September 23, 2025

Mr. Jeffrey Gaudiosi

Executive Secretary
Public Utilities Regulatory Authority
Ten Franklin Square
New Britain, CT 06051

Re: Post-Resignation Inquiry in an Effort to Preclude Future Litigation

Dear Executive Secretary Gaudiosi:

On behalf of Avangrid, Inc. (“Avangrid”) and its Connecticut public service

companies, The United Illuminating Company, Connecticut Natural Gas Corporation and
The Southern Connecticut Gas Company (together, the “Avangrid Companies”), this inquiry
is prompted by the announcement on Friday, September 19th that Chairperson Gillett has
resigned from the Public Utilities Regulatory Authority (“PURA”), with an effective date of
October 10, 2025. The Avangrid Companies have significant concerns regarding the
conduct of their open matters pending before PURA and hope to avoid future litigation by
raising their concerns here. Although we have filed this letter as “General
Correspondence,” we respectfully request, and intend, that PURA enter this letter in every
open docket at PURA involving the Avangrid Companies.

First and foremost, it is our position in all such open matters that Chairperson Gillett
must have no further involvement. Chairperson Gillett’s multiple public statements
evidencing bias and prejudgment of issues that she is required by law to adjudicate on an
impartial basis are well known and are already the subject of pending litigation. Beyond
those known statements, there is compelling evidence of her substantial participation in the
creation of a remarkably biased op-ed entitled “Don’t believe the utility company
propaganda,” and growing evidence of her open disrespect for this State’s public records
laws. 1 In recent days, a legislative impeachment inquiry was requested to address
Chairperson Gillett’s apparent misstatements under oath regarding a policy restricting her
co-commissioners’ access to staff resources. Now, despite resigning in the face of this
threatened impeachment proceeding, Chairperson Gillett claims she is resigning because
the personal and “emotional toll” of Avangrid’s allegations against her is more than “one
individual can reasonably endure.” We will not respond to that claim here other than to
say that, if there was any doubt as to whether Chairperson Gillett could fairly adjudicate
any of our matters, it is now extinguished.

1 On December 19, 2024, the Connecticut Mirror published an opinion piece entitled “Don’t believe the utility
company propaganda,” under the byline of Sen. Norm Needleman and Rep. Jonathan Steinberg, although the true
authorship of that piece is under examination in the New Britain Superior Court. See,
https://ctmirror.org/2024/12/19/dont-believe-the-utility-company-propaganda/.
Letter Regarding Post-Resignation Inquiry
September 23, 2025
Page 2

The Avangrid Companies have had recusal motions pending now for months in
multiple dockets seeking the Chairperson’s recusal for bias. 2 Our efforts to redress our
concerns before this agency on an administrative basis have been ignored and left
undecided. The simple fact is that Chairperson Gillett must not have anything further to
do with any matter pending before PURA related to the Avangrid Companies, from now
through her departure on October 10th. Doing otherwise will not only compound existing
legal challenges to PURA’s conduct but will result in new, unnecessary litigation.

We also have credible concerns about the conduct and bias of other high-ranking
PURA personnel. At present, we feel compelled to raise our concern about Attorney Scott
Muska, PURA’s General Counsel, to the extent he may seek to play any decisional role in
our matters. For example, Attorney Muska has responded to Freedom of Information
(“FOI”) requests pertaining to limitations placed on the other Commissioners to contact staff
by stating that no such documents exist. Consistent with that claim, Attorney Muska
averred under oath in a sworn affidavit that “[a]ll commissioners are free to schedule
meetings with staff to discuss dockets.” (Exhibit 1, herewith at para. 18). However, the
production of emails to the Hartford Courant late last week – items we were told did not
exist – make it clear that restrictions were in fact placed on the freedom of other
Commissioners to contact PURA staff.

Attorney Muska is also directly implicated in what increasingly appears to be a

concerted effort to mislead the parties, the court and the public about the authorship of the
disputed op-ed referenced above, as well as PURA’s serial violations of FOI obligations.
These concerning actions strongly suggest that any involvement by Attorney Muska in our
matters going forward will cause legal problems for the agency in the future. These
actions are part and parcel of the same bias concerns that we have about the outgoing
Chairperson. Attached are: (1) the Order of Judge Matthew J. Budzik, dated August 15,
2025, in Docket No. HHB-CV25-6092048S, raising concerns that PURA – and counsel for
PURA -- had not met its discovery obligations in that proceeding due to a failure to disclose
the deletion of responsive documents (Exhibit 2, herewith); and (2) the letter by
Representative Vincent J. Candelora to Speaker Matthew Ritter, requesting that Speaker
Ritter convene a Select Committee of Inquiry to determine whether Chair Gillett perjured
herself during her confirmation process before the Legislative and Executive Nominations
Committee and whether such conduct is sufficient grounds for impeachment (Exhibit 3,
herewith).

In light of these and other potential legal challenges, we feel compelled to make our
concerns clear regarding any further participation of Chairperson Gillett in the hopes of
avoiding further problems that should not continue to plague this agency. We respectfully
ask that PURA address the obvious concerns listed above and advise us how it intends to

2 See, e.g., Docket No. 24-12-01, Motion No. 108 dated 06/10/2025 (Yankee Gas Services Company d/b/a
Eversource Energy) - Motion for Recusal; Docket No. 24-10-04, Motion No. 103 dated 04/24/2025 (The United
Illuminating Company) - UI Motion to Recuse; Docket Nos. 21-05-15RE01, RE02 & RE03, Joint Motion dated 07/11/2025
(The Connecticut Light and Power Company d/b/a Eversource Energy and The United Illuminating Company) - Motion
for Recusal.
Letter Regarding Post-Resignation Inquiry
September 23, 2025
Page 3

operate going forward, including what steps the agency will be taking to ensure that PURA
staff who are unable to be objective about our matters are not hereafter involved in those
matters.

