Citizen Power - Filings at various regulatory proceedings

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Citizen Power 2121 Murray Ave Pittsburgh, PA 15217 (412) 421-6072 (412) 421-6162 Fax info@citizenpower.com	Filings Citizen Power - Filings at various regulatory proceedings (Selected legal filings of Citizen Power as part of its advocacy work for an electricity market that enables increased use of renewable energy and energy-efficiency technologies) Duquesne Light Restructuring Main Brief Main Brief filed at the Pennsylvania Public Utility Commission (PA PUC), February 2, 1998 in the Duquesne Light Company Restructuring case, (Docket No. R-974104). DQE-APS Merger Comments Comments filed at the Federal Energy Regulatory Commission (FERC) on June 22, 1998 (Docket No. EC97-46-000) on information filed by Duquesne Light Company and Allegheny Power in connection with their application to merge. Comments on DQE Auction Comments filed on November 9, 1998 at the PA PUC (Docket No. R-974104) in connection with Duquesne Light Company's plan to sell all of its generating plants. The PUC approved the generation auction without a formal investigation. Duquesne sold all of its plants to Orion Power for $1.7 billion, or exactly what it claimed it had in "stranded costs". The sale will enable the transition charge to be dropped from Duquesne customer bills in March 2002. Reliant Energy (Houston) is bidding to buy Orion in 2002. DQE Auction Complaint Complaint filed at FERC on February 11, 1999 (Docket No. El-39-99) in connection with Duquesne Light Company's plan to auction its generation plants. Jurisdiction Petition Petition filed on February 11, 1999 at FERC (Docket No. EL99-40-00) requesting FERC to assert its jurisdiction under the Federal Power Act over generation asset dispositions. Comments on The DQE-FE Generation Exchange Comments filed on June 7, 1999 at the PA PUC (Docket No. A-110150-F0020) on the plan for Duquesne Light Company (PA) and FirstEnergy (Ohio) to exchange ownership of generation plants. Duquesne took ownership of three old coal plants that it later sold in an auction. Duquesne gave its share of ownership in the Perry 1 and Beaver Valley 1&2 nuclear units to FirstEnergy. The PUC approved the exchange without a formal investigation. Initial Brief-CP and OEC Initial Brief filed on June 2, 2000 at the Public Utilities Commission of Ohio (PUCO) (Docket No. 99-1212) in connection with the FirstEnergy Restructuring or Transition Plan. Citizen Power Reply Brief Reply Brief filed in the First Energy Transition Plan case at PUCO (Docket No. 99-1212 ) on June 9, 2000. PUCO approved a settlement on July 19, 2000. Petition for Rehearing Petition for Rehearing on PUCO Order approving settlement in FirstEnergy Transition Plan case filed on August 18, 2000 (Docket No. 99-1212). PUCO denied rehearing request because rehearing request was faxed instead of hand filed or mailed. Citizen Power appealed this Order to the Ohio Supreme Court. The court dismissed the appeal without comment. Jurisdiction Rehearing Request for Rehearing filed on March 9, 2001 at FERC (Docket No. EL99-40-00) requesting FERC to reconsider its February 7, 2001 Order refusing to declare that it has jurisdiction over generation asset dispositions. Citizen Power Main Brief Main Brief filed on April 6, 2001 at the PA PUC (Docket No. A-110300F-0095) on the application of FirstEnergy to buy General Public Utilities (GPU). The PUC approved the merger on June 20, 2001. Citizen Power Reply Brief Reply Brief filed on April 13, 2001 in the FirstEnergy-GPU merger proceeding before the PA PUC, Docket No. A-110300F-0095. Reply Exceptions Exceptions to the PA PUC Administrative Law Judge's decision in the FirstEnergy-GPU merger case, May 12, 2001, Docket No. A-110300F-0095. Rehearing Motion Motion filed on September 1, 2001 in case number 00-2469-EL-UNC asking the PUCO to reconsider its decision not to investigate whether the acquisition of General Public Utilities of New Jersey by FirstEnergy (Akron, Ohio) is in the public interest. Motion was denied on September 5, 2001 and case is on appeal at the Ohio Supreme Court. Citizen Power FEGPU Initial Brief Initial Joint Brief of Citizen Power and Clean Air Council filed on September 7, 2001 at the Pennsylvania Commonwealth Court (Case No. 1674 C.D. 2001) appealing the PA PUC June 20, 2001 Orders approving the FirstEnergy-GPU merger and GPU rate relief request. Case pending. Brief of Petitioners in DC Circuit Initial Brief filed on October 31, 2001 at the U.S. Court of Appeals, DC Circuit, Case No. 01-1240, appealing two FERC orders (February 7, 2001 and April 6, 2001) rejecting Citizen Power's and the American Public Power Association's Petition for a Declaratory Order. The appeal asks the Court to make a determination as to whether FERC erred in concluding that it lacked jurisdiction to review, under Federal Power Act Section 203, proposed dispositions of generating facilities valued above $50,000 that are used to produce electric energy sold at wholesale in interstate commerce. Citizen Power Brief Merit Brief filed January 11, 2002 at the Ohio Supreme Court (Case No. 01-1956), appealing the Public Utilities Commission of Ohio Order refusing to review the acquisition of General Public Utilities (GPU) of New Jersey and Pennsylvania, by FirstEnergy, to determine if the merger is in the public interest. PA SC FE-GPU Appeal Appeal filed March 25, 2002 in the Pennsylvania Supreme Court of the Commonwealth Court decision affirming the PaPUC Order approving the merger of FirstEnergy and GPU. Initial Brief Merit Brief filed May 28, 2002 in the Ohio Supreme Court (Case No. 02-400) appealing the PUCO Order approving the FirstEnergy Compliance Filing asserting the utility has achieved a 20% customer switching level. Home \| Search \| Feedback \| Links

