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ALJ Issues Order Finding Additional CNN/REP Application Information Required Saying “Letter Filing Is Ambiguous and Unclear In Many Respects”
From the TexasLicense ALJ Order:
“On October 14, 2025, Roshan Energy, Nonprofit Electric Cooperative, filed a letter indicating it was applying for a certificate of convenience and necessity to provide retail electric service. The letter also requests that a control number be assigned.”
“The filing by Roshan Energy is ambiguous and unclear in many respects, and the Administrative Law Judge (ALJ) finds that the applicant must make an additional filing to clarify the relief it is seeking. For example, it is unclear whether the letter purports simply to seek a control number for a future application, whether it is a request for an option 1 retail electric provider certificate under PURA1 § 39.352 and 16 Texas Administrative Code (TAC) § 25.107, or whether it is a request for some other type of relief. To the extent it is intended to be a formal application, the applicant is directed to use a Commission-prescribed form for the specific type of relief being sought.
“Accordingly, by October 31, 2025, Roshan Energy shall make a filing clarifying the relief being sought in this docket and, if an application is being presented, use a Commission-prescribed form for the application.
As background, on October 14, Ramzan Ali filed a letter application with the Texas PUC stating:
“Roshan Energy, Inc., a Texas nonprofit corporation in formation as a 501(c)(12) electric cooperative under Texas Utilities Code Chapter 161, hereby applies for an initial Certificate of Convenience and Necessity (CCN) to provide retail electric service to the Ismaili communities in the Dallas and Houston metropolitan areas”.
“Founded by Ramzan Ali, Sadru Sarfani, and Faizan Sarfani, Roshan Energy is governed by a 7- member Board of Directors. Our intent is to deliver affordable, community-owned prepaid electricity at 13¢/kWh, with all profits donated to the Aga Khan Foundation (AKF) to support community development initiatives. We are supported by $200,000 in founder funding and will provide a $5,000-$10,000 surety bond as financial assurance. As a Chapter 161 cooperative, we are exempt from the $750,000 Letter of Credit requirement per §161.121. This application initiates our request for a CCN, with detailed exhibits (organizational documents, service area map, financial assurance, technical capability, customer protection plan, and funding proof) to be submitted via amendment following docket assignment. We seek expeditious processing given our nonprofit, community-focused mission and request assignment of a Control Number for tracking.”
Order No. 1 – Requiring Filing By Applicant (10/16/2025)
Application Letter (10/14/2025)
58844
(Application Of Roshan Energy, Nonprofit Electric Cooperative For A Retail Electric Provider Certificate)