Very truly yours,

/s/ David T. Martin

David T. Martin, Esq.
Vice President and General Counsel
UIL Holdings Corporation
180 Marsh Hill Road
Orange, CT 06477
Phone: 475.331.5399
Fax: 203-499-2414
E-mail: [email protected]

cc: Service List in Docket No. 24-10-04

Service List in Docket Nos. 21-05-15RE01, RE02 & RE03

Office of the Governor

[email protected]

Public Utilities Regulatory Authority

[email protected]
[email protected]
[email protected]
[email protected]

Department of Energy & Environmental Protection

[email protected]
[email protected]
[email protected]
[email protected]

Office of Consumer Counsel

[email protected]
[email protected]

Office of the Attorney General

[email protected]
[email protected]
[email protected]
[email protected]
Exhibit 1
 Affidavit of Scott Muska

I, Scott Muska, state as follows:

1. I am a resident of the State of Connecticut. I am over the age of 18 and have personal

knowledge of all the facts stated herein, except for those matters stated upon

information and belief; as to those matters, I believe them to be true. If called as a

witness, I could and would testify competently to the matters set forth below.

2. I currently hold the title of General Counsel of the Public Utilities Regulatory

Authority (Authority or PURA).

3. On April 16, 2025, the superior court issued a memorandum of decision (Court

Memorandum), in which the Court ordered discovery to gather additional facts

outside the administrative record, including directing the Authority to produce

documents demonstrating its processes in general and the processes followed in the

underlying administrative proceeding in Docket No. 23-11-02 related to rate

amendment applications by Connecticut Natural Gas and Southern Connecticut Gas

(Companies).

4. The Authority has conducted several legal reviews of the practices and procedures

explained below and firmly believes they are consistent with Title 16, the UAPA, and

FOIA. If, after reviewing this fuller explanation, the Companies have specific

objections to the Authority's general practices, the Authority continues to be willing to

discuss, through a docketed proceeding, informal technical meetings or otherwise,

those objections and to clarify or modify its practices to address the Companies'

concerns.
 Process: Panel Designation

5. When a proceeding is initiated, either by petition or on the Authority’s own initiative,

a docket is opened in the Authority’s electronic docket management system by staff of

the Docket Control unit. The docket management system is based on Lotus Notes

software and is referred to as “Lotus.” Lotus is accessible by the public.

6. General Statutes § 16-2(c) states that “Any matter coming before the authority may

be assigned by the chairperson to a panel of three or more utility commissioners.”

Similarly, Conn. Agencies Regs. § 16-2-10 states “The chairperson may assign panels

of three commissioners to any matter coming before the Authority.”

7. To assign a panel, the chairperson enters the panel assignment electronically in Lotus

or directs an administrative assistant to enter in Lotus the panel chosen by the

chairperson. The panel assignment is then reflected in the Docket Review

Notification (DRN) Form available in Lotus. In the DRN form, the panel is identified

by the first initial of the commissioners’ last name.

8. A copy of the DRN for Docket No. 23-11-02 (the subject of this administrative

appeal) is attached as Exhibit 1. The panel is also reflected in the Docket Schedule,

attached as Exhibit 2. The panel assignment of GBC refers to Commissioners

Gillett, Betkoski (retired), and Caron.

9. The process of assigning a panel is summarized, in part, on pages 1-2 of Directive

1.6, attached as Exhibit 3.

10. Docket No. 23-11-02 was established in May 2023. At that time, the Public Utilities

Regulatory Authority consisted of three commissioners only (Gillett, Betkoski, and

Caron), and Chair Gillett assigned the three commissioners to the panel.

11. The process for the panel assignment in Docket No. 23-11-02 did not differ from the

process described above.

Process: Hearing Officer Designation

12. General Statutes § 16-2(c) permits the panel of commissioners to designate a single

commissioner or a hearing officer “to ascertain the facts and report thereon to the

panel.” In addition, General Statutes § 16-2c states that “One or more utility

commissioners may assign a hearing officer pursuant to section 16-2, and the

chairperson of the Public Utilities Regulatory Authority may assign such other staff as

are necessary to advise said chairperson.” Similarly, General Statutes § 16-8(a) states

that the “Authority may, in its discretion, delegate its powers, in specific cases, to one

or more of its directors or to a hearing officer to ascertain the facts and report thereon

to the authority.”

13. Prior to Chair Gillett’s tenure, the chairperson would designate an individual

commissioner to serve as the “Lead Commissioner” for each docket. The term “Lead

Commissioner” is not defined in statute or regulation; however, the designation

appears to have been consistent with the authority under Conn. Gen. Stat. §§ 16-2,

16-2c, and 16-8 to assign a single commissioner as a fact-finding hearing officer.

See, e.g., Decision, Dec. 20, 2000, Docket No. 99-09-03RE02, In Re Connecticut

Nat. Gas Corp. (finding “The Department has delegated its powers to ascertain facts

in this proceeding to a commissioner in accordance with Conn. Gen. Stat. § 16-8.

 Because OCC has requested reconsideration of the lead commissioner to this docket's

November 27, 2000 procedural ruling, the Department interprets OCC's request for

reconsideration in the context of Conn. Gen. Stat. § 4-178a.”) (emphasis added),

attached as Exhibit 4; Decision, Mar. 24, 1987, Docket No. 85-12-09, Joint Petition

of O’Brien Energy Systems and The Connecticut Light & Power Co., at p. *3.

(“Pursuant to § 16–2(c) and 16–8(a) of the General Statutes of Connecticut, the lead

Commissioner of the panel of Commissioners assigned to this matter was designated

to conduct the hearing.”), attached as Exhibit 5; Decision, Aug. 12, 2020, Docket No.

19-12-23 Application of New Cingular Wireless Pcs, LLC for Approval of A Constr.

Plan to Install Wireless Facilities (noting that “a site inspection was conducted by the

lead commissioner [Commissioner Caron] on May 11, 2020.”), attached as Exhibit 6.

14. The “Lead Commissioner” practice dates back several decades (see Exhibit 4), but

there is no record of any votes by the commissioners over those decades to designate

a “Lead Commissioner.” Instead, it appears to have been a designation made at the

discretion of the chairperson. To my knowledge, no votes were ever taken or

recorded, and no one objected to the use of a “Lead Commissioner” or the process for

designating a “Lead Commissioner.”

