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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:

do you need a prescription for Misoprostol in mexico filed May 29, 2015 in PA PUC Case L-2014-2404361 regarding recent proposed revisions to the implementation of the Alternative Energy Portfolio Standards Act. Specifically, Citizen Power recommended that residential systems should not be subject to a design limit of 200% of their load and that the use of virtual meter aggregation should not require that a load be present at every location.

Misoprostol filed May 20, 2015 in PA PUC Case M-2014-2401127 regarding Duquesne Light’s Plan to institute “Seamless Moves” allowing customers to keep the same generation supplier when moving from a location within Duquesne Light’s territory to another location within Duquesne Light’s territory.

Citizen Power Reply Comments filed May 12, 2015 in PA PUC Case M-2015-2468992 regarding the formulation of the Total Resource Cost (TRC) Test which is used to determine the cost and benefits of energy efficiency and conservation programs in Pennsylvania.

Citizen Power Comments filed April 27, 2015 in PA PUC Case M-2014-2424864 concerning the implementation of the third phase of Pennsylvania’s Act 129 Energy Efficiency and Conservation Plans.

Citizen Power Comments filed September 3, 2014 in PA PUC Case L-2014-4361 regarding the implementation of the Alternative Energy Portfolio Standards Act as applied to net metering and virtual aggregation.

Citizen Power Comments filed March 24, 2014 in PA PUC Case L-2014-2409385 concerning the structure of electric customer bills, renewal notices, and notifications of electric generation service provider’s rate increases.

Prehearing Memorandum filed October 2, 2013 in PA PUC Case R-2013-2372129 by Citizen Power regarding Duquesne Light’s Proposed Supplement to their Tariff, which would raise rates significantly for residential consumers.

Citizen Power Comments filed June 24, 2013 in PA PUC Case M-2013-2362961 concerning the use of pass-through clauses by electric utilities and labeling of retail electric products as “fixed price”.

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Citizen Power Comments filed March 10, 2013 in PA PUC Case P-2012-2301664 regarding Duquesne Light’s Revised Market Enhancement Program Design and Cost-Recovery Proposal which unreasonably caps the share of the customer application fee that electric generation supplies at $30, which could result in additional costs for default supply customers.

Joint Comments filed March 7, 2013 in PUCO Case 12-2190-EL-POR by Citizen Power, Ohio Environmental Council, the Environmental Law and Policy Center, and the Sierra Club in response to an inappropriate letter sent by FirstEnergy to the PUC Commission regarding contested issues in an ongoing case.

Joint Petition for Partial Settlement filed January 28, 2013 in PA PUC Case M-2012-2334399 by the Office of Consumer Advocate, the Coalition for Affordable Utility Services and Energy Efficiency in Pennsylvania, the Community Action Association of Pennsylvania, Citizen Power, Comverge, and Duquesne Light Company regarding Duquesne Light’s Phase II EE&C Plan.

Citizen Power Comments filed January 23, 2013 to the U.S. Department of Energy regarding their LNG Study and the associated documents Effect of Increased Natural Gas Exports on Domestic Energy Markets and Macroeconomic Impacts of Increased LNG Exports from the United States. Citizen Power detailed flaws in the LNG Study and determined that it is not in the public interest to authorize the exportation of LNG from the lower-48 states to non-free trade agreement countries.

Citizen Power Reply Exceptions filed December 17, 2012 in PA PUC Case P-2012-2301664 concerning Exceptions filed by the Retail Energy Supply Association about the Recommended Decisions of the ALJ regarding Duquesne Light’s Default Service Petition.

Joint Memorandum in Response filed December 11, 2012 in PUCO Case 12-2190-EL-POR by Citizen Power, Ohio Environmental Council, and the Sierra Club in response to FirstEnergy’s request to extend the current Energy Efficiency and Peak Demand Reduction Program Portfolio Plan.

Citizen Power Comments filed December 10, 2012 in PA PUC Case I-2011-2237952 in response to a November 8, 2012 Tentative Order regarding Pennsylvania’s retail electric market.

Citizen Power Petition to Intervene filed December 7, 2012 in PA PUC Case M-2012-2334399 in response to Duquesne Light’s Petition requesting the Commission to approve their Phase II EE&C Plan.

