IN THE
`UNITED STATES COURT OF APPEALS
`FOR THE DISTRICT OF COLUMBIA CIRCUIT
`
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`=
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`6 BR
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`AMERICAN PUBLIC POWER
`ASSOCIATION AND AMERICAN
`MUNICIPAL POWER,INC.,
`Petitioners,
`
`Vv.
`
`FEDERAL ENERGY REGULATORY
`COMMISSION,
`
`Respondent.
`
`PETITION FOR REVIEW
`
`Pursuant to section 313(b) of the Federal Power Act, 16
`
`U.S.C. § 8251(b), Rule 15(a) of the Federal Rules of Appellate
`
`Procedure, and Circuit Rule 15, the American Public Power
`
`Association and American Municipal Power, Inc. hereby jointly
`
`petition for review of the following orders issued by the Federal
`
`Energy Regulatory Commission:
`
`Calpine Corp. v. PJM Interconnection, L.L.C., Docket Nos.
`1.
`EL16-49-000, ER18-1314-000, ER18-1314-001, and EL18-178-000,
`“Order Rejecting Proposed Tariff Revisions, Granting in Part and
`Denying in Part Complaint, and Instituting Proceeding Under
`
`
`UNITED STATES COURT OF APPEALS
`FOR THE DISTRICT OF COLUMBIA CIRCUIT
`
`)
`=
`)
`6 BR
`)
`re
`)
`oS
`)
`Ss4
`)
`w AL.
`“
`Lo
`)
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`a
`rey
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`) )
`
`AMERICAN PUBLIC POWER
`ASSOCIATION AND AMERICAN
`MUNICIPAL POWER,INC.,
`Petitioners,
`
`Vv.
`
`FEDERAL ENERGY REGULATORY
`COMMISSION,
`
`Respondent.
`
`PETITION FOR REVIEW
`
`Pursuant to section 313(b) of the Federal Power Act, 16
`
`U.S.C. § 8251(b), Rule 15(a) of the Federal Rules of Appellate
`
`Procedure, and Circuit Rule 15, the American Public Power
`
`Association and American Municipal Power, Inc. hereby jointly
`
`petition for review of the following orders issued by the Federal
`
`Energy Regulatory Commission:
`
`Calpine Corp. v. PJM Interconnection, L.L.C., Docket Nos.
`1.
`EL16-49-000, ER18-1314-000, ER18-1314-001, and EL18-178-000,
`“Order Rejecting Proposed Tariff Revisions, Granting in Part and
`Denying in Part Complaint, and Instituting Proceeding Under
`
`
`
`‘ea
`
`Section 206 of the Federal Power Act,” 163 FERC { 61,236 (June
`29, 2018);
`
`Calpine Corp., v. PJM Interconnection, L.L.C., Docket Nos.
`2.
`EL16-49-000 and EL18-178-000, “Order Establishing Just and
`Reasonable Rate,” 169 FERC { 61,239 (Dec. 19, 2019);
`
`Calpine Corp. v. PJM Interconnection, L.L.C., Docket Nos.
`3.
`EL16-49-001, EL18-178-001, and ER18-1314-002, “Order on
`Rehearing and Clarification,” 171 FERC { 61,034 (April 16, 2020);
`and
`
`Calpine Corp. v. PJM Interconnection, L.L.C., Docket Nos.
`4.
`EL16-49-002 and EL18-178-002, “Order on Rehearing and
`Clarification,” 171 FERC { 61,035 (April 16, 2020), errata issued
`April 16, 2020.
`
`Copies of these orders are attached to this petition as Attachments
`
`A through D, respectively.
`
`Respectfully submitted,
`
`/3/JohnE,McCaffrey
`
`Delia Patterson
`Senior Vice President, Advocacy &
`Communications and General Counsel
`John E. McCaffrey
`Senior Regulatory Counsel
`American Public Power Association
`2451 Crystal Drive, Suite 1000
`Arlington, VA 22202
`(202) 467-2900
`dpatterson@publicpower.org
`jmccaffrey@publicpower.org
`
`
`
`/s/ Gerit F. Hull
`Gerit F. Hull
`Deputy General Counsel for
`Regulatory Affairs
`American Municipal Power,Inc.
`1111 Schrock Road, Suite 100
`Columbus, Ohio 43229
`(614) 540-0852
`ghuli@amppartners.org
`
`DATED:April 20, 2020
`
`
`
`IN THE
`UNITED STATES COURT OF APPEALS
`FOR THE DISTRICT OF COLUMBIA CIRCUIT
`
`No.
`
`)
`)
`)
`
`) )
`
`) )
`
`)
`)
`)
`
`) )
`
`) )
`
`AMERICAN PUBLIC POWER
`ASSOCIATION AND AMERICAN
`MUNICIPAL POWER,INC.,
`
`Petitioners,
`
`Vv.
