Agency/Administration Advocacy

Legal Filings

As directed by our membership, NARUC frequently submits comments and pleadings to Federal courts on relevant issues. Below is an archive of NARUC legal filings before the Federal Courts, the Federal Energy Regulatory Commission, the Federal Communications Commission, and others.

October 12, 2021
NARUC Comments to FERC on the Advance Notice of Proposed Rulemaking on Electric Transmission (RM21-17)
March 29, 2021
NARUC Written Ex Parte with all FCC Commissioners re Auction 904 Long Form Scrutiny
January 25, 2021
NARUC Initial Comments on FCC Emergency Broadband Benefit Program
January 22, 2021
NARUC Wisconsin Amicus re bias charges
December 3, 2019
AD16-16 RM19-15 - NARUC PURPA Comments
September 10, 2018
NARUC Initial Comments in Response to the FCC's Proposed Extension of the Freeze of Jurisdictional Separations
August 27, 2018
NARUC Initial Comments in Response to FCC's Proposed Extension of the Freeze of Jurisdictional Separations
August 27, 2018
NARUC's Reply Comments to the FCC Regarding the National Verifier
August 10, 2018
NARUC Initial Comments on the Emergency Petition of Q Link Wireless for the National Verifier
June 22
NARUC Notice of Ex Parte Communication in the Matter of Nationwide Number Portability
May 29, 2018
NARUC Notice of Ex Parte Communication In the Matter of Lifeline
May 21, 2018
NARUC Notice of Ex Parte Communication In the Matter of Lifeline
May 16, 2018
NARUC's Request for an Extension of the Comment Deadline for the USTelecom Petition for Forbearance
April 20, 2018
Joint NARUC/NEI/NWSC Letter to DOE Secretary Rick Perry Re: Nuclear Waste Fund Status Transparency
April 6, 2018
NARUC Letter to FCC Chairman Pai Regarding the Composition of the BDAC
March 24, 2018
NARUC's Reply Comments Regarding the FCC's Lifeline NPRM
March 19, 2018
NARUC’s Request for Rehearing/Clarification of FERC’s Energy Storage Order (Order No. 841; Docket No. RM16-23-000)
February 21, 2018
NARUC's Initial Comments in Response to the FCC's Notice of Proposed Rulemaking on Lifeline
February 15, 2018
Nomination Letter for Indiana Utility Regulatory Commissioner Sarah Freeman as the “State Representative” on the USAC Board
February 1, 2018
NARUC, NEI, and NWSC Letter to DOE Secretary Perry and OMD Director Mulvaney to Express Opposition to Reinstatement of the Uranium Decommissioning and Decontamination Tax
December 18, 2017
NARUC Pushes for PURPA Reform in Letter to FERC
October 23, 2017
NARUC comments to FERC on DOE Grid Resiliency Pricing Rule NOPR (RM18-1)
November 17, 2017
NARUC comments to USTR on Import Injury with Regard to Certain Crystalline Silicon Photovoltaic Cells (USTR-2017-0020)
October 23, 2017
NARUC comments to FERC on DOE Grid Resiliency Pricing Rule NOPR (RM18-1)
August 31, 2017
Joint Brief: State Response to Petition for Rehearing En Banc Inmate Calling Rates
August 21, 2017
Letter to FCC Commissioner Ajit Pai on BDAC Composition
July 26, 2017
Letter to the U.S. Secretary of Energy in Support of Continued Funding for the Department of Energy's National Laboratories
May 1, 2017
NARUC NEI NWSC Letter to the Administration Regarding the Uranium Enrichment Decontamination and Decommissioning Fund
March 8, 2017
NARUC Initial Comments on Mobilitie Petition: ERRATA
February 13, 2017
NARUC Comments to FERC on Storage and DER Aggregators (RM16-23/AD16-20)
January 30, 2017
NARUC vs. FCC in the Lifeline Order
January 30, 2017
NARUC Initial Lifeline Brief
January 19, 2017
Letter to the Transition Team on the NARUC role in Presidential Transition
January 19, 2017
NARUC Letter to the Trump Transition Team on Energy Issues
January 19, 2017
NARUC Letter to the Trump Transition Team on Telecommunications Issues
January 17, 2017
NARUC et al. Response to Order to Show Cause to Stay Pending Litigation to Preserve Judicial Economy and the Efficient Resolution of Cases
November 30, 2016