Joint Reply Brief filed November 30, 2012 in PUCO Case 12-2190-EL-POR by Citizen Power, NRDC, and the Sierra Club regarding FirstEnergy’s 2013-2015 Energy Efficiency and Peak Demand Reduction Program Portfolio Plan.

Joint Initial Brief filed November 20, 2012 in PUCO Case 12-2190-EL-POR by Citizen Power, NRDC, and the Sierra Club regarding FirstEnergy’s 2013-2015 Energy Efficiency and Peak Demand Reduction Program Portfolio Plan, which was deficient in several respects.

Citizen Power Comments filed November 19, 2012 in PUCO Case 12-2157-EL-ORD regarding the adoption of green pricing programs to implement AM Sub SB 315.

Joint Comments filed November 2, 2012 in PUCO Case 12-665-EL-UNC by Citizen Power and the Sierra Club concerning the verification of energy efficiency and peak demand reduction achieved by electric distribution utilities.

Citizen Power Reply Brief filed October 22, 2012 in PA PUC Case P-2012-2301664 opposing the Main Brief of the Retail Energy Supply Association in their assertion that 3 month periods for default service auctions are prudent as well as their belief that the costs of market enhancements should be borne by default service customers.

Citizen Power Main Brief filed October 5, 2012 in PA PUC Case P-2012-2301664 regarding the correct customer participation cap for a retail opt-in program proposed under Duquesne Light’s Default Service Petition, as well as requested modifications to other aspects of the Petition.

Citizen Power Prehearing Memo filed September 14, 2012 in PA PUC Case M-2009-2123948 regarding Duquesne Light’s Final Smart Meter Technology Procurement and Installation Plan.

Joint Application for Rehearing filed August 17, 2012 in PUCO Case 12-1230-EL-SSO by Citizen Power and the Ohio Consumers’ Counsel in response to the July 18, 2012 Order which approved a stipulation that raised FirstEnergy electricity rates.
Answer to Duquesne Light’s Petition for Approval of its Smart Meter Technology Procurement and Installation Plan filed on July 23, 2012 in PA PUC Case M-2009-2123948 by Citizen Power.

Joint Reply Brief filed June 29, 2012 in PUCO Case 12-1230-EL-SSO by Citizen Power and the Ohio Consumers’ Counsel opposing the implementation of FirstEnergy’s ESP Plan.

Citizen Power Comments filed June 29, 2012 in PA PUC Case M-2012-2300653 concerning the Total Resource Cost Test and the interpretation of the incremental cost of early replacement measures.

Citizen Power Comments filed June 26, 2012 in PA PUC Case M-2012-2289411 requesting that the Pennsylvania Public Utility Commission convene a working group to investigate the ways that Pennsylvania’s EE&C programs could be implemented in order to maximize participation in PJM’s Base Residual Auctions.

Joint Brief filed June 22, 2012 in PUCO Case 12-1230-EL-SSO by Citizen Power and the Ohio Consumers’ Counsel opposing the implementation of FirstEnergy’s ESP Plan.

Citizen Power Petition to Intervene filed June 1, 2012 in PA PUC Case P-2012-2301664 regarding the Petition of the Duquesne Light Company for Approval of a Default Service Plan for the period from June 1, 2013 through May 31, 2015.

Citizen Power Comments filed May 30, 2012 in PA PUC Case M-2012-2293611 regarding the implementation of Act 11 of 2012 which allows utilities to petition for a distribution system improvement charge. Specifically, Citizen Power advocated for a requirement that utilities submit a cost benefit analysis indicating the expected benefits in terms of reliability improvements.

Citizen Power Comments filed April 17, 2012 in PA PUC Case M-2012-2289411 concerning Phase Two of Pennsylvania’s Act 129 EE&C Program specifically advocating for the retention of the low-income carve-out.

Joint Comments filed April 10, 2012 in PUCO Case 12-814-EL-UNC regarding potential strategies to mitigate expected price increases in the PJM capacity market as a result of the closing of FirstEnergy generation facilities.

Citizen Power Comments filed January 17, 2012 in PA PUC Case I-2011-2237952 in response to a December 16, 2011 Tentative Order regarding Pennsylvania’s retail electric market.

