Pleadings – IEU Ohio

Midwest ISO Facility, Carmel, Indiana

Coalition of MISO Transmission CustomersRTO Related Activities

This portion of the IEU-Ohio website contains information regarding efforts to create robust Regional Transmission Organizations (“RTO”) to facilitate effective competitive markets.

This page contains links to reference documents of interest. Some documents may be password protected. If so, the password is identified in the hyperlink information.

Reply Comments of American Manufacturers and Large Institutional Customers in DOE NOPR on Grid Reliability/Resilience Pricing, Docket No. RM18-1-000 (filed 11/7/17)
CMTC Motion in Support of Motion for Leave to Answer and Answer of Wisconsin TDUs in FERC Docket No. ER17-892 (filed 3/24/17)
CMTC/IIEC Motion for Leave to Answer and Answer in FERC Docket No. ER1-284 (filed 1/27/17)
Protest of Industrial Customers in FERC Docket No. ER17-284 (filed 12/14/16)
CMTC/IIEC Motion for Supporting Information or Finding that Filing is Deficient in FERC Case No. ER17-284 (filed 11/14/16)
Answer to Motion to Extend Date for Providing Refunds and for Expedited Action in FERC Case No. EL14-12 (filed 10/27/16)
CMTC’s Answer to Motions to Dismiss (PRA Complaint) (filed 10/13/16)
Complainant-Aligned Parties’ (includes CMC) Brief on Exceptions (filed 8/9/16)
Industrial Customers’ (includes CMTC) Protest regarding MISO’s June 28 Compliance Filing (filed 7/19/16)
MISO Compliance Filing regarding Planning Resource Auction (PRA) Complaints (filed 6/28/16)
Reply Brief of Complainant-Aligned Parties (includes CMTC) (filed 4/18/16)
Industrial Customers’ Comments on Offer Cap NOPR (filed 4/4/16)
Initial Brief of Complainant-Aligned Parties (includes CMTC) (filed 3/24/16)
Joint Complainants’ (includes CMTC) Brief Opposing Exceptions (filed 3/10/16)
CMTC Motion to Intervene – DC Circuit Appeal (filed 2/18/16)
Gorman Rebuttal Testimony (and exhibits) on behalf of Industrial Consumer Groups (includes CMTC) in Joint Complaint re: MISO TO’s Return on Equity (filed 1/27/16)
Summary of MISO/SPP Settlement filed at FERC (filed 10/13/15)
CMTC and Joint Complainants’ Reply Brief re: MISO TO’s Return on Equity (filed 10/13/15)
Joint Complainants’ Initial Brief re: MISO TO’s Return on Equity (filed 9/21/15)
Gorman Testimony (and exhibits) on behalf of Industrial Consumer Groups (includes CMTC) in Joint Complaint re: MISO TO’s Return on Equity (filed 9/2/15)
Respondents’ (EPSA, National Rural Electric Cooperative Association, EEI, PJM Power Providers Group, APPA, et al.) Brief in Order 745 Appeal at U.S. Supreme Court (filed 8/31/15)
Respondents’ (Midwest Load-Serving Entities) Brief re: Order 745 Appeal at U.S. Supreme Court (filed 8/31/15)
Joint Complainant’s Prehearing Brief re: MISO TO’s Return on Equity (filed 8/10/15)
Joint Statement of Contested Issues, Stipulated Issues, Index of Exhibits and Witness List in Joint Complaint re: MISO TO’s Return on Equity (filed 7/31/15)
Petitioners (includes CMTC and PJMICC) Brief in Order 745 Appeal at U.S. Supreme Court (filed 7/9/15)
PJM’s Brief Supporting Petitioners in Order 745 Appeal at U.S. Supreme Court (filed 7/9/15)
CMTC’s Answer to MISO’s Answer in the SSR Cost Allocation Docket (filed 7/10/15)
Joint Comments (CMTC and IIEC) in Complaints re: MISO’s Zone 4 2015-2016 Planning Resource Auction (filed 7/2/15)
CMTC’s Protest in Opposition to MISO’s Proposal to Implement Rate Schedule 43A (SSR Cost Allocation Filing) (filed 6/10/15)
CMTC’s Request for Rehearing re: FERC Order on Adder (filed 2/4/15)
Joint Consumers’ Protest re: Adder (includes CMTC) (filed 11/28/14)
Industrial Customers’ Answer (includes CMTC) (filed 9/9/14)
