November 16, 2011

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Washington, D.C. 20549

Attn:	H. Christopher Owings

	Re:	NRG Energy, Inc.
		Registration Statement on Form S-4

Ladies and Gentlemen:

Reference is made to the Registration Statement on Form S-4 (the “Registration Statement”), of NRG Energy, Inc. and the other registrants named therein (collectively, the “Registrants”), registering the offer to exchange (i) up to $800 million aggregate principal amount of 7.625% Senior Notes due 2019 (together with the guarantees thereof, the “2019 Exchange Notes”) for a like aggregate principal amount of 7.625% Senior Notes due 2019 (together with the guarantees thereof, the “2019 Old Notes”) and (ii) up to $1.2 billion aggregate principal amount of 7.875% Senior Notes due 2021 (together with the guarantees thereof, the “2021 Exchange Notes” and the 2021 Exchange Notes together with the 2019 Exchange Notes, the “Exchange Notes”) for a like aggregate principal amount of 7.875% Senior Notes due 2021 (together with the guarantees thereof, the “2021 Old Notes” and the 2021 Old Notes together with the 2019 Old Notes, the “Old Notes”).

Please be advised that the Registrants are registering the exchange offer in reliance on the position of the staff of the Securities and Exchange Commission (the “Staff”) enunciated in: Exxon Capital Holdings Corporation (available May 13, 1988); Morgan Stanley & Co. Incorporated (available June 5, 1991); and Shearman & Sterling (available July 2, 1993). In addition, the Registrants hereby represent that they have not entered into any arrangement or understanding with any person to distribute the Exchange Notes to be received in the exchange offer and, to the best of the Registrants’ information and belief, each person participating in the exchange offer will be acquiring the Exchange Notes in its ordinary course of business and will not have any arrangement or understanding with any person to participate in the distribution of the Exchange Notes to be received in the exchange offer. In this regard, the Registrants will make each person participating in the exchange offer aware, by means of the exchange offer prospectus and the related letter of transmittal, that if such person is participating in the exchange offer for the purpose of distributing the Exchange Notes to be acquired in the exchange offer, such person (i) cannot rely on the Staff position enunciated in Exxon Capital Holdings Corporation or interpretative letters to similar effect and (ii) must comply with the registration and prospectus delivery requirements of the Securities Act of 1933, as amended, in connection with a secondary resale transaction. The Registrants acknowledge that such a secondary resale

transaction by such person participating in the exchange offer for the purpose of distributing the Exchange Notes should be covered by an effective registration statement containing the selling securityholder information required by Item 507 of Regulation S-K under the Securities Act of 1933, as amended.

The Registrants represent that with respect to any broker-dealer that participates in the exchange offer with respect to Old Notes acquired for its own account as a result of market-making activities or trading activities each such broker-dealer must confirm that it has not entered into any arrangement or understanding with the Registrants or an affiliate of the registrants to distribute the Exchange Notes. The Registrants will make each person participating in the exchange offer aware (through the exchange offer prospectus) that any broker-dealer who holds Old Notes acquired for its own account as a result of market-making activities or other trading activities, and who receives Exchange Notes in exchange for such Old Notes pursuant to the exchange offer, may be a statutory underwriter and, in connection with any resale of such Exchange Notes, must deliver a prospectus meeting the requirements of the Securities Act of 1933, as amended, which may be the prospectus for the exchange offer so long as it contains a plan of distribution with respect to such resale transactions (such plan of distribution need not name the broker-dealer or disclose the amount of Exchange Notes held by the broker-dealer). In addition, the Registrants will include in the transmittal letter or similar documentation to be executed by an exchange offeree in order to participate in the applicable exchange offer the following additional representation, in substantially the form set forth below:

. . . if it is a broker-dealer that will receive Exchange Notes for its own account in exchange for Old Notes, it: (1) the Old Notes to be exchanged for Exchange Notes were acquired by it as a result of market-making or other trading activities, (2) it has not entered into any arrangement or understanding with the issuer or an affiliate of the issuer to distribute the Exchange Notes and (3) it will deliver a prospectus meeting the requirements of the Securities Act in connection with any resale of such Exchange Notes; however, by so representing and by delivering a prospectus, a broker-dealer will not be deemed to admit that it is an “underwriter” within the meaning of the Securities Act.