15. The “Lead Commissioner” would generally conduct the proceeding essentially as a

panel of one, with the remaining commissioners generally participating only at the

end of the proceeding in preparation for issuance of a final decision. For example,

the decision attached as Exhibit 6 describes a Lead Commissioner conducting a fact-

finding site visit by himself. More specifically, in a 2000 dissent, Commissioner

Arthur stated “[a]s lead commissioner for the entire evidence gathering portion of this
 proceeding, I was very frustrated by the lack of data supplied by the Applicants” and

“[a]s lead Commissioner of the case, I have sat through 17 days of hearing and

arguments, examined over 4000 pages of transcript, sifted through thousands of

pieces of evidence, and spent hundreds of hours consulting with staff. I am most

familiar with this case.” See Decision, Oct. 19, 2000, Docket No. 00-01-11, In Re

Consol. Edison, Inc., attached as Exhibit 7.

16. After being appointed in 2019, Chair Gillett reviewed, considered, and ultimately

discontinued the practice of designating a “Lead Commissioner” for all new dockets.

The Chair believed that having a single commissioner conduct the entire proceeding

was inconsistent with good regulatory practice as it reduced commissioner

engagement and deliberation. As such, Chair Gillett abolished the very practice for

which the Companies now complain (i.e., a single commissioner conducting a

proceeding unilaterally). Since this change, all commissioners on the panel are

expected to participate in the entirety of every docketed proceeding, including the

expectation to read the record, attend hearings, and confer and deliberate with each

other. For example, in the June 2021 email attached as Exhibit 8, the Chair states

“we are going to get away from the lead commissioner model moving forward and

will instead be using a more holistic approach to dockets where all commissioners

participate more directly in the deliberations for each decision.” (emphasis added).

17. This change is manifested in Directive 1.6. For example, page 5 of Directive 1.6

requires the lead staff “to determine weeks and/or dates that are most appropriate to

schedule key procedural events that correspond to the commissioners’ availability.”

The directive also requires all technical meeting and hearing agendas to be distributed
 to the commissioners’ administrative assistants. Exhibit 3, pp. 10, 13. Further, “[a]ll

work product associated with a docketed proceeding shall follow the SharePoint

Directive 1.5 and shall be accessible in real-time to commissioners and any member

of PURA decisional staff.” Id., p. 22.

18. Importantly, each commissioner directly and automatically receives all filings

submitted in a proceeding by any participant, as well as those issued at the direction

of the Authority, including motions, motion rulings, pre-filed testimony,

correspondence, and hearing notices. Further, to assist each commissioner in

remaining appraised of the status of each docket, the Authority conducts standing

monthly “sector” meetings to review each of the dockets by sector (e.g., natural gas,

grid modernization, water, etc.). See Directive 1.3 attached as Exhibit 9. At the

sector meeting, a staff member presents the current status of each docket and, among

other things, identifies upcoming docket events and pending motions. However, the

sector meeting is not the exclusive mechanism for commissioner engagement, and

Directive 1.3 states “nor are the sector meetings intended as a substitute for any

detailed strategic or scheduling discussions for individual dockets that may be needed

or requested by a commissioner regarding a docket.” Id., p. 2. All commissioners are

free to schedule meetings with staff to discuss dockets. See emails attached at

Exhibit 10. All commissioners are invited to and encouraged to participate in the

Sector meetings. For example, in a February 2024 email, attached as Exhibit 11,

Chair Gillett states “I am looking for ways to make sure that the commissioners are

fully apprised of decisional points, which will be highlighted at these [sector]

meetings.”
19. Although Chair Gillett ended the practice of assigning a “Lead Commissioner” (i.e., a

single commissioner serving as a hearing officer), under limited circumstances, the

Authority may assign a staff attorney as a hearing officer, most often for applications

to install small cell wireless telecommunications facilities on a utility pole. See

Directive 3.3 attached as Exhibit 12. When this type of application is received, the

chair will notify the panel by email of the intent to assign the legal advisor as the

hearing officer for the docket and obtain the panel’s consent. Attached as Exhibit 13

are several examples of these exchanges between the commissioners. The Notice of

Proceeding (NOP) issued for the docket identifies the hearing officer assignment. See

example NOP as Exhibit 14.

20. With respect to Docket No. 23-11-02, neither a “Lead Commissioner” nor a hearing

officer was designated. The hearing transcripts demonstrate that all three

commissioners (Commissioners Gillett, Betkoski, and Caron) attended and

participated in all or most of the 15 hearings and oral arguments. Further, the Final

Decision in the proceeding states that “A majority of the Commissioners heard the

matter and/or read the record of the proceeding; . . .” Decision, p. 3 fn. 3. This is

consistent with the Authority’s practices under Chair Gillett.

Process: Presiding Officer Designation

21. Conn. Agencies Regs. § 16-1-2(13) states that the "Presiding officer" is “the

commissioner or the hearing officer designated by the head of the Authority to preside

at a hearing.” This mirrors the language of General Statute § 4-166(13), which states
 that the “Presiding officer” is “the member of an agency or the hearing officer

designated by the head of the agency to preside at the hearing.”

22. The Authority construes the term “head of the Authority” in its regulations and “head

of the agency” in the UAPA to mean the Chair of PURA. Notably, under Conn.

Agencies Regs. § 16-2-10, “The chairperson serves as the chief executive of the

Authority for administrative purposes.” Similarly, General Statutes § 16-2(f)(2) states

“The chairperson . . . shall (A) coordinate the activities of the authority and prescribe

the duties of the staff assigned to the authority; . . .”

23. In addition, when PURA existed as a standalone department in the executive branch

named the Department of Public Utility Control (DPUC), the chairperson of the

DPUC was deemed by statute to be the “department head,” indicating that the

chairperson is the head of the agency. See Conn. Gen. Stat. § 4-5 (2010), attached as

Exhibit 15.

24. Subsequently, under Public Act 11-80, effective July 1, 2011, the Public Utilities

Control Authority (PUCA), at that time named the DPUC, was renamed the Public

Utilities Regulatory Authority (PURA) and merged with the Department of

Environmental Protection (DEP) to create the Department of Energy and

Environmental Protection (DEEP). Because PURA was no longer a separate

“department” in the executive branch, Section 3 of Public Act 11-80 amended

General Statutes § 4-5 to remove the reference to the PURA chair from the definition

of “department head.” However, the role of the PURA chair as head of the agency

has remained constant.

25. As discussed above, the Authority no longer designates a “Lead Commissioner” to

each docket and only occasionally designates a staff attorney as a hearing officer.

