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

CONCLUSION

For the foregoing reasons, the Movants request that the Commission (i) reject the NEC's CMS proposal and not offer any substantive guidance on it; (ii) direct the parties to utilize the Dispute Resolution Service for reconsidering the proposal during the period prior to implementation of approved, revised NEPOOL governance procedures and voting rules, or; (iii), alternatively, direct that NEPOOL refile a CMS proposal at such time as approved NEPOOL governance procedures and revised voting rules are in place and a new vote is taken as to the most desirable CMS for NEPOOL; and (iv), if the Commission does consider the merits of the NEC's proposal, modify the proposal with respect to the allocation of FCRs in a manner consistent with the discussion herein.

Dated: April 23, 1999
Respectfully submitted,




______________________________________

Larry F. Eisenstat

George E. Johnson
Mark L. Perlis

Dickstein Shapiro Morin & Oshinsky LLP

2101 L Street, N.W.

Washington, D.C. 20037-1526

(202) 785-9700



Attorneys for 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

• View Previous Section
• Back to Issue Menu