If you have any further questions or comments or desire further information in respect of the Registration Statement, please do not hesitate to contact Paul Zier of Kirkland & Ellis LLP, special counsel to the Registrants, at 312-862-2180.

			Sincerely,


NRG ENERGY, INC.


By:	/s/ Christopher Sotos
	Name:	Christopher Sotos
	Title:	Vice President and Treasurer

	GUARANTORS:


	ARTHUR KILL POWER LLC
	ASTORIA GAS TURBINE POWER LLC
	CABRILLO POWER I LLC
	CABRILLO POWER II LLC
	CARBON MANAGEMENT SOLUTIONS LLC
	CLEAN EDGE ENERGY LLC
	CONEMAUGH POWER LLC
	CONNECTICUT JET POWER LLC
	COTTONWOOD DEVELOPMENT LLC
	COTTONWOOD GENERATING PARTNERS I LLC
	COTTONWOOD GENERATING PARTNERS II LLC
	COTTONWOOD GENERATING PARTNERS III LLC
	COTTONWOOD ENERGY COMPANY LP
	COTTONWOOD TECHNOLOGY PARTNERS LP
	DEVON POWER LLC
	DUNKIRK POWER LLC
	EASTERN SIERRA ENERGY COMPANY
	EL SEGUNDO POWER, LLC
	EL SEGUNDO POWER II LLC
	ENERGY PLUS HOLDINGS LLC
	ENERGY PLUS NATURAL GAS LP
	ENERGY PROTECTION INSURANCE COMPANY
	HUNTLEY POWER LLC

	INDEPENDENCE ENERGY ALLIANCE LLC
	INDEPENDENCE ENERGY GROUP LLC
	INDEPENDENCE ENERGY NATURAL GAS LLC
	INDIAN RIVER OPERATIONS INC.
	INDIAN RIVER POWER LLC
	KEYSTONE POWER LLC
	LANGFORD WIND POWER, LLC
	LOUISIANA GENERATING LLC
	MIDDLETOWN POWER LLC
	MONTVILLE POWER LLC
	NEO CORPORATION
	NEO FREEHOLD-GEN LLC
	NEO POWER SERVICES INC.
	NEW GENCO GP, LLC
	NORWALK POWER LLC
	NRG AFFILIATE SERVICES INC.
	NRG ARTESIAN ENERGY LLC
	NRG ARTHUR KILL OPERATIONS INC.
	NRG ASTORIA GAS TURBINE OPERATIONS INC.
	NRG BAYOU COVE LLC
	NRG CABRILLO POWER OPERATIONS INC.
	NRG CALIFORNIA PEAKER OPERATIONS LLC
	NRG CEDAR BAYOU DEVELOPMENT COMPANY, LLC
	NRG CONNECTICUT AFFILIATE SERVICES INC.
	NRG DEVELOPMENT COMPANY INC.
	NRG DEVON OPERATIONS INC.
	NRG DUNKIRK OPERATIONS INC.
	NRG EL SEGUNDO OPERATIONS INC.
	NRG ENERGY SERVICES LLC
	NRG ENERGY SERVICES GROUP LLC
	NRG GENERATION HOLDINGS, INC.
	NRG HUNTLEY OPERATIONS INC.
	NRG ILION LP LLC
	NRG INTERNATIONAL LLC
	NRG MAINTENANCE SERVICES LLC
	NRG MEXTRANS INC.
	NRG MIDATLANTIC AFFILIATE SERVICES INC.
	NRG MIDDLETOWN OPERATIONS INC.
	NRG MONTVILLE OPERATIONS INC.