With three commissioners sitting for almost every hearing, the designation of a

presiding officer is administratively efficient. Holding a hearing typically involves a

tremendous amount of communication and coordination with administrative,

technical, and legal staff regarding notices, agendas, information technology,

audio/visual displays, security, exhibit preparation, scheduling court reporters, etc.

See Directive 1.6, pp. 8-14 attached as Exhibit 3. Requiring staff to coordinate with

all three commissioners on ministerial matters for each hearing would be

burdensome.

26. Importantly, consistent with the discontinuation of the “Lead Commissioner”

designation, the role of the presiding officer is generally ministerial. Because the full

panel of commissioners participates in the entirety of each proceeding, all notices,

correspondence, interrogatories, requests for documents, motion rulings, and other

issuances are issued on behalf of or at the direction of the panel as a whole and not by

the presiding officer individually. This approach differs significantly from the “Lead

Commissioner” or hearing officer model in which the Lead Commissioner or hearing

officer act individually as a fact-finding hearing officer up until the full panel voted

on a final decision.

27. The presiding officer designation is made by the Chair and, for Docket No. 23-11-02,

was identified in the public agendas for the hearings. See Exhibit 16. For additional

clarity, the presiding officer designation is now also identified in the Notice of

Proceeding. See, e.g. Exhibit 17 (stating “In accordance with General Statutes § 16-
 2(c), the Chairperson assigns this matter to a panel consisting of Commissioners

Arconti, Gillett, and Caron. The full panel shall hear the entire matter, and the

commissioners may confer or communicate on this matter pursuant to General

Statutes § 16-2(n). No hearing officer or commissioner(s) has been assigned to

ascertain the facts and report thereon to the panel. The Chairperson designates

Commissioner Arconti to serve as the presiding officer pursuant to General Statutes §

4-166(13) and the Authority’s rules of practice, Conn. Agencies Regs. §§ 16- 1-1 to

16-1-137.”).

Process: Motion Rulings

28. Parties and intervenors in docketed proceedings will frequently submit a variety of

motions to the Authority during the pendency of a matter. Motion types include

motions for extensions of time, for party/intervenor status, for protective order, for

approval of customer notices, and for procedural changes. Complex dockets, such as

Docket No. 23-11-02, generally experience a high volume of motions. Parties filed

approximately 120 motions up until the date of the final decision, and over a dozen

more motions have been filed since.

29. To understand the Authority’s current motion practice, it is helpful to understand how

the Authority ruled on motions under the “Lead Commissioner” model employed by

the Authority pre-2021. Previously, the Lead Commissioner would typically rule on

motions in proceedings and issue them under the Executive Secretary signature block

without a vote at a regular meeting. See examples attached as Exhibit 18. If a party

or intervenor was dissatisfied with a ruling by the Lead Commissioner, the party or
 intervenor could seek reconsideration, a review by the full panel under General

Statutes § 4-178a, or raise an objection during a hearing with the full panel. Notably,

a review sought under General Statutes § 4-178a does not require a vote of the panel.

Instead, the process simply permits a “majority of the members” the discretion to

“make an appropriate order, including the reconvening of the hearing.”

30. As explained in Paragraph 15, the Authority no longer assigns a Lead Commissioner

to “to ascertain the facts and report thereon to the panel.” Consequently, motions are

reviewed and deliberated, to the extent appropriate, by the full panel. The process by

which Authority staff process a motion is detailed in Directive 2.5, attached as

Exhibit 19.

31. The vast majority of motions are ministerial in nature, with motions for extensions of

time and motions for protective orders constituting the bulk of motions. For context,

PURA issued approximately 1,400 motion rulings in 2024, 1,100 motion rulings in

2023, and 1,000 motion rulings in 2022. See annual reports at

https://portal.ct.gov/pura/about/annual-report. Upon receipt of a draft motion ruling

from staff, the presiding officer, in consultation with a legal advisor and technical

staff, will review the motion and determine if the motion is non-ministerial and

warrants deliberation by the commissioners. In addition, the commissioners are in

frequent conversation on various issues, and the commissioners may affirmatively

raise a motion filing for discussion and confer on the disposition of a motion with the

presiding officer. Importantly, each commissioner is immediately electronically

notified of any docket filing, including motions and any objections, in the Lotus

system. Directive 2.5, which addresses motion rulings, states that “The Presiding
 Officer shall review the draft motion ruling, confer with commissioners and staff as

warranted, make any appropriate changes, mark ‘Done’ in the email table, and

forward the motion ruling FYRA email back to the Legal Advisor.” (emphasis added).

See Exhibit 19, p. 3.

32. If a motion is ministerial, the presiding officer will generally not confer with the

other commissioners; however, the Authority affords parties and intervenors 7 days to

object or respond to a motion. Consequently, each of the commissioners has the

opportunity to confer on all motions, including ministerial motions, as they deem

appropriate. Due to the volume of ministerial motions, it would be administratively

inefficient to confer on each motion, particularly since these motions are generally

unopposed and are granted the majority of the time.

33. If a motion is not simply ministerial and if the other commissioners have not yet

initiated a discussion on the disposition of the motion, the presiding officer will

confer with the commissioners in person or by email to determine the appropriate

disposition of the motion. Attached as Exhibits 20 are numerous examples of the full

panel of commissioners conferring electronically on motion rulings. The

commissioners also confer in person on various matters, including motion rulings.

These in-person deliberations are specifically referenced in the emails contained in

Exhibit 20 and occur on both an ad-hoc and regular basis. Based on the consensus of

the commissioners formed from the conferences and communications, the presiding

officer will then finalize the draft motion ruling and return it to the lead staff to be

issued per curiam under the Executive Secretary signature block.

34. This process is explicitly contemplated and permitted under General Statutes § 16-

2(n), which states that “Two or more utility commissioners serving on a panel . . .

may confer or communicate regarding the matter before such panel. Any such

conference or communication . . . shall not constitute a meeting as defined in section

1-200.” Because such conferences and communication between commissioners are

expressly excluded from the definition of “meetings” under General Statutes § 1-200,

the Authority does not consider these verbal and electronic communications to be

“votes” as the term is used in General Statutes § 1-225(a), which requires the meeting

minutes of any public meeting to reflect any votes of the commissioners. In 2018,

prior to the tenure of Chair Gillett, the Authority’s legal staff examined the

Authority’s practice of generally not voting on motion rulings and determined that

motion rulings did not require a vote of the commissioners at a public meeting. This

long-running practice continued with no objection by the Companies until this appeal.