1-30-11 Citizen Power Comments filed November 30, 2011 in the U.S. Environmental Protection Agency’s Case EPA-HQ-OAR-2010-0505 concerning proposed Oil and Natural Gas Air Pollution Standards which amended the new source performance standards and the national emission standards for hazardous air pollutants as they apply to the Oil and Natural Gas sector. Specifically, Citizen Power recommended standards which would have required third party verification was well as stringent estimations of VOC emissions from produced water ponds.

Citizen Power Comments filed November 3, 2011 in PA PUC Case I-2011-2237952 regarding proposed changes to the structure of Pennsylvania’s retail electric market.

Citizen Power Comments filed October 6, 2011 in PUCO Case 11-4624-AU-ORD concerning the composition of the fuel source advisory council.

Joint Motion for Waiver and Comments filed September 14, 2011 in PUCO Case 11-4627-EL-WVR regarding the annual deadline for the filing of Ohio utilities energy efficiency portfolio status reports.

Citizen Power Comments filed September 12, 2011 in PA PUC Case M-2011-2249441 concerning the definition of “customer generators” as used in Act 213’s net metering provisions.

Joint Petition for Reconsideration filed August 1, 2011 in PUCO Case P-2010-2195426 by Citizen Power and the Pennsylvania Cement and Steel Manufacturers Coalition in response to the Commission’s Order denying our petition requesting a review of the potential over-collection of stranded costs and a corresponding refund of the over-collections to consumers.

Joint Application for Rehearing filed July 8, 2011 in PUCO Case 09-951-EL-EEC by Citizen Power, the Office of the Ohio Consumers’ Counsel, the Ohio Environmental Council, and NRDC regarding the Finding and Order of PUCO allowing FirstEnergy to count inappropriate Distribution and Transmission projects toward their EE&C and PDR benchmarks.

Joint Comments filed June 27, 2011 in PUCO Case 11-2479-EL-ACP by Citizen Power and the Office of the Ohio Consumers’ Counsel opposing the Application of FirstEnergy for a Force Majeure determination regarding SREC benchmarks in 2010.

Citizen Power Motion to Intervene filed June 6, 2011 in PUCO Case 11-2479-EL-ACP which concerns the Application of FirstEnergy for a Force Majeure determination regarding SREC benchmarks in 2010.

Joint Motion for Protective Order filed June 2, 2011 in PUCO Case 10-3023-EL-EEC by Citizen Power, the Office of the Ohio Consumers’ Counsel, and the NRDC regarding the filing of confidential information in a case concerning the application of FirstEnergy’s 2010 transmission and distribution projects toward their EE&C benchmarks.

Joint Motion for Hearing filed June 2, 2011 in PUCO Case 10-3023-EL-EEC by Citizen Power, the Office of the Ohio Consumers’ Counsel, and the NRDC regarding an Application of FirstEnergy to count certain transmission and distribution projects toward their 2010 EE&C benchmarks.

Joint Reply Comments filed May 2, 2011 in PUCO Case 11-776-AU-ORD by Citizen Power, the Office of the Ohio Consumers’ Counsel, Advocates for Basic Legal Equality, and the Ohio Poverty Law Center concerning the Commissions’ review of the Chapters of the Ohio Administrative Code relating to the Rules of Practice and Procedure, Commission Meetings, Complaint Proceedings, and Utility Tariffs and Underground Protection.

Joint Comments filed April 1, 2011 in PUCO Case 11-776-AU-ORD by Citizen Power, the Office of the Ohio Consumers’ Counsel, Advocates for Basic Legal Equality, and the Ohio Poverty Law Center concerning the Commissions’ review of the Chapters of the Ohio Administrative Code relating to the Rules of Practice and Procedure, Commission Meetings, Complaint Proceedings, and Utility Tariffs and Underground Protection.

Joint Comments filed February 11, 2011 in PUCO Case 10-3126-EL-UNC concerning alternative distribution financing methods that remove the “throughput incentive”. Specifically, since current distribution financing is based on a per kwh structure, distribution utilities have an incentive to increase sales/usage instead of promoting conservation. Alternative financing structures can eliminate this incentive.

Citizen Power Exceptions to the Initial Decision of Administrative Law Judges Wayne L. Weismandel and Mary D. Long filed on January 10, 2011 in PA PUC Case A-2010-2176520 regarding the Joint Application of West Penn Power Company and FirstEnergy to allow a merger between the two companies.

