FERC Filings

MOTION OF EPSA FOR LEAVE TO INTERVENE AND PROTEST, CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORPORATION

I. MOTION TO INTERVENE

EPSA is the national trade association representing competitive power suppliers active in U.S. and global power 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<sup>1</sup>.

Many of EPSA's members are authorized to sell energy and ancillary services at market-based rates. Given that EPSA members are engaged in numerous transactions within the California markets and, therefore, could be affected by the ISO price cap and other proposals, EPSA has a direct and substantial interest in the outcome of this proceeding that cannot be adequately represented by any other party.
All pleadings, correspondence and other communications concerning this proceeding should be directed to:
Lynne H. Church, Executive Director

Larry F. Eisenstat
*Julie Simon, Director of Policy

*Michael J. Rustum
Electric Power Supply Association

Dickstein Shapiro Morin
1401 H Street, N.W., Suite 760

& Oshinsky, LLP
Washington, D.C. 20005

2101 L Street, N.W.
Tel:
(202) 789-7200

Washington, D.C. 20037
Fax:
(202) 789-7201

Tel:
(202) 785-9700

Fax:
(202) 887-0689
*designated for receipt of service
1. The comments contained in this filing represent the position of EPSA as an organization, but not necessarily the view of any particular member with respect to any issue.