35. On the rare occasion that one of the commissioners does not concur with the panel on

a motion ruling, that commissioner may have the ruling note that they do not join in

the ruling or may issue a written dissent. See Exhibit 21.

36. If a party or intervenor is unsatisfied with a motion ruling or believes there was an

error of law or fact, they may (and typically will) file a motion for reconsideration,

seek review by the full panel under General Statutes § 4-178a, or raise the objection

at a hearing of the panel of commissioners. Motions for reconsideration usually

include a more detailed factual or legal analysis for consideration by the panel.

Notably, since the Authority no longer uses Lead Commissioners and rarely assigns

hearing officers, a request for panel review under General Statutes § 4-178a of a Lead
 Commissioner or hearing officer ruling is no longer directly applicable; however, the

Authority will treat such motions as a motion to reconsider its prior ruling. Motions

for reconsideration are treated as non-ministerial and would be the subject of

discussion between the commissioners to ensure consensus.

37. The use of the Executive Secretary signature block to issue motion rulings has been

the general practice of the Authority for decades. Notably, the practice was used

when the Authority utilized Lead Commissioners who issued rulings unilaterally. See

Exhibit 18. Consequently, the Executive Secretary signature block does not conceal

or hide that the ruling was issued by a single commissioner. In fact, the opposite is

true. For example, The Connecticut Light and Power Company, in filing a motion for

panel review, stated that “[t]he [Motion] Ruling . . . was signed only by PURA’s

Executive Secretary [and] did not contain any indicia that it was evaluated by, or

decided by, any, or a majority of, PURA’s Commissioners.” Motion No. 38, Nov. 2,

2020, Docket No. 20-08-03, Investigation into Electric Distribution Companies’

Preparation and Response to Tropical Storm Isaias, p. 9 (emphasis added). The

United Illuminating Company, a corporate affiliate of the Companies, simultaneously

filed a similar motion requesting a full panel review under General Statutes § 4-178a

of a motion ruling issued with the Executive Secretary signature block. See Motion

No. 39, Nov. 2, 2020, Docket No. 20-08-03, Investigation into Electric Distribution

Companies’ Preparation and Response to Tropical Storm Isaias. As such, a ruling

issued with the Executive Secretary signature has generally been understood by the

Companies to have been issued by a single lead commissioner and, as such, subject to

panel review.
38. How the practice of using the Executive Secretary signature block arose decades ago

is unknown. However, with respect to motions for extensions of time, Conn.

Agencies Regs. § 16-1-6 states that “The executive secretary of the Authority shall

notify all parties of the Authority’s action upon such motion.” The practice of issuing

motion rulings under the Executive Secretary signature was apparently extended to all

motion rulings and, until recently, was not considered objectionable. However, unlike

Lead Commissioner rulings, motion rulings are currently issued by the presiding

officer on behalf of the panel of commissioners; therefore, it would create confusion

if the presiding officer’s individual signature were attached to a per curiam ruling.

Therefore, the current process of affixing the Executive Secretary signature block to

motion rulings is actually more accurate than when the Lead Commissioner

unilaterally issued rulings under the Executive Secretary signature block.

39. To my knowledge, all motion rulings issued in Docket No. 23-11-02 conformed to the

process described above. Specifically, the Authority ruled on 120 motions before

issuing a final decision, including 15 motions for party/intervenor requests or

consultant notices; 62 motions for protective treatment; 25 motions for extensions of

time; and 18 other procedural or evidentiary motions.

40. All three commissioners were aware of the substance of each motion, the associated

objections, and any requests for reconsideration. Consistent with the process

described in Directive 2.5, the panel conferred on non-ministerial motions. No

motion rulings were issued without the express or implied consent of at least a

majority of the commissioners. No commissioners dissented from a motion ruling.

The Companies had the opportunity to file motions for reconsideration and to raise
 their objections to the full panel if they believed the ruling was incorrect or had been

issued unilaterally.

41. The Company filed three (3) motions for reconsideration of motion rulings. Motion

No. 67 sought reconsideration of the ruling on Motion No. 48. Over the objection by

another party, the Authority reconsidered its prior ruling and granted the Company’s

request. See rulings attached as Exhibit 22. The Company also filed Motion Nos. 69

and 97 seeking reconsideration of rulings issued in response to Motions No. 54 and

77, respectively. The Authority reconsidered the rulings – ultimately denying Motion

No. 60 but granting Motion No. 97 with modification. Id.

42. Of the 120 motion rulings, the Companies identified eight (8) motion rulings (Motion

Ruling Nos. 6, 14, 73, 76, 102, 115, 116, and 118), which the Companies claim were

improperly issued by Chair Gillett. Complaint, ¶ 32. Unlike for the rulings on

Motion Nos. 48, 54, and 77 noted above, the Companies did not file a motion for

reconsideration or for panel review of any of these motions. Notably, the Companies’

affiliate, Avangrid Service Company (using the same legal counsel as the Companies

in this proceeding – Keegan Werlin LLP), had sought panel review of a motion ruling

issued under the Executive Secretary signature. Motion No. 39, Nov. 2, 2020, Docket

No. 20-08-03, Investigation into Electric Distribution Companies’ Preparation and

Response to Tropical Storm Isaias. With Companies’ legal counsel having

previously sought panel review of similar motion rulings, it is not clear why the

Companies did not request reconsideration or panel review of these 8 motion rulings

in this proceeding.
43. The statement that Motion Ruling Nos. 6, 14, 73, 76, 102, 115, 116, and 118 were

issued unilaterally is inaccurate. As noted above, a Lead Commissioner was not

designated for this docket, and the commissioners either conferred or had the

opportunity to confer (and possibly dissent) on all motions. The motion rulings were

issued based on the consensus of the commissioners. In addition, the Companies had

numerous opportunities to raise their objections to the panel.