Midwest TDU’s Answer to Suppliers’ Motion for Expedited Action re: MISO’s Capacity Market (filed 9/9/14)
Request for Rehearing re: System Support Resources (filed 8/21/14)
Petition for Rehearing En Banc, U.S. Court of Appeals for the District of Columbia Circuit, No. 11-1486 (filed 7/7/14)
CMTC’s Answer in Support of Motion to Stay Effectiveness of Service Agreement (filed 5/13/14)
Joint Complainant’s Answer to MISO TO’s Motion to Dismiss Complaint (complaint regarding MISO TO’s return on equity, capital structure and ROE adders) – filed 1/22/14
Joint Complainant’s Answer in Support of MISO’s Motion to Dismiss (motion to be dismissed as a party in complaint against MISO TO’s re: return on equity, capital structure and ROE adders)
CMTC’s Reply Comments (in response to Initial Briefs filed by the NRC Companies, MISO’s IMM & the Capacity Suppliers) related to MISO’s Proposed Resource Adequacy Construct (filed 11/25/13)
Joint Complaint regarding Return on Equity, Capital Structure and Return on Equity Adders (filed at FERC 11/12/13)
CMTC’s Initial Brief regarding MOPR Rehearing Requests (filed at FERC 10/11/13)
Industrial Customer’s Motion for Leave to Answer & Answer in Response to Electric Power Supply Association’s Comments & Protests in Ameren Energy Resources Complaint (filed 8/28/13)
Industrial Customers’ Protest regarding Ameren Energy Resources Complaint against MISO related to costs recovered through an SSR Agreement (filed at FERC 8/1/13)
Industrial Customers’ Protest regarding MISO’s filing for approval of an SSR agreement with Ameren Energy Marketing & allocation of costs associated with Edwards (filed at FERC 7/31/13)
Industrial Customers’ Protest regarding MISO’s Compliance Filing at FERC regarding a proposed system support resource agreement and rate schedule for Harbor Beach (filed at FERC 7/18/13)
Industrial Customers’ Protest regarding MISO’s Application for Approval of a System Support Resources (SSR) Agreement with city of Escanaba (filed at FERC 7/5/13)
Industrial Customers’ Answer in Opposition to MISO’s Answer re: MISO’s System Support Resources (SSR) Agreement between MISO and DTE Electric (filed at FERC 5/22/13)
CMTC/Industrial Customers Protest of MISO’s Request for Approval of a System Support Resources Agreement with DTE Electric Co. (filed at FERC 4/23/13)
Joint Brief of Intervenors Supporting Respondent in Appeal of Order 745 (filed at U.S. Court of Appeals on 9/11/12)
Illinois Commerce Commission, et al. (includes CMTC) Petition for Review of FERC’s MVP Order (filed at U.S Court of Appeals, 7th Circuit 8/8/12)
CMTC’s Protest of MISO’s compliance filing regarding the methodology for assigning capacity obligations (filed at FERC 8/1/12)
CMTC’s Request for Clarification or, Alternatively, Request for Rehearing re: FERC’s June 11 Order on MISO’s Resource Adequacy Proposal (filed at FERC 7/11/12)
Protest of Demand Response Supporters (includes CMTC) re: MISO Order 719 and 745 compliance filings (filed at FERC 4/13/12)
CMTC Protest regarding proposed revisions in MISO’s tariff concerning cost allocation of network upgrades related to the integration of Entergy into MISO (filed at FERC 12/19/11)
Notice of Appeal of FERC Orders (conditionally accepting MISO tariff revisioins and conditionally accepting compliance filing) – documents below filed 12/14/11)
Petition for Review
Motion to Consolidate
Service List
CMTC (and others/DemandResponse Supporters) Answer re: demand response resources, cost allocation & M&V protocols (filed at FERC 10/26/11)
CMTC (and others/Demand Response Supporters) Protest re: MISO’s Compliance Filing to Implement FERC’s Full LMP Compensation Approach (filed 9/23/11)
CMTC, IIEC and Wisconsin Industrial Energy Group Protest concerning MISO’s proposed tariff changes regarding Resource Adequacy Requirements (filed at FERC 9/15/11)
