Supplemental Protest of Public Citizen, And Request For An Evidentiary Hearing

By Tyson Slocum

FERC filing

In its December 9, 2019 application for market-based rate authority, Goldman Sachs Renewable Power Marketing LLC makes two serious factual misrepresentations. First, Goldman Sachs Renewable Power Marketing LLC claims that The Goldman Sachs Group, Inc. is not an affiliate. Second, Goldman Sachs Renewable Power LLC claims that its unidentified “Board of Directors consists of three independent directors, who are independent of The Goldman Sachs Group, Inc.”1 Both statements are false.

Public Citizen has learned the identities of the three members of Goldman Sachs Renewable Power’s Board of Directors. These three individuals serve as corporate directors for an additional sixty shell companies, all affiliated with The Goldman Sachs Group, Inc. In addition, the three are affiliated with unusual Cayman Islands-based firms that provide directors-for-hire. The fact that The Goldman Sachs Group, Inc. employs these same three directors for at least 61 affiliated shell companies renders these individuals unable to claim independence from The Goldman Sachs Group, Inc. These disturbing revelations help explain why Goldman Sachs Renewable Power Marketing LLC was so eager to conceal from FERC the three names of its corporate directors.

Given the extent of the misleading statements in the December 9 application, the Commission must find the application deficient, and must order a full, evidentiary hearing in order to properly resolve the many disputed facts in the December 9 application.

The full filing is available here.