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.