Request for Rehearing to Promote Transparency for Ohio Consumers
Read topic-matched comments in ER26-3515
Topics in the text: Registry access · Filing procedure · Cost allocation
What the document says
PDF p. 19
Ohio asks FERC to give state consumer advocates confidential registry access.
extend access to the Large Load Registry confidential information to state consumer advocate offices, subject to confidentiality obligations. PDF p. 19Filed comments: Registry access
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Source sections
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Opening text
opening text · Topic match: Filing procedure
ER26-3515-000 REQUEST FOR REHEARING TO PROMOTE TRANSPARENCY FOR OHIO CONSUMERS BY OFFICE OF THE OHIO CONSUMERS’ COUNSEL Maureen Willis Consumers’ Counsel Angela O/Brien Deputy Consumers’ Counsel Office of the Ohio Consumers’ Counsel 65 East State Street, Suite 700 Columbus, Ohio 43215 Telephone:…Read this passage Filed comments: Filing procedure
TABLE OF CONTENTS
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TABLE OF CONTENTS I.Read this passage Filed comments: Filing procedure
A. FERC’s failure to allow state consumer advocate offices access to the
printed heading · Topic match: Registry access
FERC’s failure to allow state consumer advocate offices access to the Large Load Registry confidential information fails the test for reasoned decision-making because FERC never addressed OCC’s concerns. .......................8Read this passage Filed comments: Registry access
B. FERC’s exclusion of state consumer advocate offices from the
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FERC’s exclusion of state consumer advocate offices from the confidential information in the Large Load Registry unduly discriminates against these statutorily mandated consumer representatives. ...............................13Read this passage Filed comments: Registry access
C. FERC’s ruling is an unlawful unexplained departure from its rulings in the
printed heading · Topic match: Cost allocation
ER26-3515-000 REQUEST FOR REHEARING TO PROMOTE TRANSPARENCY FOR OHIO CONSUMERS BY OFFICE OF THE OHIO CONSUMERS’ COUNSELRead this passage Filed comments: Cost allocation
I. INTRODUCTION
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I.Read this passage
INTRODUCTION
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Under Section 313 of the Federal Power Act (“FPA”), 16 U.S.C. § 825l, and Rule 713 of the FERC’s Rules of Practice and Procedure, 18 C.F.R. § 385.713, the Office of the Ohio Consumers’ Counsel (“OCC”) requests rehearing of the October 9 Order.Read this passage Filed comments: Registry access
II. BACKGROUND
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II.Read this passage
BACKGROUND
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The October 9 Order accepts PJM’s Large Load Registry proposal, including the definition of Large Loads and the provision that excludes state consumer advocate offices from access to the confidential information collected and maintained in the Registry.18 The October 9 Order rejected all other…Read this passage Filed comments: Registry access
III. SPECIFICATIONS OF ERRORS ON REHEARING
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FERC erred by acting in an arbitrary and capricious manner in approving PJM’s Large Load Registry proposal without ensuring that state consumer advocate offices have access to the confidential information that will be collected and maintained in that Registry.Read this passage Filed comments: Registry access
IV. ISSUES ON REHEARING
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Whether FERC’s ruling excluding state consumer advocate offices from the confidential information in the Large Load Registry unduly discriminates against state consumer advocate offices as compared to other entities entitled to access that information, contrary to the statutory requirements in…Read this passage Filed comments: Registry access
V. REQUEST FOR REHEARING
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REQUEST FOR REHEARINGRead this passage Filed comments: Filing procedure
A. FERC’s failure to allow state consumer advocate offices access to the Large
printed heading · Topic match: Registry access
The October 9 Order recounts PJM’s argument that the confidential information in the Registry must be available only to “‘as small a universe of entities as possible,’ while still making sure it is available to those who require access to implement their responsibilities, as well 20October 9 Order…Read this passage Filed comments: Registry access
B. FERC’s exclusion of state consumer advocate offices from the confidential
printed heading · Topic match: Registry access
FERC’s exclusion of state consumer advocate offices from the confidential information in the Large Load Registry unduly discriminates against these statutorily mandated consumer representatives.Read this passage Filed comments: Registry access
C. FERC’s ruling is an unlawful unexplained departure from its rulings in the
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The same is true of the state consumer advocate offices need to access the confidential information in the Large Load Registry.Read this passage Filed comments: Registry access
VI. CONCLUSION AND PRAYER FOR RELIEF
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CONCLUSION AND PRAYER FOR RELIEF WHEREFORE, OCC respectfully requests that FERC reconsider its ruling in the October 9 Order.Read this passage Filed comments: Registry access
CERTIFICATE OF SERVICE
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Dated in Washington, D.C., on this 9th day of November, 2026. /s/ Denise C.Read this passage