Citizen Power Reply Comments filed January 6, 2011 in PA Case M-00051865 regarding the updating of the Technical Reference Manual.

Citizen Power Motion to  Intervene filed December 30, 2010 in PUCO Case 10-3023-EL-EEC concerning the application of FirstEnergy’s 2010 transmission and distribution projects toward their EE&C benchmarks.

Citizen Power Comments filed December 23, 2010 in PA PUC Case M-00051865 regarding the Technical Reference Manual’s use of the demand coincidence factor to determine the amount of demand savings from certain efficiency measures.

Citizen Power Reply Brief filed on November 15, 2010 in PA PUC Case A-2010-2176520 opposing the merger of West Penn Power and FirstEnergy.

Joint Reply Comments filed on November 15, 2010 in PUCO Case 09-512-GE-UNC by Citizen Power, the Office of the Ohio Consumers’ Counsel, Citizens’ Coalition, Sierra Club of Ohio, NRDC, and the Ohio Environmental Council regarding the Draft Technical Reference Manual for protocols for the measurement and verification of energy efficiency and peak demand reduction measures.

Joint Reply Comments filed on November 15, 2010 in PUCO Case 09-512-GE-UNC by Citizen Power, the Office of the Ohio Consumers’ Counsel, Citizens’ Coalition, Sierra Club of Ohio, NRDC, the Ohio Poverty Law Center, and the Ohio Environmental Council regarding the Draft Technical Reference Manual for protocols for the measurement and verification of energy efficiency and peak demand reduction measures.

Joint Reply Comments filed on November 9, 2010 in PUCO Case 09-1940-EL-REN by The Ohio Consumer and Environmental Advocates regarding the application of Ohio Revised Code 4928.65 to the FirstEnergy Solutions R.E. Burger Units 4 & 5.

Citizen Power Main Brief filed on November 3, 2010 in PA PUC Case A-2010-2176520 opposing the merger of West Penn Power and FirstEnergy.

Joint Stipulation filed November 3, 2010 in PUCO Case 10-1265-EL-UNC by Citizen Power, FirstEnergy, Ohio Partners for Affordable Energy, and the Staff of the Public Utilities Commission of Ohio stating that FirstEnergy’s 2009 returns on equity fell within the statutory “safe harbor” and were not significantly excessive.

Joint Reply filed November 1, 2010 in PUCO Case P-2010-2195426 by Citizen Power and the Pennsylvania Cement and Steel Manufacturers Coalition in response to the Answers of Duquesne Light, The Energy Association of Pennsylvania, UGI Utilities Inc, PPL Electric Utilities Corporation, West Penn Power Company d/b/a Allegheny Power, PECO Energy Company, Metropolitan Edison Company, Pennsylvania Electric Company, and Pennsylvania Power Company on the Pleadings concerning our petition’s request for a review of the potential over-collection of stranded costs and a corresponding refund of the over-collections to consumers.

Joint Answer filed November 1, 2010 in PUCO Case P-2010-2195426 by Citizen Power and the Pennsylvania Cement and Steel Manufacturers Coalition in response to PPL’s Motion on the Pleadings concerning our petition’s request for a review of the potential over-collection of stranded costs and a corresponding refund of the over-collections to consumers.

Joint Comments filed October 12, 2010 in PUCO Case 09-1940-EL-REN by The Ohio Consumer and Environmental Advocates concerning the unconstitutional and impractical application of Ohio Revised Code 4928.65 to the FirstEnergy Solutions R.E. Burger Units 4 & 5.

Joint Application for Rehearing filed September 24, 2010 in PUCO Case 10-388-EL-SSO by Citizen Power, the Office of the Ohio Consumers’ Counsel, and NRDC in response to the August 25, 2010 Order which approved a modified settlement for the provision of electricity in the FirstEnergy Ohio service territories.

Citizen Power Prehearing Memorandum filed September 23, 2010 in PA PUC Case R-2010-2179522 by Citizen Power in response to Proposed Supplement 35 to Duquesne Light Company’s Tariff Electric No. 24 which would significant impact residential distribution rates and could discourage energy conservation.

Petition to Intervene September 21, 2010 in PA PUC Case R-2010-2179522 by Citizen Power in response to Proposed Supplement 35 to Duquesne Light Company’s Tariff Electric No. 24 which would significantly impact residential distribution rates.