Citizen Power
2121 Murray Ave
Pittsburgh, PA 15217
(412) 421-6072
(412) 421-6162 Fax
info@citizenpower.com

Filings

Citizen Power - Filings at various regulatory proceedings

(Selected legal filings of Citizen Power as part of its advocacy work for an electricity market that enables increased use of renewable energy and energy-efficiency technologies)

Duquesne Light Restructuring Main Brief Main Brief filed at the Pennsylvania Public Utility Commission (PA PUC), February 2, 1998 in the Duquesne Light Company Restructuring case, (Docket No. R-974104).

DQE-APS Merger Comments Comments filed at the Federal Energy Regulatory Commission (FERC) on June 22, 1998 (Docket No. EC97-46-000) on information filed by Duquesne Light Company and Allegheny Power in connection with their application to merge.

Comments on DQE Auction Comments filed on November 9, 1998 at the PA PUC (Docket No. R-974104) in connection with Duquesne Light Company's plan to sell all of its generating plants. The PUC approved the generation auction without a formal investigation. Duquesne sold all of its plants to Orion Power for $1.7 billion, or exactly what it claimed it had in "stranded costs". The sale will enable the transition charge to be dropped from Duquesne customer bills in March 2002. Reliant Energy (Houston) is bidding to buy Orion in 2002.

DQE Auction Complaint Complaint filed at FERC on February 11, 1999 (Docket No. El-39-99) in connection with Duquesne Light Company's plan to auction its generation plants.

Jurisdiction Petition Petition filed on February 11, 1999 at FERC (Docket No. EL99-40-00) requesting FERC to assert its jurisdiction under the Federal Power Act over generation asset dispositions.

Comments on The DQE-FE Generation Exchange Comments filed on June 7, 1999 at the PA PUC (Docket No. A-110150-F0020) on the plan for Duquesne Light Company (PA) and FirstEnergy (Ohio) to exchange ownership of generation plants. Duquesne took ownership of three old coal plants that it later sold in an auction. Duquesne gave its share of ownership in the Perry 1 and Beaver Valley 1&2 nuclear units to FirstEnergy. The PUC approved the exchange without a formal investigation.

