FERC Filings
MOTION TO INTERVENE AND PROTEST OF U.S. GENERATING COMPANY, USGEN NEW ENGLAND, INC., PG&E ENERGY TRADING-POWER, L.P., DUKE ENERGY POWER SERVICES, L.L.C, CASCO BAY ENERGY COMPANY, L.L.C., AND THE ELECTRIC POWER SUPPLY ASSOCIATION
MOTION TO INTERVENE
USGen develops and manages the operation of independent power facilities throughout the United States, including facilities located within the NEPOOL control area. USGenNE, an affiliate of USGen, is a NEPOOL Participant, having acquired, effective September 1, 1998, the non-nuclear generating assets of New England Power Company, all of which are located within the NEPOOL control area. PGET-Power, a power marketer with Commission authorization to sell electricity at wholesale throughout the United States and an affiliate of USGen and USGenNE, also is a NEPOOL Participant. As a result, each of the USGen Companies has a direct and substantial interest in the instant proceeding which cannot be adequately represented by any other party. Accordingly, their intervention is in the public interest and should be granted.
Duke owns and operates electric power plants across the United States and Canada. Duke is a NEPOOL Participant. Casco Bay, a wholly-owned Duke affiliate, is a limited liability company organized and existing under the laws of the State of Delaware. Casco Bay owns and will operate the Maine Independence Station ("MIS"), a 520 MW combined cycle gas-fired electric generating facility to be located in Veazie, Maine and which is expected to commence commercial operations in May 2000. MIS will be interconnected to Pool Transmission Facilities ("PTF") owned by Bangor Hydro-Electric Company, a NEPOOL Participant. An application concerning Casco Bay’s plan to add the MIS facility to the NEPOOL grid along with the necessary transmission upgrades and system reinforcements required to fully integrate the facility was recently approved under Section 18.4 of the Restated NEPOOL Agreement ("RNA"). As a result, Duke and Casco Bay each have direct and substantial interests in the instant proceeding which cannot be adequately represented by any other party. Accordingly, their intervention is in the public interest and should be granted.
EPSA is the national trade association representing competitive power suppliers active in U.S. and global markets. EPSA’s members, which include power generators, power marketers and suppliers of goods and services to the electric power supply industry, share a commitment to bringing the benefits of competition to all electric customers. Using a broad spectrum of fossil-fuel and renewable technologies, EPSA members generate reliable, competitively priced electricity, steam and other forms of useful energy from environmentally-responsible facilities. Several EPSA members are NEPOOL Participants. As a result, EPSA has a direct and substantial interest in the instant proceeding that cannot be adequately represented by any other party. Accordingly, its intervention is in the public interest and should be granted.
All pleadings, correspondence and other communications concerning this docket should be directed to the following persons, and their names and addresses should be placed on the official service list for this docket:
Sanford L. Hartman
*Peter E. Meier
U.S. Generating Company
One Bowdoin Square
Suite 600
Boston, MA 02114
Tel: 617-788-3365
Fax: 617-788-3900
*Larry F. Eisenstat
George E. Johnson
Mark L. Perlis
Dickstein Shapiro Morin &
Oshinsky, LLP
2101 L Street, N.W.
Washington, DC 20037
Tel: 202-775-9700
Fax: 202-887-0689
*Peter J. Ledig
Casco Bay Energy Company, LLC
c/o Duke Energy Power Services, LLC
5400 Westheimer Court
Houston, TX 77056-5310
Tel: 713-627-6550
Fax: 713-627-6555
*Brent C. Bailey, Esq.
Duke Energy Power Services, LLC
5400 Westheimer Court
Houston, TX 77056-5310
Tel: 713-627-6307
Fax: 713-627-5550
Lynne H. Church, Executive Director
*Julie Simon, Director of Policy
Electric Power Supply Association
1401 H Street, N.W., Suite 760
Washington, D.C. 20005
Tel: 202-789-7200
Fax: 202-789-7201
* Authorized to receive service hereunder.