FERC Filings

MOTION OF EPSA FOR LEAVE TO INTERVENE, OPEN-ACCESS SAME-TIME INFORMATION

I. Introduction

Pursuant to Rule 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission ("FERC" or "Commission"), 18 C.F.R. 385. 214, the Electric Power Supply Association ("EPSA") hereby moves for leave to intervene in the above-captioned proceeding. The E-tagging procedures the North American Reliability Council (NERC) and its member utilities are implementing pursuant to NERC's "Policy 3-Interchange" vary from FERC-approved transmission tariffs and therefore conflict with FERC's prior Order regarding the use of tagging¹. Also, the E-tagging requirements were developed without regard for fundamental due process procedures and allows arbitrary and discriminatory application that threatens to undermine the development of competitive wholesale power markets. EPSA urges the Commission to grant the relief PECO Energy Company-Power Team (PECO) requests in its Motion, including an order suspending the implementation of E-tagging until NERC's Policy 3--Interchange has been filed with, and approved by, the Commission as an amendment to the open access transmission tariffs. 1. Coalition Against Private Tariffs, 83 FERC 61,015

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