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New Texas Nonprofit Co-op Seeking To Serve Retail Customers At Choice TDUs Asks PUC To Order That Neither CCN Nor REP Certificate Required

September 8, 2026

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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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Roshan Energy, which describes itself as a "Nonprofit Electric Cooperative", has filed a formal request at the Texas PUC for a declaratory order holding that Roshan, operating only as a Chapter 161 member-only cooperative, is not required to obtain a CCN or a REP certificate in order to serve its voluntary members, who would be located within the boundaries of TDU service areas which have retail electric customer choice

As first reported by EnergyChoiceMatters.com, Roshan had made similar filings with the Texas PUC about a year ago, with such filings dismissed as impermissible requests for an advisory opinion

As further discussed below, Roshan says that an application to serve as an ERCOT LSE has been denied due to the lack of CCN or other instrument from the PUCT, and thus the issue now presents a live controversy

As originally detailed last year, under Roshan Energy's sought model, which Roshan has described as "retail electric service," the Roshan Energy retail customers, who would join the co-op as members, would be located within and taking delivery service from the ERCOT TDUs who have choice programs

Roshan Energy has said that it is formed and organized as a nonprofit electric cooperative under Texas Utilities Code Chapter 161

A Chapter 161 cop-op may, "generate, acquire, and accumulate electric energy and transmit, distribute, sell, furnish, and dispose of that electric energy to its members only".

For a full discussion of the powers of a Chapter 161 nonprofit corporation, see our prior story here

Roshan represented that ERCOT has stated that ERCOT will not process Roshan’s LSE registration without proof of PUCT authorization or exemption covering the requested service areas.

Roshan represented that ERCOT has informed Roshan that Roshan’s remedy is to appeal Roshan’s LSE rejection to the PUCT or to obtain a PUCT determination confirming authority or exemption, after which Roshan would need to submit a new LSE application supported by that proof.

Roshan thus asked the PUC to determine whether Roshan Energy LLC, as a nonprofit electric cooperative organized under Texas Utilities Code Chapter 161 and operating strictly on a member-only basis, must obtain (a) a Certificate of Convenience and Necessity under PURA § 37.051, (b) a Retail Electric Provider certificate under PURA § 39.352 and 16 TAC § 25.107, or (c) other Commission authorization, before providing retail electric service exclusively to its voluntary members in areas of the ERCOT region that are already certificated to transmission and distribution utilities.

Roshan specifically requested that the Commission declare one of the following:

(a) that Roshan, operating only as a Chapter 161 member-only cooperative, is not required to obtain a CCN or a REP certificate in order to serve its voluntary members; or

(b) in the alternative, the precise certificate, registration, or other authorization the Commission requires, and the correct application process to obtain it.

Roshan said, "Roshan intends to operate strictly as a member-only cooperative. Only persons or entities that voluntarily apply and are accepted as members would be eligible to receive electric service. Roshan would not offer service to the general public and would not operate as a competitive Retail Electric Provider offering customer choice to non-members."

Roshan does not propose to own or operate transmission or distribution facilities. Retail delivery would use existing transmission and distribution utility systems in the ERCOT region

Roshan said that Roshan will operate without profit to private owners. "After reasonable operating costs and reserves, remaining surplus is intended for charitable purposes, including support of humanitarian work through the Aga Khan Development Network," Roshan said

Roshan said that its "authorized representative" has approximately seven years of experience in QSE operations, scheduling, and risk management. Roshan listed its Founder and Authorized Representative as Ramzan Ali

Roshan stated, "Petitioner is prepared to comply with whatever process the Commission identifies. If the Commission determines that a CCN, a REP certificate, or another form of authorization is required, Petitioner requests that the order state the correct filing and the applicable rule."

Docket 60216

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