FERC Filings
MOTION OF EPSA FOR LEAVE TO INTERVENE, PJM INTERCONNECTION, L.L.C
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 to ensure that cost allocation procedures do not undermine the development of competitive markets and that PJM's unbundled budget proposal treats all PJM participants fairly.
November 18, 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
Larry F. Eisenstat, Esq.
Michael J. Rustum, Esq.
Dickstein, Shapiro, Morin & Oshinsky
2101 L Street, NW
Washington, D.C. 20037
202-828-2224