Joint (CMTC, IEU-Ohio, ELCON, AFPA, etc.) Request for Clarification and Rehearing of FERC Order 1000 (filed at FERC 8/22/11)
CMTC Protest re: MISO’s Request for Waiver (filed at FERC 6/24/11)
Industrial Customers’ Answer to Midwest Transmission Owners Request to File Unauthorized Pleading (filed at FERC 2/22/11)
Industrial Customers’ Request for Rehearing of FERC’s December 16 Order (filed at FERC 1/18/11)
CMTC/EnerNOC’s Comments Supporting MISO’s December 8 Compliance Filing re: LMR Deliverability (filed at FERC 12/29/10)
CMTC’s Answer to MISO, Midwest Transmission Owners, American Wind Energy Association and Wind on the Wires re: multi-value projects and cost allocation (filed at FERC 11/8/10)
Joint Comments regarding Demand Response Compensation (filed at FERC 10/13/10)
Joint Comments regarding transmission planning and cost allocation (filed at FERC 9/29/10)
CMTC Remarks Regarding Issues Raised by FERC in its Supplemental NOPR on the Benefits of Demand Response (filed at FERC 9/13/10)
CMTC/Industrial Customers’ Protest regarding the establishment of transmission projects designated as Multi-Value Projects (MVPs) and Network Updates (filed at FERC 9/10/10)
MISO Transmission Cost Allocation Filing (filed at FERC 7/15/10) (NOTE: this is a large file – 5 MB/500+ pages)
CMTC/MTDU Request for Rehearing or Clarification of FERC’s June 2010 order re: locational capacity requirements (filed at FERC 7/8/10)
CMTC/PJMICC, et al. Comments re: Demand Response Compensation in Organized Wholesale Energy Markets (filed at FERC 5/13/10)
IEU-Ohio/CMTC, et al. Comments re: Demand Response Compensation in Organized Wholesale Energy Markets (filed at FERC 5/13/10)
CMTC/PJMICC Comments on RTO/ISO Performance Metrics (filed 3/5/09)
CMTC/IEU-Ohio’s Answer to the Motion for Leave to File Answer and Answer of PJM Interconnection regarding FirstEnergy’s integration plan to transition from MISO to PJM (filed 2/18/10)
CMTC/IEU-Ohio’s Request for Rehearing regarding the FirstEnergy Companies’ proposed integration plan related to energy efficiency improvements and peak demand reductions (filed 1/19/10)
CMTC’s Answer in response to MISO’s Motion in Opposition to Late Interventions in the docket related to revenue sufficiency guarantee charges and exemptions (filed 1/19/10)
CMTC’s Limited Answer in response to Dynegy Power Marketing’s Motion to Intervene & Comments related to load modifying resources deliverability issues (filed 11/25/09)
CMTC, EnerNOC and Wal-Mart Joint Motion for Leave to Answer and Limited Answer regarding comments filed related to guidelines established in Order Nos. 719 & 719-A
CMTC, EnerNOC and Wal-Mart Joint Protest regarding MISO’s compliance filing related to the participation of Aggregators of Retail Customers (ARCs) (filed 11/6/09)
CMTC and Illinois Protest to MISO’s Proposal to Increase the CONE (Cost of New Entry) (filed 8/21/09)
CMTC and Midwest Transmission Dependent Utilities Motion for Leave to Answer and Answer (filed 8/6/09)
CMTC and Midwest Transmission Dependent Utilities Motion for Leave to Answer and Answer (filed 7/23/09)
CMTC’s Limited Answer addressing Protests and Comments regarding deliverability of Load Modifying Resources in Voluntary Capacity Auction (filed 7/23/09)
CMTC Comments addressing MISO’s compliance filing regarding deliverability of Load Modifying Resources in Voluntary Capacity Auction (filed 7/8/9)
Joint Protest re: MISO’s Order 719 Compliance Filing (filed 5/26/09)
Customer Groups’ Protest re: MISO Schedule 30 proposed revisions (filed 5/5/09)
Midwest Industrials and TDU’s Answer in Opposition to Motions to Intervene Out-of-Time (filed 12/24/08)