FERC Filings

MOTION OF EPSA FOR LEAVE TO INTERVENE OUT OF TIME, COMMONWEALTH EDISON COMPANY

IV.

WHEREFORE, EPSA, at a minimum, urges the Commission to require Com Ed to fully explain and justify that its request to refunctionalize transmission facilities to the distribution function is consistent with the requirements set forth in Order No. 888. In the new competitive environment being fostered by Order Nos. 888 and 889, it would be unfortunate if the Commission, under the guise of deferring to state regulatory decisions, allowed Com Ed to take actions that undermine the very goals the Commission is promoting.

EPSA respectfully requests leave to intervene out of time in, and become a party to, this proceeding, and to be afforded all rights appropriate to that status.

October 21, 1999

Respectfully submitted,

____________________________
Julie Simon, Director of Policy
Mark E. Bennett, Senior Manager of Policy
ELECTRIC POWER SUPPLY ASSOCIATION
1401 H Street, NW, Suite 760
Washington, DC 20005
202-789-7200

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