44. During the hearing on April 30, 2024, which was attended by all three commissioners,

there was a lengthy discussion regarding the Authority’s ruling on Motion Nos. 73

and 76. Following the discussion, the commissioners took a 4 minute recess, during

which the three commissioners and legal counsel conferred, and after which the Chair

issued a ruling from the bench “sustain[ing] the objection [raised by a party] on the

basis of the rulings to both Motion Ruling 73 and 76.” The Company’s attorney

responded to the commissioners that “We’ll just maintain, note our objection for the

record.” As such, all three commissioners were aware of the Companies’ objections

to the rulings on Montion Nos. 73 and 76 but collectively did not reconsider or

change the motion rulings. See Exhibit 23.

45. Also, during the April 30, 2024 hearing, there was a discussion related to Motion No.

6. The Company did not raise or note an objection to the Motion No. 6 ruling before

the panel of commissioners. See Exhibit 24.

46. In addition, during the April 30, 2024 hearing, the Companies’ attorney explained to

the panel of commissioners the details of the soon-to-be-filed Motion No. 102.

Specifically, Attorney Venora stated: “Chair Gillett, and Commissioners, I have just

one. It relates to a Motion for Administrative Notice that the Company's will be filing
 within the next day or so, and we are not asking for a ruling today, but I just wanted

to provide some background on why we are submitting this particular motion.” See

Exhibit 25. As such, all three commissioners were fully aware of the substance of

Motion No. 102 and had the opportunity to confer on the disposition of the motion.

47. For Motions No. 115 and 116, which were submitted after the hearings, the

commissioners conferred both verbally and in writing, with Commissioners Betkoski

and Caron providing their approval in writing prior to issuance. See Exhibit 26

Notably, Motion No. 115 involved the Companies’ allegations regarding ex parte

communications. However, the alleged ex parte communications were determined by

the Court to be “not a material issue in the application or hearing proceeding.” Court

Memorandum, p. 7. In essence, this affirms the commissioners’ ruling on Motion

No. 115.

48. The Companies also had the opportunity to address motion rulings and procedural

concerns in their written exceptions. The Companies’ written exceptions included

approximately 80 pages of argument on motion rulings and other procedural

concerns. Companies’ Written Exceptions, Oct. 25, 2024, Docket No. 23-11-02, pp.

151-237. The full panel reviewed the Companies’ written exceptions.

49. Oral argument was held on October 30, 2024, before all three commissioners. The

Companies’ attorney, Cheryl Kimball, Esq., raised a lengthy objection regarding the

process for motion rulings, including referencing the rulings for Motion Nos. 6, 14,

73, 76, 102, 115, 116, and 118. Transcript (Oct. 30, 2024), pp. 9-19, attached as

Exhibit 27. Notably, Attorney Kimball informed the panel that, “[t]he Commission

has the inherent, unalienable power to overrule a Presiding Officer, and the
 opportunity for that has passed by the time the Final Decision is issued. At that point,

the potential for a party to obtain relief during the proceeding is cut off.” Id., p. 14

(emphasis added). At that time, the Final Decision had not yet been issued, and, as

such, the full panel of commissioners that Attorney Kimball was directly addressing

could have “overruled” any action taken by one or more commissioners. However,

the panel of commissioners asked no questions regarding process, did not express any

concern regarding the motion process, and did not “overrule” any determinations or

rulings issued by the Authority up to that point.

50. At the special meeting approving the Final Decision on November 18, 2024, each of

the commissioners commented on the Final Decision and their vote. None of the

commissioners, including Commissioner Caron (dissenting), raised any concern with

respect to the Companies’ allegations of procedural irregularities.

51. The foregoing demonstrates that the Companies had, and benefited from, numerous

layers of procedural opportunities with regard to the 120 motions ruling issued in the

proceeding. Consequently, the Companies’ complaint appears to arise from their

dissatisfaction that the full panel of commissioners did not rule in their favor on 8 of

those motions.

Opinion Piece Authorship

52. In response to a FOIA request filed by the Companies, the Authority, on February 28,

2025, and March 19, 2025, produced approximately 190 pages of documents

consisting of the communications between PURA and members of the General

Assembly during 2023 and 2024, including the authors of the op-ed (Senator
 Needleman and Representative Steinberg). The production included all documents on

both work and personal electronic devices, including the six (6) text messages

referenced by the Companies.

53. The Authority does not have possession or control of any documents concerning the

drafting or authorship of the December 19, 2024 Opinion piece.

54. For purposes of full transparency, the Authority is providing the following

communications that do not concern the drafting or authorship of the December 19,

2024 Opinion piece, but which provide relevant context. These documents indicate

that the Authority was working on a number of drafts at this time related to the

upcoming legislative session:

(a) Exhibit 28, a calendar invitation for a December 13, 2024 meeting between

Chair Gillett and Senator Needleman, Representative Steinberg, and other state

agency leaders to discuss energy policy pertaining to the 2025 legislative

session;

(b) Exhibit 29, an email dated December 15, 2024, between Chair Gillett and Rep.

Steinberg regarding a draft legislative concept (which is referenced in the text

messages);

(c) Exhibit 30, an email dated December 15, 2024, from Chair Gillett to PURA

staff seeking comments and redlines on draft legislation;

(d) Exhibit 31, an internal email dated December 17, 2024, from Chair Gillett to

PURA staff, including Theresa Govert, regarding input on draft legislative

concepts;
(e) Exhibit 32, an email exchange regarding an invitation for a January 9, 2025

pre-legislative session meeting with leadership of the Energy and Technology

Committee;