NARUC Protest at FERC Against Challenge to VT PURPA Rules (EL17-16)
November 23, 2016
NARUC Ex Parte to FCC on Lifeline Waivers
November 7, 2016
NARUC Comments to FERC on PURPA (AD16-16)
November 7, 2016
Implementation Issues Under the Public Utility Regulatory Policies Act of 1978 (AD 16-16-000)
October 31, 2016
15-4161 et al, Gobal Tel*Link, et al, vs. FCC (Appeal of the FCC’s preemptive Inmate Calling Order) Reply Brief of State and Local Petitioners
October 11, 2016
NARUC Opposition To FCC Motion to Hold the Case In Abeyance
October 7, 2016
NARUC Intervention to Oppose Request to Preempt MD PSC Community Solar Net Metering
September 16, 2016
NARUC Notice of Written Ex Parte from the State Members of the FCC’s Federal State Joint Conference on Advanced Services on State Broadband Policy with Survey Attached
September 2, 2016
NARUC et al Petition for Stay of Inmate Calling Reconsideration Order
September 1, 2016
NARUC Letter Request for Withdrawal of the Current Rule Defining Waters of the United States (WOTUS) or for Both the EPA and the U.S. Army Corps of Engineers to Propose a Supplemental Rule
August 29, 2016
Joint Reply Comments of the Western Coal Traffic League, American Public Power Association, Edison Electric Institute, National Association of Regulatory Utility Commissioners, National Rural Electric Cooperative Association, and Freight Rail Customer Alliance
August 29, 2016
Joint NARUC- Coal Shipper Reply Comments in STB EP733 Expediting Railroad Rate Cases
August 26, 2016
NARUC Amicus Brief in Support of California PUC’s Use of Broadband Data
August 4, 2016
NARUC Comments to CFTC Regarding RTO-ISO Order Proposed Amendment
July 29, 2016
State/NARUC Opposition to FCC Motion to Hold Inmate Calling Appeal in Abeyance
July 7, 2016
NARUC Comment Letter in the Pipeline and Hazardous Materials Safety Administration’s Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines rulemaking (PHMSA-2011-0023)
June 28, 2016
Joint Reply Comments of the Western Coal Traffic League, American Public Power Association, National Association of Regulatory Utility Commissioners, National Rural Electric Cooperative Association, and Freight Rail Customer Alliance to the Supplemental Notice of Proposed Rulemaking
June 9, 2016
NARUC Reply Brief, Petitions for Review of an Order of the Federal Communications Commission (FCC)
June 6, 2016
State and Local Government Petitioners Petition for Review of Final Agency Action of the FCC
June 3, 2016
NARUC Petition for Review of Lifeline
May 31, 2016
Joint Comments of NARUC et al to the supplemental Notice of Proposed Rulemaking
May 19, 2016
NARUC Letter to FERC Regarding Panelists for Competitive Transmission Technical Conference
April 14, 2016
NARUC Extension Request Letter to Comment on PHMSA Docket No. PHMSA-2011-0023, Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines
April 4, 2016
Petitioner Brief Combined with Statutory Addendum for VoIP Access to Numbers
March 17, 2016
Letter to the FCC in the Matter of Lifeline and Link Up Reform and Modernization
February 12, 2016
NARUC-NWSC-NEI letter to DOE on NWF reporting
January 8, 2016
NARUC Petition for Review v FCC case no. 15-1497
December 30, 2015
Joint Comments in United States Rail Service Issues – Performance Data Reporting.
December 15, 2015
NARUC Amicus Brief in Hughes v. PPL EnergyPlus and CPV Maryland v. PPL EnergyPlus (Nos. 14-614, 14-623) re: capacity contract for differences
November 3, 2015
NARUC-NWSC-NEI letter to DOE
October 28, 2015
NARUC Comments in the Matter of Technology Transitions WC Docket 05-25
October 15, 2015
Joint Brief for Intervenors Cogent Communications, Comptel, Dish Network Corporation, Free Press, Netflix, Open Technology Institute New America, Public Knowlege et al in support of the FCC
September 21, 2015
Brief of Intervenor Supporting Petitioners consolidated case nos. 15-3291 and 15-3555 in the Sixth Circuit Court of Appeals.
