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Texas PUC Staff Recommend Approval Of EE REP 2, LLC Amendment Application, After Change In Persons Relied On To Meet Experience Rule

December 5, 2025

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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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Staff of the Texas PUC have recommended that the Commission approve an amendment to the retail electric provider certificate of EE REP 2, LLC f/k/a MI Texas REP 2, LLC.

The amendment was sought by EE REP 2, LLC to reflect, among other things, a change in ownership and control, including changes to the individuals on which the REP will rely to satisfy technical and managerial qualifications. As first reported by EnergyChoiceMatters.com, as of September 1, 2025, MI Texas REP 2, LLC experienced a change in ownership and control. The new owner and direct parent company of MI Texas REP 2, LLC is Elevate Energy, LLC (which holds Texas REP Certificate No. 10353 and which is part of Energywell).

As previously reported (details here), PUCT Staff previously requested that EE REP 2’s application to amend its REP certificate be denied because Staff alleged that, "the application relies on persons prohibited from exercising control [of a REP] under 16 TAC § 25.107(g)(1)(A) to meet the requirements of subsections (d) and (e) [of the certification rules]."

Subsections (d) and (e) address, among other things, technical and managerial requirements for REP certification, including a requirement that a REP have one or more principals or employees in managerial positions whose combined experience in the competitive electric industry or competitive gas industry equals or exceeds 15 years.

16 TAC § 25.107(g)(1)(A)(i-iii) provides that, "[i]n no instance may any of the following persons control the REP or be relied upon to meet the requirements of subsections (d) and (e) of this section: (A) A person who was a principal of a market participant, at any time within the six months prior to the market participant: (i) experiencing a mass transition of the REP’s customers under §25.43 of this title; (ii) having their ERCOT SFA, or similar agreement for an independent organization other than ERCOT terminated; or (iii) exiting an electricity or gas market with outstanding payment obligations that, at the time of the application or amendment, remain outstanding."

Specifically, Staff had alleged that both Tom McGinn and Marilee Stewart, who were listed by EE REP 2, LLC to meet the prior energy market experience rule, were "principals" for Griddy Energy LLC, which had its REP certificate revoked by the Commission in Docket No. 51859 on August 4, 2022, following a mass transition of Griddy's customers under 16 TAC § 25.43(l).

See more details on Staff's earlier recommendation here

However, EE REP 2, LLC said that neither Tom McGinn nor Marilee Stewart were a principal of Griddy based on how the term principal is defined in the PUC's REP certification rules. EE REP 2, LLC alleged that Staff offered no evidence to the contrary

See full details on EE REP 2, LLC's response here

While contesting Staff's interpretation of Tom McGinn's and Marilee Stewart's roles at Griddy, EE REP 2, LLC also updated its application in order to meet the required prior competitive energy market experience rule with different individuals, removing McGinn and Stewart from such section of the application

On the basis of the new individuals that EE REP 2, LLC lists as meeting the prior experience standard (Matt Terry and Liz Maberry), Staff now recommends that EE REP 2, LLC's amendment application be approved

Notably, Staff's recommendation in favor of approval is based on EE REP 2, LLC now using different individuals to meet the prior energy market experience requirement in the rule

Staff's recommendation notably does not address EE REP 2, LLC's arguments that neither Tom McGinn nor Marilee Stewart met the definition of "principal" as it relates to each's role at Griddy

Docket 58646

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