Aspire Power Ventures, LP v. Public Utility Commission of Texas, Electric Reliability Council of Texas, Thomas Gleeson, Lori Cobos, Jimmy Glotfelty, Kathleen Jackson, and Courtney Hjaltman

ACCEPTED 15-24-00118-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 1/7/2025 8:13 AM No. 15-24-00118-CV CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS COURT OF APPEALS FOR THE AUSTIN, TEXAS FIFTEENTH DISTRICT OF TEXAS 1/7/2025 8:13:51 AM AUSTIN, TEXAS CHRISTOPHER A. PRINE Clerk

ASPIRE POWER VENTURES, LP, Appellant, v. PUBLIC UTILITY COMMISSION OF TEXAS, ELECTRIC RELIABILITY COUNCIL OF TEXAS, THOMAS GLEESON, LORI COBOS, JIMMY GLOTFELTY, KATHLEEN JACKSON, AND COURTNEY HJALTMAN, Appellees.

On Appeal from the 345th Judicial District of Texas Travis County, Texas Cause No. D-1-GN-24-003384 Hon. Catherine A. Mauzy, Presiding JOINT UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEES’ BRIEFS ON THE MERITS

TO THE HONORABLE COURT: Appellees Public Utility Commission of Texas, Thomas Gleeson, Lori Cobos, Jimmy Glotfelty, Kathleen Jackson and Courtney Hjaltman (the “PUCT Appellees”), and Appellee Electric Reliability Council of Texas, Inc. (“ERCOT”) (together, “Appellees”) hereby jointly file this

Unopposed Motion for Extension of Time to file their Briefs on the Merits.

In support of this Motion, Appellees respectfully show the following: 1. Appellees’ respective Briefs on the Merits are currently due January 17, 2025.

2. Appellees jointly request an extension of time of thirty days, to February 17, 2025. This is the PUCT Appellees’ and ERCOT’s first request for an extension of time for the filing of their Briefs on the Merits.

3. This Court previously granted Appellant Aspire Power Ventures, LP’s (“Aspire”) requested 10-day extension to file its Brief on the Merits. Aspire, accordingly, filed its Brief on the Merits on December 18, 2024.

4. In addition to the intervening Christmas and New Years’ holidays, Appellees rely on the following facts as a reasonable explanation for the request extension of time: For ERCOT’s part, when undersigned counsel received Aspire’s Brief on the Merits, undersigned counsel was in a jury trial in the Southern District of New York (Cause No. 1:19-cv-01578), and has five summary judgment responses, an affirmative summary judgment deadline, two summary judgment hearings, and an all-day mediation on or before January 17. Counsel for the PUCT Appellees also has several filing deadlines in January, including a brief on the merits due in City of College Station v. PUCT, No. D-1-GN24-005680, Travis County District Court, and is preparing for a February 4 oral argument before the Fifth Circuit (No. 16-60670).

5. The undersigned have conferred with opposing counsel, who has indicated they do not oppose this request.

CONCLUSION AND PRAYER For the reasons set forth above, the PUCT Appellees and ERCOT pray that the Court grant this Joint Motion for Extension of Time, and allow Appellees until February 17, 2025 to file their respective Briefs on the Merits.

Respectfully submitted, /s/ John R. Hulme /s/ Elliot Clark Ken Paxon Elliot Clark Attorney General of Texas State Bar No. 24012428 [email protected] Brent Webster Elin Isenhower First Assistant Attorney General State Bar No. 24104206 Ralph Molina [email protected] Deputy First Assistant Attorney General 600 W. 5th Street, Suite 900 Austin, Texas 78701 James Lloyd Telephone: (512) 370-2800 Deputy Attorney General for Civil Facsimile: (512) 370-2850 Litigation ATTORNEYS FOR APPELLEE ERCOT Kellie E. Billings-Ray Chief, Environmental Protection Division John R. Hulme Special Counsel State Bar No. 10258400 [email protected] Amanda Atkinson Cagle Assistant Attorney General State Bar No. 00783569 [email protected] Jordan Pratt Assistant Attorney General State Bar No. 24140277 [email protected] Office of the Attorney General of Texas Environmental Protection Division P.O. Box 12548, MC-066 Austin, TX 78711-2548 (512) 463-2021 (Ph.) (512) 320-0911 (Fax) ATTORNEYS FOR THE PUCT APPELLEES CERTIFICATE OF SERVICE By my signature below, I hereby certify that a true and correct copy of this document has been served on all counsel of record in accordance with the Texas Rules of Civil Procedure on January 7, 2025.

/s/ Elliot Clark Elliot Clark

Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Elliot Clark Bar No. 24012428 [email protected] Envelope ID: 95918105 Filing Code Description: Motion Filing Description: Appellees Joint Unopposed Mtn for Ext to file Brief Status as of 1/7/2025 8:40 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status David Laurent [email protected] 1/7/2025 8:13:51 AM SENT

Associated Case Party: Aspire Power Ventures, LP Name BarNumber Email TimestampSubmitted Status Chrysta L.Castaneda [email protected] 1/7/2025 8:13:51 AM SENT Nicole Michael [email protected] 1/7/2025 8:13:51 AM SENT Monica Latin [email protected] 1/7/2025 8:13:51 AM SENT Brent M.Rubin [email protected] 1/7/2025 8:13:51 AM SENT Ken Carroll [email protected] 1/7/2025 8:13:51 AM SENT

Associated Case Party: Electric Reliability Council of Texas Name BarNumber Email TimestampSubmitted Status Elliot Clark [email protected] 1/7/2025 8:13:51 AM SENT Elliot Clark [email protected] 1/7/2025 8:13:51 AM SENT Elin Isenhower [email protected] 1/7/2025 8:13:51 AM SENT Elin Isenhower [email protected] 1/7/2025 8:13:51 AM SENT

Associated Case Party: Public Utility Commission of Texas Name BarNumber Email TimestampSubmitted Status John Hulme [email protected] 1/7/2025 8:13:51 AM SENT Amanda AtkinsonCagle [email protected] 1/7/2025 8:13:51 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Elliot Clark Bar No. 24012428 [email protected] Envelope ID: 95918105 Filing Code Description: Motion Filing Description: Appellees Joint Unopposed Mtn for Ext to file Brief Status as of 1/7/2025 8:40 AM CST Associated Case Party: Public Utility Commission of Texas Amanda AtkinsonCagle [email protected] 1/7/2025 8:13:51 AM SENT Jordan Pratt [email protected] 1/7/2025 8:13:51 AM SENT