(f) Exhibit 33, a follow-up communication regarding the January 9, 2025 meeting

providing information for one of the draft legislative concepts discussed at the

meeting; and

(g) Exhibit 34, an email dated February 10, 2025, conveying PURA’s comments

and recommended language regarding a legislative proposal for standard

service.
 PURA Directive 1.3

avoided during the scheduled sector meeting time slot, the PURA chairperson shall decide
whether to reschedule the sector meeting after considering the meeting agenda and affected
staff. Should an individual staff member experience a scheduling conflict due to scheduled or
unscheduled personal, sick, or vacation leave, it is the staff member’s responsibility to provide a
summary of the information on which they were scheduled to present to their supervisor.
4. Participant Expectations. Lead technical staff and the legal advisor should coordinate on the
presentation for each docket prior to the sector meeting. The presentation may take the form of verbal
remarks, unless a visual aid (powerpoint or excel) would further the conversation.
a. Presentation content – continued dockets, routine matters. The presentation is expected to
consist of the following elements: (1) a concise statement of the docket subject matter (i.e.,
“elevator pitch”; (2) a brief overview of any developments in the docket that have transpired
since the previous sector meeting (i.e., “current status”); (3) a delineation of anticipated next
steps, both internal and external (i.e., “next steps”); and (4) any items of note for which staff are
requesting commissioner guidance or input, to occur by follow-up meeting or email.
b. Presentation content – new dockets. At the first sector meeting on which a docket appears on
the agenda, the presentation is expected to reflect additional detail, as follows: (1) an
explanation of the matter(s) on which the Authority has been asked to render a decision; (2) an
overview of the legal standard of review; (3) proposed next steps; (4) information regarding any
coordination that will be needed with other staff units within PURA or with other agencies; and
(5) any initial requests for commissioner guidance or input.
c. Meetings held by Zoom. The lead staff and legal advisor for each docket shall enable the video
function, at a minimum, for the duration of their presentation of the specific docket material.
5. Miscellaneous. Sector meetings are not a substitute for unit-specific staff meetings, nor are the
meetings intended as a substitute for any detailed strategic or scheduling discussions for individual
dockets that may be needed or requested by a commissioner regarding a docket.

Page 2 of 2

D-58
Exhibit 10a
Muska, Scott

From: Govert, Theresa <[email protected]>

Sent: Thursday, June 27, 2024 9:18 AM
To: Caron, Michael A
Subject: Re: 24-01-15 Frontier PFD/ WEs

Hi Commissioner,

Of course! Do you have specific questions, or would you just like to discuss the PFD more generally? Also, I think it
might be helpful to include Elizabeth Tanaka and Scott in the discussion, as Elizabeth was the lead lawyer. I will
work with Sheena to find a time to set up a zoom call with everyone for today.

Thanks,

Theresa

From: Caron, Michael A <[email protected]>

Sent: Thursday, June 27, 2024 8:21 AM
To: Govert, Theresa <[email protected]>
Cc: Nguyen, Quat <[email protected]>
Subject: 24-01-15 Frontier PFD/ WEs

Theresa,

Hope you’re feeling better. I would like to speak with Quat before I go on vacay Friday (6/28) on the above
docket. Thanks.

Michael Caron

Public Utility Regulatory Authority

1
D-59
Exhibit 10b
Muska, Scott

From: Kramer, Peter

Sent: Wednesday, January 29, 2025 10:53 AM
To: McElrath, Sheena
Subject: RE: Mtg. w/ Commissioner Caron

Yes, that works for me and the UPA team. Can you send a calendar invite? Thank you, Sheena!

Peter Kramer
Managing Director, Technical Staff
Connec cut Public U li es Regulatory Authority
10 Franklin Square, New Britain, CT 06051
p: 720-352-3824| e: [email protected]
ct.gov/pura

From: McElrath, Sheena <[email protected]>

Sent: Wednesday, January 29, 2025 9:57 AM
To: Kramer, Peter <[email protected]>
Subject: Re: Mtg. w/ Commissioner Caron

Good morning! Commissioner Caron is looking for a review of where we are with the new Straw
Proposals and next steps for 2025. Can we schedule for Feb. 10 at 1pm?

Sheena S. McElrath

Administrative Assistant to PURA Chair, Vice Chair and Commissioner

CT Public Utilities Regulatory Authority (PURA)

p: 860-827-2658|e: [email protected]

www.ct.gov/pura

From: McElrath, Sheena <[email protected]>

Sent: Friday, January 24, 2025 3:47 PM
To: Kramer, Peter <[email protected]>
Subject: Re: Mtg. w/ Commissioner Caron

Let me check in with Commissioner Caron and I will follow up.

Thanks so much!

1
D-60
Sheena S. McElrath

Administrative Assistant to PURA Chair, Vice Chair and Commissioner

CT Public Utilities Regulatory Authority (PURA)

p: 860-827-2658|e: [email protected]

www.ct.gov/pura

From: Kramer, Peter <[email protected]>

Sent: Friday, January 24, 2025 3:02 PM
To: McElrath, Sheena <[email protected]>
Subject: RE: Mtg. w/ Commissioner Caron

Hi Sheena,
Certainly. Can you let me know what I and the team should prepare for the meeting? Best option for Monday is
1PM. Otherwise could we look at 02/03 or 02/10 to schedule?
Thank you,
Peter

Peter Kramer
Managing Director, Technical Staff
Connecticut Public Utilities Regulatory Authority
10 Franklin Square, New Britain, CT 06051
p: 720-352-3824| e: [email protected]
ct.gov/pura

From: McElrath, Sheena <[email protected]>

Sent: Friday, January 24, 2025 12:09 PM
To: Kramer, Peter <[email protected]>
Subject: Mtg. w/ Commissioner Caron

Good afternoon! Commissioner Caron would like to schedule a meeting with the UPA team on PBR. Please let me
know if we can try and schedule an in person meeting on Mon. Jan. 27.

Thank you!

Sheena S. McElrath

Administrative Assistant to PURA Chair, Vice Chair and Commissioner

CT Public Utilities Regulatory Authority (PURA)

2
D-61
Exhibit 2
 ORDER 438570
DOCKET NO: HHBCV256092048S SUPERIOR COURT

THE SOUTHERN CONNECTICUT GAS JUDICIAL DISTRICT OF NEW BRITAIN

COMPANY AT NEW BRITAIN
V.
PUBLIC UTILITIES REGULATORY 6/25/2025
AUTHORITY

ORDER

ORDER REGARDING:
05/16/2025 115.00 MOTION FOR ORDER

The foregoing, having been considered by the Court, is hereby:

ORDER:

The plaintiffs, The Connecticut Natural Gas Corporation and The Southern Connecticut Gas Company,
move for an order of compliance, or, in the alternative, additional discovery pursuant to the court’s
memorandum of decision dated April 16, 2025 (decision). See Docket Entry 115.00 (in both
CV-25-6092047 and CV-25-6092048). The plaintiffs argue that the defendant, the Public Utilities
Regulatory Authority (PURA), has not adequately responded to discovery ordered by the court regarding
the circumstances surrounding the drafting of an op-ed article appearing in the Connecticut Mirror on
December 19, 2024. See Decision, at 7-9. Pursuant General Statutes § 4-183 (i) and Practice Book §
13-9 (a), and as set forth below, the court exercises its discretion to authorize additional discovery.

