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FERC Filings

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

III. CONCLUSION

WHEREFORE, the Commission should reject the proposed Amendment No. 21 to the ISO Tariff for extension of authority to Cap Energy and Ancillary Service Bids.

October 14, 1999

Respectfully submitted,

_____________________________
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

Larry F. Eisenstat
Michael J. Rustum
Dickstein Shapiro Morin
& Oshinsky, LLP
2101 L Street, N.W.
Washington, D.C. 20037

Attorneys for the Electric Power
Supply Association