Joint Petition for a Declaratory Order filed August 24, 2010 in PA PUC Case P-2010-2195426 by Citizen Power and the Pennsylvania Cement and Steel Manufacturers Coalition requesting a review of the potential over-collection of stranded costs and a corresponding refund of the over-collections to consumers.

Joint Memorandum Contra Application for Rehearing filed August 9, 2010 in PUCO Case 09-786-EL-UNC by Citizen Power, the Office of the Ohio Consumers’ Counsel, the Ohio Energy Group, the Ohio Hospital Association, and the Ohio Manufacturers’ Association in opposition to the position of FirstEnergy that nothing in R.C. 4928.143 allows the Commission to test for excessive earnings by comparing them with prior rate plans.

Joint Memorandum Contra Application for Rehearing filed August 5, 2010 in PUCO Case 09-786-EL-UNC by Citizen Power, the Office of the Ohio Consumers’ Counsel, the Ohio Energy Group, the Ohio Hospital Association, and the Ohio Manufacturers’ Association in opposition to the position of Duke Energy that nothing in R.C. 4928.143 allows the Commission to test for excessive earnings by comparing them with prior rate plans.

Joint Application for Rehearing filed August 4, 2010 in PUCO Case 09-786-EL-UNC by Citizen Power, the Office of the Ohio Consumers’ Counsel, the Ohio Energy Group, the Ohio Hospital Association, and the Ohio Manufacturers’ Association concerning the PUCO’s Entry which granted a delay in the application of the significantly excessive earnings test as well as not including interest in any refunds due consumers.

Joint Application for Rehearing filed July 30, 2010 in PUCO Case 09-786-EL-UNC by Citizen Power, the Office of the Ohio Consumers’ Counsel, the Ohio Energy Group, the Ohio Hospital Association, and the Ohio Manufacturers’ Association concerning the PUCO’s Finding and Order which failed to properly address the treatment of off-system sales vis-à-vis the significantly excessive earnings test.

Joint Supplemental Brief filed July 1, 2010 in PUCO Case 10-388-EL-SSO by Citizen Power, the Office of the Ohio Consumers’ Counsel, Citizen’s Coalition, and NRDC in opposition to the Supplemental Stipulation in the FirstEnergy Standard Service Offer Case.

Joint Reply to FirstEnergy’s Memorandum Contra Motion to Dismiss filed June 21, 2010 in PUCO Case 09-951-EL-EEC by Citizen Power, the Office of the Ohio Consumers’ Counsel, NRDC, and the Ohio Environmental Council regarding FirstEnergy’s Application to count certain distribution and transmission projects toward their energy efficiency benchmarks.

Citizen Power Prehearing Memorandum filed June 15, 2010 in PA PUC Case A-2010-2176520 regarding the Petition of Allegheny Power and FirstEnergy for a Certificate of Public Convenience in order to merge the two companies.

Citizen Power Petition to Intervene filed June 14, 2010 by Citizen Power in PA PUC Case A-2010-2176520 regarding the Petition of Allegheny Power and FirstEnergy for a Certificate of Public Convenience in order to merge the two companies.

Citizen Power Comments filed May 29, 2010 in PA PUC Case L-2009-2095604 regarding the development of a statewide model for default electric service.

Joint Motion to Dismiss filed May 28, 2010 in PUCO Case 09-951-EL-EEC by Citizen Power, the Office of the Ohio Consumers’ Counsel, the NRDC, and the Ohio Environmental Council regarding FirstEnergy’s Application to count certain distribution and transmission projects toward their energy efficiency benchmarks.

Citizen Power Petition to Intervene filed May 17, 2010 in PUCO Case 10-499-EL-ACP by Citizen Power regarding FirstEnergy’s Alternative Energy Portfolio status report and 2009 annual compliance review.

Joint Brief filed April 30, 2010 in PUCO Case 10-388-EL-SSO by Citizen Power, the Office of the Ohio Consumers’ Counsel, Citizen’s Coalition, and NRDC arguing that the review process in FirstEnergy’s Standard Service Offer was improper and that settlement is not in the best interest of consumers as required by law.