	NRG NEW JERSEY ENERGY SALES LLC
	NRG NEW ROADS HOLDINGS LLC
	NRG NORTH CENTRAL OPERATIONS INC.
	NRG NORTHEAST AFFILIATE SERVICES INC.
	NRG NORWALK HARBOR OPERATIONS INC.
	NRG OPERATING SERVICES, INC.
	NRG OSWEGO HARBOR POWER OPERATIONS INC.
	NRG POWER MARKETING LLC
	NRG RETAIL LLC
	NRG ROCKFORD ACQUISITION LLC
	NRG SAGUARO OPERATIONS INC.
	NRG SERVICES CORPORATION
	NRG SIMPLYSMART SOLUTIONS LLC
	NRG SOUTH CENTRAL AFFILIATE SERVICES INC.
	NRG SOUTH CENTRAL GENERATING LLC
	NRG SOUTH CENTRAL OPERATIONS INC.
	NRG TEXAS C&I SUPPLY LLC
	NRG TEXAS HOLDING INC.
	NRG TEXAS LLC
	NRG TEXAS POWER LLC
	NRG WEST COAST LLC
	NRG WESTERN AFFILIATE SERVICES INC.
	O’BRIEN COGENERATION, INC. II
	ONSITE ENERGY, INC.
	OSWEGO HARBOR POWER LLC
	PENNYWISE POWER LLC
	RE RETAIL RECEIVABLES, LLC
	RELIANT ENERGY NORTHEAST LLC
	RELIANT ENERGY POWER SUPPLY, LLC
	RELIANT ENERGY RETAIL HOLDINGS, LLC
	RELIANT ENERGY RETAIL SERVICES, LLC
	RELIANT ENERGY TEXAS RETAIL, LLC
	RERH HOLDINGS, LLC
	SAGUARO POWER LLC
	SOMERSET OPERATIONS INC.
	SOMERSET POWER LLC
	TEXAS GENCO FINANCING CORP.
	TEXAS GENCO GP, LLC

	TEXAS GENCO HOLDINGS, INC.
	TEXAS GENCO OPERATING SERVICES, LLC
	VIENNA OPERATIONS INC.
	VIENNA POWER LLC
	WCP (GENERATION) HOLDINGS LLC
	WEST COAST POWER LLC

By:	/s/ Christopher Sotos
	Name:	Christopher Sotos
	Title:	Treasurer


ELBOW CREEK WIND PROJECT LLC


By:	/s/ Christopher Sotos
	Name:	Christopher Sotos
	Title:	Controller


GCP FUNDING COMPANY, LLC


By:	/s/ Christopher Sotos
	Name:	Christopher Sotos
	Title:	Management Board Member


GREEN MOUNTAIN ENERGY COMPANY


By:	/s/ Christopher Sotos
	Name:	Christopher Sotos
	Title:	Vice President, Treasury


NRG CONSTRUCTION LLC


By:	/s/ Rachel Smith
	Name:	Rachel Smith
	Title:	Treasurer

NRG ENERGY LABOR SERVICES LLC


By:	/s/ Gaetan Frotte
	Name:	Gaetan Frotte
	Title:	Vice President and Treasurer


NRG ILION LIMITED PARTNERSHIP


By:	Rockford Acquisition LLC, its General Partner

By:	/s/ Christopher Sotos
	Name:	Christopher Sotos
	Title:	Treasurer


NRG SOUTH TEXAS LP


By:	Texas Genco GP, LLC, its General Partner

By:	/s/ Christopher Sotos
	Name:	Christopher Sotos
	Title:	Treasurer


TEXAS GENCO LP, LLC


By:	/s/ Christopher Sotos
	Name:	Christopher Sotos
	Title:	Management Committee Member


TEXAS GENCO SERVICES, LP


By:	New Genco GP, LLC, its General Partner

By:	/s/ Christopher Sotos
	Name:	Christopher Sotos
	Title:	Treasurer