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REQUEST FOR REHEARING ON PJM GRANDFATHERING PROCESS

Request for Rehearing of the Electric Power Supply Association, Docket No. ER99-2340-000

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

______________________________

)
PJM Interconnection, L.L.C.
)

Docket No. ER99-2340-000
_____________________________ )

REQUEST FOR REHEARING OF THE
ELECTRIC POWER SUPPLY ASSOCIATION

Pursuant to Rule 713 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (FERC or Commission), 18 CFR § 385.713, the Electric Power Supply Association (EPSA) hereby requests rehearing of the Order issued June 17, 1999 in this proceeding (Order). For the reasons set forth below, the Commission should, on rehearing, reject PJM's grandfathering procedures (Section 39.2 of the PJM Tariff). Alternatively, the Commission should not defer to PJM's procedures, but should review and address the merits of PJM's application of its grandfathering provisions on a case-by-case basis.