Submission Description: (doc-less) Motion to Intervene of PSEG Companies, et.
`al. under EL20-10-000.
`
`Submission Date: 11/21/2019 8:50:42 AM
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`Filed Date: 11/21/2019 8:50:42 AM
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`Dockets
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`EL20-10-000 Complaint
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`Filing Party/Contacts:
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`Filing Party Signer (Representative)
`Other Contact (Principal)
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`PSEG Companies cara.lewis@pseg.com
`Robert.Gardinor@pseg.com
`PSEG Energy Resources & Trade LLC cara.lewis@pseg.com
`Robert.Gardinor@pseg.com
`PSEG Power LLC cara.lewis@pseg.com
`Robert.Gardinor@pseg.com
`Public Service Electric and Gas Company cara.lewis@pseg.com
`Robert.Gardinor@pseg.com
`
`Basis for Intervening:
`Basis for Intervening:
`Pursuant to Rule 214 of the Rules of Practice and Procedure of the Federal
`Energy Regulatory Commission ( Commission  or  FERC ), 18 C.F.R. §
`385.214 Public Service Electric and Gas Company ( PSE&G ), PSEG Power LLC
`( PSEG Power ) and PSEG Energy Resources & Trade LLC ( PSEG ER&T )
`(collectively, the  PSEG Companies ) jointly move for leave to intervene in
`this matter. In support of their filing, the PSEG Companies respectfully show as
`follows.
`THE PSEG COMPANIES
`The PSEG Companies are each wholly owned, direct and indirect subsidiaries of
`Public Service Enterprise Group Incorporated ( PSEG ). The principal and
`executive offices of PSEG are located at 80 Park Plaza, Newark, New Jersey
`07102. PSEG is a public utility holding company engaged in, among other things,
`the generation of electric energy, and the transmission, distribution and sale
`of electricity and natural gas through its subsidiaries. PSE&G is a public
`utility company organized under the laws of the State of New Jersey. PSE&G is
`presently engaged in, among other things, the transmission and distribution of
`electricity and the distribution of natural gas in New Jersey. PSE&G owns
`transmission facilities in PJM Interconnection, L.L.C. ( PJM ). PSEG Power
`is a wholesale energy supply company that integrates its generation asset
`operations with its wholesale energy, fuel supply, energy trading and marketing,
`and risk management functions through three principal subsidiaries: (i) PSEG
`Nuclear LLC ( PSEG Nuclear ), which owns and operates nuclear generating
`stations; (ii) PSEG Fossil LLC ( PSEG Fossil ), which develops, owns, and
`operates domestic fossil-fuel fired and other non-nuclear generating stations;
`and (iii) PSEG ER&T, which is described below. PSEG ER&T, an indirect subsidiary
`of PSEG, sells power and energy and certain ancillary services at market-based
`rates. PSEG ER&T markets the capacity and production of PSEG Nuclear s and
`PSEG Fossil s generating stations, manages the commodity price risks and
`market risks related to generation, and provides gas supply services. PSEG ER&T
`is engaged in extensive asset-based energy trading operations throughout the
`Northeast.
`MOTION TO INTERVENE
`PSE&G, as an owner of transmission in PJM, PSEG Power, as a direct and indirect
`owner of generation assets in PJM, and PSEG ER&T, as a participant in the PJM
`electricity markets and a transmission customer within the PJM footprint, each
`have a substantial interest in this proceeding. The PSEG Companies will be
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`specifically and directly impacted by the outcome of this proceeding. No other
`party can represent these interests. Good cause thus exists for this motion, and
`the PSEG Companies respectfully request that the Commission grant their motion
`to intervene.
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