The State of Tennessee and the State of North Carolina v the FCC
September 21, 2015
Joint NARUC (et al) INTERVENOR BRIEF SUPPORTING THE FCC IN THE NET NEUTRALITY APPEAL
September 17, 2015
NARUC and California PUC joint Amicus in Federal Circuit case 15-5082 PG&E et al v. United States
August 31, 2015
Comments before the FCC on Lifeline and Link Up Reform and Modernization and Telecommunications Carriers Eligible for Universal Service Support and the Connect America Fund
August 11, 2015
Lifeline Awareness Week letter from President Edgar
June 11, 2015
NARUC EX PARTE on direct access to numbers
June 10, 2015
Comments of the State members of the Federal-State Joint Conference on Advanced Services and NARUC on the April 29, 2015 Broadband Opportunity Council Notice and Request for Comment
June 1, 2015
NARUC Reply Comments on NAPM LNP Transition Plan
April 29, 2015
REPLY JOINT COMMENTS OF THE WESTERN COAL TRAFFIC LEAGUE, AMERICAN PUBLIC POWER ASSOCIATION, NATIONAL ASSOCIATION OF REGULATORY UTILITY COMMISSIONERS, NATIONAL RURAL ELECTRIC COOPERATIVE ASSOCIATION, AND EDISON ELECTRIC INSTITUTE
April 7, 2015
NARUC Petitioners Reply Brief to Opposition Briefs Supreme Court No. 14-901
March 31, 2015
NARUC Nomination of New Jersey Board of Public Utilities Upendra J. Chivukula as NARUC's representative to the FCC's Communications Security, Reliability, and Interoperability Council.
March 18, 2015
NARUC Notice of Written Ex Parte Communication filed in the Matter(s) of Telephone Number Portability, et al. CC Docket No. 95-116; WC Docket No. 07-149; WC Docket No. 09-109
NARUC believes the agency, in its oversight role, should require an adequate time frame for a proper transition. Moreover, the FCC should, before finalizing any transition plan, seek input from interested stake-holders, including NARUC’s member public service ommissions, which regularly interact with the current administrator, on any draft transition plan’s components.
March 12, 2015
Letter in support of the EPA's "Fix-a-Leak-Week", March 16-22, 2015
March 10, 2015
NARUC Comments to the FCC on Transition
March 4, 2015
Joint Comments of the Western Coal Traffic League, American Public Power Association, National Association of Regulatory Utility Commissioners, and National Rural Electric Cooperative Association
February 13, 2015
Notice of Ex Parte Municipal Broadband
January 26, 2015
Petition for Certiorari to the United States Court of Appeals for the Tenth Circuit
January 15, 2015
Nomination of Commissioner Scott Rupp to NANC
January 9, 2015
NARUC Inmate Calling FNPRM Comments
December 2, 2014
Letter to Chairman Wheeler regarding Utilities Access to Spectrum to Promote Public Safety
November 25, 2014
Letter to EPA Administrator Gina McCarthy RE: Regulation of Carbon from Existing Power Plants; EPA Clean Carbon Plan; HQ-OAR-2013-0602
October 6, 2014
Support for EPA's “Shower Better Month,” October 2014
June 30, 2014
Commission Support for Educating Consumers on Portable Generator Carbon Monoxide Safety
April 18, 2014
Letter re: the Uranium Enrichment Decontamination and Decommissioning Fund.
April 9, 2014
Letter to the Surface Transportation Board re STB Docket No. EP 724. United States Rail Service Issues. Signed with APPA EEI and NRECA
March 14, 2014
EPA “Fix-a-Leak Week" Letter 2014
March 12, 2013
Letter to all State Commissioners
Urging all of NARUC members to endorse the U.S. Environmental Protection Agency's WaterSense initiative

For legal filings prior to 2013, please visit the NARUC Resource Library.