Joint Application for Rehearing filed April 19, 2010 in PUCO Case 10-388-EL-SSO by Citizen Power, the Office of the Ohio Consumers’ Counsel, Citizens Coalition, Environmental Law & Policy Center, NRDC, Northeast Ohio Public Energy Council, Northwest Ohio Aggregation Coalition, and the Ohio Environmental Council in response to the April 6, 2010 Entry issued by the Public Utilities Commission of Ohio which provided that they would take administrative notice of the record in FirstEnergy’s pending market rate offer Case and granted certain Motion for Waivers filed by FirstEnergy.

Joint Reply Brief filed April 12, 2010 in PUCO Case 09-1947-EL-POR by Citizen Power, the Office of the Ohio Consumers’ Counsel, NRDC, and Citizens Coalition regarding deficiencies in FirstEnergy’s Energy Efficiency and Peak Demand Reduction Program Portfolio.

Joint Response filed April 1, 2010 in PECO Case 09-786-EL-UNC by the Office of Ohio Consumers’ Counsel, the Ohio Manufacturers’ Association, the Ohio Hospital Association, the Ohio Energy Group, and Citizen Power regarding questions posed by the Commission about the development of a significantly excessive earnings test.

Citizen Power Petition to Intervene filed March 30, 2010 in PUCO Case 09-1820-EL-ATA concerning FirstEnergy’s Smart Grid Modernization Initiative.

Joint Interlocutory Appeal filed March 29, 2010 in PUCO Case 10-388-EL-SSO by Citizen Power, the Office of the Ohio Consumers’ Counsel, Citizens Coalition, NRDC, and the Ohio Environmental Council requesting that the Public Utility Commission modify the Attorney Examiner’s Entry which allowed for a unreasonably short procedural schedule in the FirstEnergy Electric Security Plan Case.

Joint Post-Hearing Brief filed March 29, 2010 in PUCO Case 09-1947-EL-POR by Citizen Power, the Office of the Ohio Consumers’ Counsel, NRDC, and Citizens Coalition regarding deficiencies in FirstEnergy’s Energy Efficiency and Peak Demand Reduction Program Portfolio.

Joint Memorandum Contra FirstEnergy’s Motion filed March 26, 2010 in PUCO Case 10-388-EL-SSO by Citizen Power, Office of the Ohio Consumers’ Counsel, Citizen’s Coalition, NRDC, Northwest Ohio Aggregation Coalition, Northeast Ohio Public Energy Council and the Ohio Environmental Council.

Citizen Power Exceptions to the Initial Decision of ALJ Meehan filed February 17, 2010 regarding the allocation of costs stemming from Duquesne Light’s Smart Meter Technology Procurement and Installation Plan.

Citizen Power Reply Comments filed January 20, 2010 in PUCO Case 09-1920-EL-ATA concerning FirstEnergy’s Smart Grid Modernization Initiative.

Joint Reply Brief filed January 15, 2010 in PUCO Case 09-906-EL-SSO by Citizen Power, the Office of the Ohio Consumers’ Counsel, the Citizens Coalition, and the NRDC regarding FirstEnergy’s proposal to hold an auction to supply default electric service.

Joint Reply Comments filed on January 11, 2010 by the Office of Ohio Consumers’ Counsel, the Ohio Manufacturers’ Association, the Ohio Hospital Association, the Ohio Energy Group, and Citizen Power regarding the development of a significantly excessive earnings test for utilities pursuant to Senate Bill 221.

Joint Post-Hearing Brief filed January 8, 2010 in PUCO Case 09-906-EL-SSO by Citizen Power, the Office of the Ohio Consumers’ Counsel, the Citizens Coalition, and the NRDC regarding FirstEnergy’s proposal to hold an auction to supply default electric service.

Citizen Power Reply Brief filed December 22, 2009 in PA PUC Case M-2009-2123948 regarding the allocation of costs stemming from Duquesne Light’s Smart Meter Technology Procurement and Installation Plan.

Joint Response filed December 22, 2009 in PUCO Case 09-580-EL-EEC regarding FirstEnergy’s filing of a revised compact florescent light bulb program.

Citizen Power Main Brief filed December 8, 2009 in PA PUC Case M-2009-2123948 regarding the allocation of costs stemming from Duquesne Light’s Smart Meter Technology Procurement and Installation Plan.

