Kidder Hill Community Wind LLC (KHCW) has filed a motion to reconsider the order for incompleteness from the Vermont Public Utility Commission (PUC).
To summarize, the motion:
- Recounts the history and substance of the KHCW petition for a certificate of public good (CPG), and the PUC's order of incompleteness;
- Explains the basis and extent of the PUC's authority under current Vermont statutes;
- Details why and how the KHCW petition provided more than the minimum information necessary to be deemed complete under Vermont law and Public Utility Commission rules;
- Provides examples of past petitions that were approved and granted a CPG with less information provided than was provided by KHCW;
- Requests the PUC reconsider its order of incompleteness and proceed to consider or contest the KHCW petition for a certificate of public good.