No-Action Letter under
Public Utility Holding Company Act of 1935 —
Section 2(a)(7)(A)

Old Dominion Electric Cooperative, et al.

October 13, 2004

Response of the Office of Public Utility Regulation,
Division of Investment Management

Our Ref. No. 04-3-OPUR
Old Dominion Electric Cooperative, et al.
File No. 132-3

Based on the facts and representations in your letter of October 13, 2004, and without necessarily agreeing with your legal analysis, we would not recommend any enforcement action to the Commission under section 2(a)(7)(A) of the Public Utility Holding Company Act of 1935 against Old Dominion, New Dominion or any of the Member Distribution Cooperatives as a result of the Reorganization and under the circumstances described in your letter.

You should note that facts or conditions different from those presented in your letter might require a different conclusion. Further, this response expresses only the Division’s position on enforcement action. It does not purport to express any legal conclusion on the questions presented.

David G. LaRoche
Special Counsel

October 13, 2004

Incoming Letter

The Incoming Letter is in PDF format.

http://www.sec.gov/divisions/investment/noaction/olddominion101304.htm