379 Thornall Street 5th Floor Edison, NJ 08837
August 19, 2004
VIA HAND DELIVERY
Ms. Felicia Greer Executive Director Maryland Public Service Commission William Donald Schaefer Tower 6 St. Paul Street Baltimore, MD 21202-6806
Re: Reliant Energy Solutions East, LLC’s Electricity Supplier License – IR-525
Dear Ms. Greer:
On August 10, 2004, I received a letter from your office directing Reliant Energy S o l u t i o n s E a s t , L L C ( “ R E S E ” ) t o r e s p o n d t o t h e a l l e g a t i o n s i n a l e t t e r f i l e d w i t h t h e P u b l i c Service Commission (“Commission”) on July 29, 2004 by Public Citizen. Your letter
specifically directs RESE to file its response with the Commission on or before August 19, 2004, and to serve a copy of the response on Public Citizen. Accordingly, this letter constitutes Reliant’s response to the allegations in Public Citizen’s letter to the Commission. As noted below, a copy of this response is being served on Public Citizen today via U.S. mail.
Public Citizen’s letter includes two allegations that it claims form sufficient justification for the Commission to review whether RESE’s electricity supplier license should be revoked. First, Public Citizen claims that the indictment of an affiliate of RESE, Reliant Energy Services, Inc. (“RES”), coupled with RESE’s reliance on that affiliate as a source of power supply in Maryland, represents a significant material change that should prompt a Commission review of the RESE license. Second, Public Citizen alleges that RESE filed a “false license application” with the Commission by failing to disclose certain charges incurred pursuant to the California Independent System Operator’s tariff.
Reliant Energy Services, Inc. Indictment
RESE filed its electricity supplier license application with the Commission on March 6, 2003. The application was approved, and the license was granted, on May 21, 2003. In its application, Reliant disclosed the FERC investigation into the events that led to the indictment discussed below and the resulting settlement agreement with FERC. Since its initial filing, RESE has filed supplemental information with the Commission on an ongoing basis in compliance with the Commission’s requirement that electricity suppliers provide notice of material changes to previously filed information.