FERC Filings
MOTION OF EPSA FOR LEAVE TO INTERVENE OUT OF TIME, COMMONWEALTH EDISON COMPANY
I.
On September 17, 1999, Commonwealth Edison Company and Commonwealth Edison Company of Indiana (jointly, Com Ed) filed certain tariff sheets under its Open Access Transmission Tariff (OATT) "to reduce and update the rates for transmission and ancillary services and to update the loss factors." By Notice issued September 22, 1999, the Commission set October 7, 1999 as the deadline for timely interventions and protests.
The Electric Power Supply Association (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 bring the benefits of competition to all electric customers. Using a broad spectrum of fossil-fuel and renewable technologies, EPSA's generator members supply reliable, competitively priced electricity, steam and other forms of useful energy from environmentally-responsible facilities.<sup>1</sup> EPSA members either own generating facilities or trade power in wholesale markets and are engaged in making market-based sales in a competitive electric market. To effectuate these transactions, EPSA members utilize the Open Access Transmission tariffs of Com Ed and other jurisdictional providers. Therefore, EPSA has a direct and substantial interest in the issue presented in this proceeding that cannot be represented by any other party.
EPSA is intervening in this proceeding out of time because the Commission's September 22, 1999 Notice did not give adequate notice that the issue of "refunctionalizing" Com Ed's transmission facilities had been raised in this proceeding. It wasn't until other intervenors raised the issue that EPSA became aware of the problems associated with this filing. EPSA's intervention at this time will not unduly delay or disrupt the proceedings and its input will assist the Commission in its consideration of the important policy issues raised by the Com Ed filing.
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 specific issue.