remains pending.

On April 30, 2026, the NETOs submitted a 205 filing at FERC requesting an ROE of 11.39% based on recalculating March 19, 2026 Order results with current data. This matter remains pending. The Company does not believe these proceedings will have a material effect on its financial condition or results of operations.

Legal Proceedings