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Noble Americas Energy Solutions Seeks Corrected PUC Order, Affirmation NAES Was Always In Compliance

November 24,2015



Noble Americas Energy Solutions LLC on November 23 requested that the Pennsylvania PUC correct an error in a November 19 tentative order which had inaccurately listed Noble Americas as failing to provide proof of security when the PUC, had, in fact, confirmed with Noble Americas that such proof of security had been provided by the company as required and prior to the issuance of such tentative order.

Noble Americas Energy Solutions wrote, "Noble Solutions received two Security Renewal Notice Letters from the Commission's Bureau of Technical Utility Services (TUS) stating our Financial Assurance was expiring Nov 1, 2015. On October 28, 2015 Noble Solutions timely sent, via Fed Ex Overnight, our renewed bond."

Noble Americas Energy Solutions attached to its November 23 pleading seeking the correction, "a copy of the FedEx receipt that was signed by N. Chikotas as well as a copy of the email with the electronic copy (PDF) of the bond sent to Stephen Jakab of the PAPUC staff."

"As evidenced by the supporting documentation, Noble Solutions provided the required financial security well before the requested November 9, 2015 deadline," Noble Americas Energy Solutions wrote.

"On November 18, 2015, Noble Solutions became aware of two issues regarding our financial security and EGS license. First, PAPUC staff contacted Bryan White at Noble Solutions at 6:30 am PST/9:30 EST advising that our EGS license was going to be canceled because of a lack of a bond. Second, we were advised that, for some unknown reason, Noble Solutions had two separate utility codes -- viz. # A-110141 which is the original docket that all EGS licensing activity had been issued and # A-2011-2237924 which was the docket number assigned when Noble Solutions filed to have its license expanded to include incidental residential accounts. PAPUC staff later confirmed to us that the second entry appeared to be an internal filing error," Noble Americas Energy Solutions wrote.

"Noble Solutions was subsequently notified by email on the morning of November 19th that it was erroneously listed as one of the EGSs failing to submit the required financial security on the PAPUC's Tentative Order at Docket No. M-2015-2490383, which was to be considered at the Commission's public meeting that day. While assuring Noble Solutions that its EGS license was in no danger of being cancelled, PAPUC staff advised that it was too late to remove Noble Solutions from the supplier table in the Tentative Order. Following public meeting, the PAPUC entered its Tentative Order which identified Noble Solutions as failing to have provided the required financial security and tentatively ordering that its EGS license be cancelled," Noble Americas Energy Solutions wrote.

"Since Noble Solutions timely furnished evidence of the appropriate financial security, Noble Solutions respectfully requests that the PAPUC take expedited action to rectify the foregoing issues in a manner that removes Noble Solutions from the supplier table in the Tentative Order and makes clear that Noble Solutions was always in compliance with its financial security obligations. Expedited action is necessary so as to minimize the potential harm to Noble Solutions and the confusion these issues have already caused with our customers, business relationships, and potential consumers in the Pennsylvania and national retail electric markets," Noble Americas Energy Solutions wrote.

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