In their respective complaints (see Count Thirteen in CV-25-6092047; Count Fourteen in

CV-25-6092048), the plaintiffs allege that the underlying rate decision was rendered upon improper
procedure because, inter alia, certain statements by the Chairperson of PURA, Marissa Gillett, evidence
an improper bias. It is undisputed that text messages to and from Chairperson Gillett, and publicly
disclosed pursuant to a Freedom of Information Act (FOIA) request, could be interpreted as indicating
that Chairperson Gillett reviewed and/or commented upon the December 19th op-ed prior to its
publication. In the decision, the court held that “a disinterested observer could conclude that the author
of the op-ed in question could have in some measure adjudged the facts of CNG’s and SCG’s
applications before hearing the case, which is to say, prejudged whether the requested rate increases
were appropriate.” Decision, at 9. In the decision, the court therefore exercised its discretion pursuant
General Statutes § 4-183 (i) and Practice Book § 13-9 (a) to authorize limited discovery. Specifically, the
court ordered the production of “all documents within the possession and control of PURA that concern
the drafting or authorship of the December 19, 2024 op-ed.” To what extent, if any, Chairperson Gillett
(and PURA Chief of Staff Theresa Govert) may have reviewed and/or commented upon the December
19th op-ed is a factual dispute among the parties.

The court held a hearing on the motion for order of compliance on June 23, 2025. At the June 23rd
hearing, counsel for PURA represented to the court that documents that were likely responsive to the
court’s April 16th discovery order were deleted from Chairperson Gillett’s electronic devices. Because
of this circumstance, PURA had no responsive documents concerning the text exchange disclosed as a
result of the FOIA request. Because document production is unable to yield any facts concerning to what
extent, if at all, Chairperson Gillett (and PURA Chief of Staff Theresa Govert) may have reviewed and/
or commented upon the December 19th op-ed, the court exercises its discretion pursuant General
Statutes § 4-183 (i) and Practice Book § 13-9 (a) to authorize limited oral discovery.

Within 15 days of the date of this order, the plaintiffs may depose Chairperson Gillett and Chief of Staff
Govert concerning the circumstances surrounding the deletion of any documents responsive to the
HHBCV256092048S 6/25/2025 Page 1 of 2
court’s original discovery order as set forth in the April 16th decision, any actions taken to recover any
potentially responsive documents, and the circumstances surrounding any review, editing, or
commenting upon the December 19th op-ed by Chairperson Gillett and/or Chief of Staff Govert. The
depositions of Chairperson Gillett and Chief of Staff Govert shall be separate, but shall be jointly
conducted by the plaintiffs.

Within 21 days of the date of this order, any party may seek leave to take additional discovery to the
extent the above authorized discovery does not adequately address the issues discussed herein. For
clarity, the above order does not supersede the discovery order issued by the court in the April 16th
decision or relieve any party of its continuing duty to respond to discovery should responsive documents
be located in the future.

Judicial Notice (JDNO) was sent regarding this order.

438570

Judge: MATTHEW JOSEPH BUDZIK

This document may be signed or verified electronically and has the same validity and status as a document with a physical
(pen-to-paper) signature. For more information, see Section I.E. of the State of Connecticut Superior Court E-Services
Procedures and Technical Standards (https://jud.ct.gov/external/super/E-Services/e-standards.pdf), section 51-193c of the
Connecticut General Statutes and Connecticut Practice Book Section 4-4.

HHBCV256092048S 6/25/2025 Page 2 of 2

Exhibit 3
 State of Connecticut
HOUSE OF REPRESENTATIVES
STATE CAPITOL
HARTFORD, CONNECTICUT 06106-1591

REPRESENTATIVE VINCENT J. CANDELORA REPUBLICAN LEADER

EIGHTY-SIXTH ASSEMBLY DISTRICT

LEGISLATIVE OFFICE BUILDING, ROOM 4200

300 CAPITOL AVENUE
HARTFORD, CT 06106-1591

TOLL FREE: (800) 842-1423

CAPITOL: (860) 240-8700
[email protected]

September 18, 2025

Speaker Matthew Ritter

300 Capitol Avenue
Room 4105
Hartford, CT 06106

Dear Speaker Ritter,

In light of recent press reports that the Chairman of the Public Utilities Regulatory Authority
("Authority"), Marissa Gillett, may have lied during her confirmation hearing in front of the Legislative
and Executive Nominations Committee ("Committee"), I am requesting that you convene a Select
Committee of Inquiry to investigate and consider her conduct, and report to the House on its findings,
including whether sufficient grounds exist for impeachment.

In her sworn testimony in front of the Committee on February 20, 2025, and in response to my direct
questions, Ms. Gillett denied the existence of any email or directive to the commissioners and/or staff
of the Authority that required staff support to commissioners be directed through her. In fact, in
support of her claim, she stated that there was a signed "attestation in writing" from the
commissioners that no such directive was ever issued. Not only did I request a copy of that attestation
during her confirmation hearing, but on March 27, I followed up my inquiry with a letter directly to
Chair Gillett asking for a copy (see attached). To date, no such attestation has been produced.

I suspect no such attestation exists since it has now been reported that, in direct contradiction to Ms.
Gillett's sworn testimony during her confirmation hearing, she did in fact issue a directive to the other
commissioners of the Authority that restricted access to support staff.

www.RepCandelora.com
As a result of this revelation, I am requesting that you convene a Select Committee of Inquiry to
determine whether Chair Gillett perjured herself during her confirmation process before the Legislative
and Executive Nominations Committee and whether such conduct is sufficient grounds for
impeachment. I sincerely regret having to make such a request; however, this institution must be
protected and the integrity of our nomination and confirmation process demands that nominees
conduct themselves with the highest level of honesty. Misleading or untrue statements provided by
nominees during this process cannot be tolerated.

Sincerely,

Representative Vincent Candelora

House Republican Leader
CC:
Martin Looney- Senate President Pro Tempore
Stephen Harding- Senate Republican Leader