Citizen Power Petition to Intervene filed December 4, 2009 in PUCO Case 09-951-EL-EEC regarding an application by FirstEnergy to count transmission and distribution projects toward their energy efficiency benchmarks.

Citizen Power Motion to Intervene filed November 27, 2009 in PUCO Case 09-906-EL-SSO concerning FirstEnergy’s Application for a Market Rate Offer to conduct a competitive bidding process for standard service offer electric generation supply.

Joint Memorandum Contra filed November 23, 2009 in PUCO Case 08-888-EL-ORD by the Ohio Consumer and Environmental Advocates opposing Applications for Rehearing filed by FirstEnergy, Duke, and the Industrial Energy Users pertaining to the new green energy rules in Ohio.

Joint Application for Rehearing filed November 13, 2009 in PUCO Case 08-888-EL-ORD by the Ohio Consumer and Environmental Advocates regarding issues with proposed modifications to the Ohio Administrative Code.

Joint Comments filed November 10, 2009 in PUCO Case 09-512-GE-UNC by the Ohio Consumer and Environmental Advocates regarding the approach used for all Ohio electric utilities to computer energy efficiency cost-effectiveness.

Citizen Power Reply to FirstEnergy’s Motion Contra to its Petition to Intervene filed November 9, 2009 in PUCO Case 09-580-EL-EEC regarding FirstEnergy’s Energy Efficiency and Peak Demand Reduction Program Portfolio.

Citizen Power Petition to Intervene filed November 6, 2009 in PA PUC Case P-2009-2135500 in response to a Petition by Duquesne Light to increase default supply rates.

Citizen Power Petition to Intervene filed October 23, 2009 in PUCO Case 09-580-EL-EEC regarding FirstEnergy’s Energy Efficiency and Peak Demand Reduction Program Portfolio.

Citizen Power Petition to Intervene filed October 22, 2009 in PUCO Case 09-714-EL-UNC concerning the development of a draft energy efficiency and peak demand reduction portfolio template for use by Ohio’s electric utilities.

Citizen Power Comments filed September 25, 2009 in PUCO Case 09-778-EL-UNC opposing the proposal of FirstEnergy to move from the territory of MISO to PJM.

Joint Comments filed September 11, 2009 in PUCO Case 09-714-EL-UNC by the Ohio Consumer and Environmental Advocates concerning the energy efficiency and peak demand reduction portfolio template.

Joint Comments filed July 24, 2009 in PUCO Case 09-512-GE-UNC by the Ohio Consumer and Environmental Advocates regarding the implementation of SB 221 and the associated protocols for the measurement and verification of energy efficiency and peak demand reduction measures.

Citizen Power Comments filed May 26, 2009 in PUCO Case 09-0090-EL-COI regarding the possibility of Ohio ending their relationship with established Regional Transmission Organizations.

Citizen Power Comments filed April 15, 2009 in PA PUC Case M-2009-2092655 regarding the establishment of minimum smart meter capability standards.

Supplemental Stipulation filed February 26, 2009 in PUCO Case 08-935-EL-SSO adding and modifying terms of the February 19, 2009 Stipulation in order to improve the consumer provisions included in FirstEnergy’s Electric Security Plan.

Joint Memorandum Contra filed February 5, 2009 in PUCO Case 09-21-EL-ATA by Citizen Power, Office of the Ohio Consumers’ Counsel, Ohio Partners for Affordable Energy, Northwest Ohio Aggregation Coalition, The Neighborhood Environmental Coalition, The Empowerment Center of Greater Cleveland, United Clevelanders Against Poverty, Cleveland Housing Network, and The Consumers for Fair Utility Rates in response to FirstEnergy’s Application for Rehearing in response to FirstEnergy’s Application for Rehearing seeking a greater increase in electric rates for their customers.

Joint Application for Rehearing filed February 2, 2009 in PUCO Case 08-935-EL-SSO by the Ohio Consumer and Environmental Advocates stating that the Interim Rate Order was unjust, unreasonable, and unlawful.

Joint Memorandum Contra Application for Rehearing filed January 13, 2009 in PUCO Case 08-935-EL-SSO by The Ohio Consumer and Environmental Advocates arguing that the Commission should reject FirstEnergy’s claims that new rates are permissible.

