BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION

Transcription

1 BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION Appiication of NRG Energy Center Harrisburg LLC for a Certificate of Public Convenience Authorizing it to Abandon Steam Service on the Following Seven Segments of its Low Pressure Steam System In the City of Harrisburg, Dauphin County, Pennsylvania: (a) North Third Street between Forster and Reily Streets; (b) Green Street between North and Forster Streets; (c) Locust Street between North Second and Court Streets; (d) North Second Street between North and Herr Streets; (e) Forster Street between North Second and Bartine Streets; (f) Bartine Street between Briggs and Union Streets; and (g) Briggs Street between North Second and Green Streets Protest of: Matthew Simmons Docket No. A m o TO m Wi CO cz. m 35" CO CD CD cn Address: Phone: '/a Walnut St Apt. 3A Harrisburg PA (717) simmonsmitajearthlink.net If your Protest involves utility service provided to a difterent address than your mailing address, please list this information below. Name Street/P.O. Box 241 Briees St City Harrisburg If represented by private counsel: Attorney Name: Attorney I.D. Number: Office: Address: State PA Zip Phone:

2 STATE CLEARLY AND CONCISELY THE FACTS SHOWING YOUR INTEREST IN THIS APPLICATION TO ABANDON STEAM HEAT SERVICE AND YOUR REASONS OR GROUNDS FOR THE PROTEST: On May 13, 2011 I received an official notice from NRG,fromtheir attorneys, that steam service at 241 Briggs St. Harrisburg PA would be terminated as an abandonment application had been filed with the PUC. NRG is stating that it is too costly to repair the pipes servicing the properties on both Briggs and Green Streets since they no longer have a large customer base here. Additionally they argue that they are phasing out all residential customers so that they can increase their profitability. NRG has offered $2, towards the cost of converting the property to a boiler or alternative heating system.

3 DESCRIBE YOUR STANDING TO PROTEST THIS APPLICATION. HOW WILL YOU DIRECTLY BE HARMED IF NRG IS PERMITTED TO ABANDON SERVICE TO YOU? I believe that NRG can afford to provide more financial assistance toward the purchase of a new boiler in the above mentioned property. Specifically, that an amount of $5, should be offered as that amount would not prove to be a financial hardship for NRG. It is my opinion that in the ten (10) years since NRG first applied for abandonment in this area, that the economy was much stronger and the value of properties in the area were significantly higher. The ensuing recession and housing market crash has left our neighbors with houses worth less than they were ten (10) years ago. Subsequently, our borrowing power has been reduced and our ability to qualify for refinancing or equity loans has been diminished. Additionally, I believe that NRG should have notified us when they initially applied for abandonment ten (10) years ago so that we could have planned for termination. Finally, I believe that NRG, as they have argued, will see more long term profits since abandoning these lines will reduce both their steam loss and maintenance needs. The savings garnered by their action will certainly exceed the $2, they have offered in compensation. Verification: I Matthew Simmons, hereby state that the facts above set forth are true and correct (or are true and correct to the best of my knowledge, information and belief and that I expect to be able to prove the same at a hearing held in this matter. I understand that the statements herein are made subject to the penalties of 18 Pa. C.S (relating to unsworn falsification to authorities). Signature: /_ Date: 05/26/201 Please return the completed form to one of the addresses listed below: If using U.S. Postal Service: Secretary Pennsylvania Public Utility Commission P.O. Box 3265 Harrisburg, PA If using overnight delivery service: Secretary Pennsylvania Public Utility Commission 400 North Street Commonwealth Keystone Building, 2nd Floor Harrisburg, Pennsylvania 17120

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5 Please print in ink or type. PENNSYLVANIA PUBLIC UTILITY COMMISSION Foilnal Cuiii jlaiiil Turtn 1. CUSTOMER (COMPLAINANT) INFORMATION Your name, mailing address, county, telephone number, utility account number and service address: Name Matthew Simmons Street/P.O. Box 411 1/2 Walnut St. Apt #3A City Harrisburg State PA Zip County Dauphin Daytime Telephone Number Where We Can Contact You: (717 ) Address (optional): simmonsmit3>earthlink.net Utility Account Number (from your bill) If your complaint involves utility service provided to a different address than yo^r mailing address, please list this information below. Name Street/P.O. Box 241 Briggs St City Harrisburg State PA Zip run- nmimc ur u i i i v^umrmn i irtcorunucn i y. NRG Entiigy Center Harrisbuiu, LLC 3. TiTE OF UTILITY (check one) ELECTRIC S DDI 739 Rev. July 2007 GAS WATER TELEPHONE (local, long distance) SJ STEAM HEAT WASTE WATER -o m -<~" - ; cr m > MOTOR CARRIER ffi.o.- taxi, movina comoanv limousine^ CD CD i 5 o

