Destec Energy, Inc., Destec Operating Company, Cogen Lyondell, Inc., and Lyondell Petrochemical Company v. Houston Lighting & Power Company
This Texas Court of Appeals case addresses whether a partnership formed by Destec Energy, Inc. and Lyondell Petrochemical Company, which generates and distributes electricity to its partners, requires a certificate of convenience and necessity (CCN) from the Public Utility Commission (PUC). Appellants argued for a 'self-use' exemption based on the aggregate theory of partnership. The court affirmed the trial court's judgment, holding that under the Texas Revised Partnership Act (TRPA), a partnership is a distinct entity from its partners, thus precluding the application of the self-use exemption for electricity distributed from the partnership to its partners. The decision emphasizes the entity theory of partnerships for regulatory purposes.