Initial Brief-CP and OEC Initial Brief filed on June 2, 2000 at the Public Utilities Commission of Ohio (PUCO) (Docket No. 99-1212) in connection with the FirstEnergy Restructuring or Transition Plan.

Citizen Power Reply Brief Reply Brief filed in the First Energy Transition Plan case at PUCO (Docket No. 99-1212 ) on June 9, 2000. PUCO approved a settlement on July 19, 2000.

Petition for Rehearing Petition for Rehearing on PUCO Order approving settlement in FirstEnergy Transition Plan case filed on August 18, 2000 (Docket No. 99-1212). PUCO denied rehearing request because rehearing request was faxed instead of hand filed or mailed. Citizen Power appealed this Order to the Ohio Supreme Court. The court dismissed the appeal without comment.

Jurisdiction Rehearing Request for Rehearing filed on March 9, 2001 at FERC (Docket No. EL99-40-00) requesting FERC to reconsider its February 7, 2001 Order refusing to declare that it has jurisdiction over generation asset dispositions.

Citizen Power Main Brief Main Brief filed on April 6, 2001 at the PA PUC (Docket No. A-110300F-0095) on the application of FirstEnergy to buy General Public Utilities (GPU). The PUC approved the merger on June 20, 2001.

Citizen Power Reply Brief Reply Brief filed on April 13, 2001 in the FirstEnergy-GPU merger proceeding before the PA PUC, Docket No. A-110300F-0095.

Reply Exceptions Exceptions to the PA PUC Administrative Law Judge's decision in the FirstEnergy-GPU merger case, May 12, 2001, Docket No. A-110300F-0095.

Rehearing Motion Motion filed on September 1, 2001 in case number 00-2469-EL-UNC asking the PUCO to reconsider its decision not to investigate whether the acquisition of General Public Utilities of New Jersey by FirstEnergy (Akron, Ohio) is in the public interest. Motion was denied on September 5, 2001 and case is on appeal at the Ohio Supreme Court.

Citizen Power FEGPU Initial Brief Initial Joint Brief of Citizen Power and Clean Air Council filed on September 7, 2001 at the Pennsylvania Commonwealth Court (Case No. 1674 C.D. 2001) appealing the PA PUC June 20, 2001 Orders approving the FirstEnergy-GPU merger and GPU rate relief request. Case pending.

Brief of Petitioners in DC Circuit Initial Brief filed on October 31, 2001 at the U.S. Court of Appeals, DC Circuit, Case No. 01-1240, appealing two FERC orders (February 7, 2001 and April 6, 2001) rejecting Citizen Power's and the American Public Power Association's Petition for a Declaratory Order. The appeal asks the Court to make a determination as to whether FERC erred in concluding that it lacked jurisdiction to review, under Federal Power Act Section 203, proposed dispositions of generating facilities valued above $50,000 that are used to produce electric energy sold at wholesale in interstate commerce.

Citizen Power Brief Merit Brief filed January 11, 2002 at the Ohio Supreme Court (Case No. 01-1956), appealing the Public Utilities Commission of Ohio Order refusing to review the acquisition of General Public Utilities (GPU) of New Jersey and Pennsylvania, by FirstEnergy, to determine if the merger is in the public interest.

PA SC FE-GPU Appeal Appeal filed March 25, 2002 in the Pennsylvania Supreme Court of the Commonwealth Court decision affirming the PaPUC Order approving the merger of FirstEnergy and GPU.

Initial Brief Merit Brief filed May 28, 2002 in the Ohio Supreme Court (Case No. 02-400) appealing the PUCO Order approving the FirstEnergy Compliance Filing asserting the utility has achieved a 20% customer switching level.

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