FERC Filings

MOTION TO INTERVENE AND PROTEST OF EPSA, AMERICAN ELECTRIC POWER SERVICE CORP.

I. MOTION TO INTERVENE

EPSA is the national trade association representing competitive power suppliers active in United States and global power markets. EPSA's members, which include power generators, power marketers and suppliers of goods and services to the electric power supply industry, share a commitment to bring the benefits of competition to all electric customers. Using a broad spectrum of fossil-fuel and renewable technologies, EPSA's members generate reliable, competitively priced electricity, steam and other forms of useful energy from environmentally-responsible facilities.

Certain of EPSA's members presently are, or are in the process of, considering the development of new generating projects in AEP's service territory that must interconnect to AEP's transmission system. EPSA is interested in facilitating the adoption of interconnection rules, procedures and agreements which, from a national perspective, are just and reasonable and not unduly discriminatory and promote the development of competitive electricity markets. Accordingly, EPSA has a direct and substantial interest in the outcome of the instant proceeding that cannot adequately be represented by any other party. EPSA submits that good cause exists for granting this timely motion to intervene, and that its intervention is in the public interest, and should thus be granted.

All pleadings, correspondence and other communications concerning this docket should be directed to the following persons, and their names and addresses should be placed on the official service list for this docket:

*Julie Simon, Director of Policy
Larry F. Eisenstat
Mark Bennett, Senior Manager of Policy
*Michael J. Rustum
Electric Power Supply Association
Dickstein Shapiro Morin & Oshinsky LLP
1401 H Street, N.W., Suite 760
2101 L Street, N.W.
Washington, D.C. 20005
Washington, D.C. 20037-1526

* Designated for receipt of service