6 4. COMPLAINT (check one) A. In general, what is your complaint? I want to oppose the company's proposed rate increase. There are incorrect charges on my bill. There is a reliability, safety or quality problem with my utility service. H I received a notice that my utility service is being terminated. 1 would like a payment agreement. Other (explain). B. State the facts of your complaint. Include any specific dates, times or places that may be important. If the complaint is about a bill, tell us about any charges that you believe are not correct. Use additional paper if you need more space. Provide copies of all relevant documents you believe will support your complaint On May 13, 2011 I received an official notice from NRG, from their attorneys, that steam service at 241 Briggs St. Hanisburg PA would be terminated as an abandonment application had been filed with the PUC (Docket No. A ). NRG is stating that it is too costly to repair the pipes servicing the properties on both Briggs and Green Streets since they no longer have a large customer base here. Additionally they argue that they are phasing out all residential customers so that they can increase their profitability. NRG has offered $2, towards the cost of converting the property to a boiler or alternative heating system g Rev. Jufy 2007

7 5. RELIEF How do you want your complaint to be resolved? Use additional paper if you need more space. I believe that NRG can afford to provide more financial assistance toward the purchase of a new boiler in the above mentioned property. Specifically, that an amount of $5, should be offered as that amount would not prove to be a financial hardship for NRG. It is my opinion that in the ten (10) years since NRG first applied for abandonment in this area, that the economy was much stronger and the value of properties in the area were significantly higher. The ensuing recession and housing market crash has left our neighbors with houses worth less than they were ten (10) years ago. Subsequently, our borrowing power has been reduced and our ability to qualify for refinancing or equity loans has been diminished. Additionally, I believe that NRG should have notified us when they initially applied for abandonment ten (10) years ago so that we could have planned for termination. Finally, I believe that NRG, as they have argued, will see more long term profits since abandoning these lines will reduce both their steam loss and maintenance needs. The savings garnered by their action wilf certainly exceed the $2, they have offered in compensation Rev. July 2007

8 6. PROTECTION FROM ABUSE Answer the following question if your complaint is against a natural gas distribution utility, an electric distribution utility or a water distribution utility AND your complaint is about a billing problem, a request to receive service, a security deposit request, termination of service or a request for a payment agreement. Has a court granted a "Protection from Abuse" order for your personal safety or welfare? YES NO 0 7. PRIOR UTILITY CONTACT Answer the following question only if you are a residential customer and your complaint is against an electric distribution utility, natural gas distribution utility or a water distribution utility. Have you spoken to a utility company representative about this complaint? YES (includes appeals of BCS determinations) 0 NO If you tried to, but could not speak to a utility company representative about your complaint, please explain why. 8. LEGAL REPRESENTATION (IF ANY) If you are represented by a lawyer in this matter you must provide your lawyer's name, address, telephone number, and address, if known. Lawyer's Name Street City State Zip Area Code/Phone Number Address (If Known) o Rev. July 2007

9 9. VERIFICATION AND SIGNATURE You must print or type your name below on the line provided for the verification paragraph, and you must sign and date (in ink) this form on the lines provided. Verification: I Matthew Simmons, hereby state that the facts above set forth are true and correct (or are true and correct to the best of my knowledge, information and belief) and that I expect to be able to prove the same at a hearing held in this matter. I understand that the statements herein are made subject to the penalties of 18 Pa. C.S (relating to unsworn falsification to authorities). (Signature) 05/26/2011 (Date) Titfe of authorized employee or officer 10. FILING Please return the completed form to one of the addresses listed below: If using U.S. Postal Service: Secretary Pennsylvania Public Utility Commission P.O. Box 3265 Harrisburg, PA If using overnight delivery service: Secretary Pennsylvania Public Utility Commission 400 North Street Commonwealth Keystone Building, 2 nd Floor Harrisburg, Pennsylvania Facsimiles and/or electronic filings of the complaint will not be accepted. If you have any questions about filling out this form, please contact the Secretary's Bureau at Keep a copy of your complaint for your records Rev. July 2007

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