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MOTION OF THE ELECTRIC POWER SUPPLY ASSOCIATION FOR LEAVE TO INTERVENE AND COMMENTS

V.

FOR THE REASONS SET FORTH HEREIN, EPSA respectfully requests permission to intervene in and become a party to this proceeding, and to be afforded all rights appropriate to that status. In addition, the Commission should require modifications to the PJM proposals as set forth herein.



April 20, 1999

Respectfully submitted,

Lynne H. Church, Executive Director
Julie Simon, Director of Policy
Electric pOWER SUPPLY Association
1401 H Street, NW, Suite 760
Washington, DC 20005
202-789-7200


Larry F. Eisenstat, Esq.
Michael J. Rustum, Esq.
Dickstein, Shapiro, Morin & Oshinsky
2101 L Street, NW
Washington, D.C. 20037
202-828-2224