Joint Memorandum Contra to the Motion filed January 13, 2009 in PUCO Case 08-935-EL-SSO by The Ohio Consumer and Environmental Advocates advocating that the Commission reject FirstEnergy’s desire to stay the date which they would have to file their tariff.

Joint Motion to Dismiss filed January 13, 2009 in PUCO Case 09-21-EL-ATA by Citizen Power, Office of the Ohio Consumers’ Counsel, Northeast Ohio Public Energy Council, and Northwest Ohio Aggregation Coalition in opposition to an Application by FirstEnergy to implement a FUEL rider, which would increase electric rates for low-income consumers.

Citizen Power Petition to Intervene filed January 12, 2009 in PUCO Case 09-21-EL-ATA regarding an Application by FirstEnergy to implement a FUEL rider, which would increase electric rates for low-income consumers.

Joint Comments filed January 5, 2009 in PUCO Case 08-935-EL-SSO by the Ohio Consumer and Environmental Advocates advocating that the Commission reject FirstEnergy’s tariff filing.

Joint Reply Brief filed December 12, 2008 in PUCO Case 08-935-EL-SSO by Citizen Power and Ohio Partners for Affordable Energy highlighting the of FirstEnergy’s Electric Security Plan.

Joint Application for Rehearing  filed December 5, 2008 in PUCO Case 06-653-EL-ORD by The Ohio Consumer and Environmental Advocates regarding the adoption of rules for electric utilities; electric service and safety standards; competitive electric service; uniform electric interconnection service; electric reliability, safety and consumer service; certification to operate as a competitive retail electric service; and market monitoring.

Joint Brief filed November 21, 2008 in PUCO Case 08-935-EL-SSO by Citizen Power and Ohio Partners for Affordable Energy outlining the deficiencies of FirstEnergy’s Electric Security Plan.

Joint Brief filed October 31, 2008 in PUCO Case 08-935-EL-SSO by The Ohio Consumer and Environmental Advocates regarding an Application by FirstEnergy for a short-term Electric Security Plan.

Joint Application for Rehearing filed October 17, 2008 in PUCO Case 08-777-EL-ORD by The Ohio Consumer and Environmental Advocates regarding the adoption of rules for standard service offer, corporate separation, reasonable arrangements, and transmission riders for electric utilities pursuant to Sections 4928.14, 4928.17, and 4905.31, Revised Code, as amended by Amended Substitute Senate Bill No. 221.

Joint Reply Comments filed August 29, 2008 in PUCO Case 06-653-EL-ORD by The Ohio Consumer and Environmental Advocates regarding the adoption of rules for electric utilities; electric service and safety standards; competitive electric service; uniform electric interconnection service; electric reliability, safety and consumer service; certification to operate as a competitive retail electric service; and market monitoring.

Joint Comments filed August 12, 2008 in PUCO Case 06-653-EL-ORD by The Ohio Consumer and Environmental Advocates regarding the adoption of rules for electric utilities; electric service and safety standards; competitive electric service; uniform electric interconnection service; electric reliability, safety and consumer service; certification to operate as a competitive retail electric service; and market monitoring.

Joint Comments filed July 22, 2008 in PUCO Case 08-777-EL-ORD by The Ohio Consumer and Environmental Advocates regarding the adoption of rules for standard service offer, corporate separation, reasonable arrangements, and transmission riders for electric utilities pursuant to Sections 4928.14, 4928.17, and 4905.31, Revised Code, as amended by Amended Substitute Senate Bill No. 221.

Reply Comments filed February 9, 2005 in PA PUC Case M-00051865 by Citizen Power concerning the implementation of Pennsylvania’s Alternative Energy Portfolio Standards Act.

Comments filed January 14, 2005 in PA PUC Case M-00051865 by Citizen Power concerning the implementation of Pennsylvania’s Alternative Energy Portfolio Standards Act.

Initial 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.

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

Citizen Power 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.

Brief of Petitioners in DC Circuit 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 FEGPU Initial 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.

Rehearing 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.

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

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

Citizen Power 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.

Jurisdiction Rehearing Request 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.

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.

Citizen Power Reply 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.

Initial Brief-CP and OEC 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.

Comments on The DQE-FE Generation Exchange 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.

Jurisdiction 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.

DQE Auction 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.

Comments on DQE Auction 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.

DQE-APS Merger 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.

Duquesne Light Restructuring 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).