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MOTION OF EPSA FOR LEAVE TO INTERVENE AND PROTEST, NEW ENGLAND POWER POOL

III. CONCLUSION

WHEREFORE, the Commission should reject the NEPOOL Participants’ Committee’s proposed revisions to Market Rules 6, 8 and 9.

Dated: October 15, 1999

Respectfully submitted,

_____________________________

Julie Simon, Director of Policy
Mark E. Bennett, Senior Manager of Policy
Electric Power Supply Association
1401 H Street, N.W., Suite 760
Washington, D.C. 20005