`
`FEDERAL ENERGY REGULATORY
`COMMISSION,
`
`Respondent.
`
`CORPORATE DISCLOSURE STATEMENT OF
`THE AMERICAN PUBLIC POWER ASSOCIATION
`
`Pursuant to Rule 26.1 of the Federal Rules of Appellate
`
`Procedure and Circuit Rule 26.1, the American Public Power
`
`Association (“APPA”) hereby submits this corporate disclosure
`
`statement.
`
`APPAhasno parentcorporation or publicly traded stock.
`
`APPAis the national trade association representing the interests
`
`of not-for-profit, state, municipal, and other locally owned electric
`
`utilities in the United States.
`
`
`
`Respectfully submitted,
`
`/s/ John E. McCaffrey
`John E. McCaffrey
`Senior Regulatory Counsel
`American Public Power Association
`2451 Crystal Drive
`Suite 1000
`Arlington, VA 22202
`(202) 467-2900
`jmccaffrey@publicpower.org
`
`DATED: April 20, 2020
`
`
`
`IN THE
`UNITED STATES COURT OF APPEALS
`FOR THE DISTRICT OF COLUMBIA CIRCUIT
`
`AMERICAN PUBLIC POWER
`ASSOCIATION AND AMERICAN
`MUNICIPAL POWER,INC.,
`
`Petitioners,
`
`Vv.
`
`FEDERAL ENERGY REGULATORY
`COMMISSION,
`
`Respondent.
`
`aetliliaiiililletlal
`
`°
`
`CORPORATE DISCLOSURE STATEMENT OF
`AMERICAN MUNICIPAL POWER,INC.
`
`Pursuant to Rule 26.1 of the Federal Rules of Appellate
`
`Procedure and Circuit Rule 26.1, American Municipal Power,Inc.
`
`(“AMP”) hereby submits this corporate disclosure statement.
`
`American Municipal Power, Inc.is a non-profit Ohio
`
`corporation organized in 1971. AMP has 135 members, including
`
`1384 member municipalelectric systems in the states of Ohio,
`
`Pennsylvania, Michigan, Virginia, Kentucky, West Virginia,
`
`Indiana, and Maryland, and the Delaware Municipal Electric
`
`
`
`Corporation, a joint action agency with nine membersthatis
`
`headquartered in Smyrna, Delaware. AMPprovides wholesale
`
`energy supply and related services to its members. AMPissues no
`
`stock, has no parent corporation, and is not owned in whole or in
`
`part by any publicly held corporation.
`
`Respectfully submitted,
`
`/s/ Gerit F. Hull
`Gerit F. Hull
`Deputy General Counsel for
`Regulatory Affairs
`American Municipal Power,Inc.
`1111 Schrock Road, Suite 100
`Columbus, Ohio 43229
`(614) 540-0852
`ghull@amppartners.org
`
`DATED:April 20, 2020
`
`
`
`IN THE
`UNITED STATES COURT OF APPEALS
`FOR THE DISTRICT OF COLUMBIA CIRCUIT
`
`AMERICAN PUBLIC POWER
`ASSOCIATION AND AMERICAN
`MUNICIPAL POWER,INC.,
`
`Petitioners,
`
`Vv.
`
`FEDERAL ENERGY REGULATORY
`COMMISSION,
`
`Respondent.
`
`
`
`emereeeeeeeNeeNe”eeeNieeetNee”Nee”“eee”ee”
`
`CERTIFICATE OF SERVICE
`
`Pursuant to Rule 15(c) of the Federal Rules of Appellate
`
`Procedure, I hereby certify that I have this 20th day of April,
`
`2020, served copies of the foregoing Petition for Review and
`
`Corporate Disclosure Statements upon the following as shown
`
`below:
`
`
`
`Party
`
`Method
`
`Ms. Kimberly D. Bose
`Secretary
`Federal Energy Regulatory
`Commission
`888 First Street, N.E.
`Washington, D.C. 20426
`
`Robert Solomon
`Solicitor
`Federal Energy Regulatory
`Commission
`888 First Street, N.E.
`Washington, D.C. 20426
`robert.solomon@ferc.gov
`
`First-class mail (w/o
`attachments); and
`FERC eFiling
`
`First-class mail (w/o
`attachments); and
`
`I herebyfurthercertify that I have served a copy of the
`
`foregoing documents by e-mail on all parties on the FERC service
`
`lists in the underlying proceedings in Docket Nos. EL16-49, ER18-
`
`1314, and EL18-178, as shown on the attached servicelists.
`
`/s/ John E. McCaffrey
`John E. McCaffrey
`Senior Regulatory Counsel
`American Public Power Association
`2451 Crystal Drive, Suite 1000
`Arlington, VA 22202
`(202) 467-2900
`jmecaffrey@publicpower.org
`
`
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