FERC Filings

MOTION TO INTERVENE AND PROTEST OF EPSA, SOUTHWEST POWER POOL

I. MOTION TO INTERVENE

EPSA is the national trade association representing competitive power suppliers, including independent power producers, merchant generators and power marketers. EPSA members provide reliable, competitively priced electricity from environmentally responsible facilities in U.S. and global power markets. EPSA seeks to bring the benefits of competition to all power 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.<sup>2</sup>

Certain of EPSA's members are considering the development of generating projects in SPP's service territory that must interconnect to SPP's transmission system. EPSA is interested in facilitating the adoption of interconnection rules, procedures and agreements that, from a national perspective, are just and reasonable, 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
1. §§ 385.211 and 385.214.

2. The comments contained in this filing represent the position of EPSA as an organization, but not necessarily the view of any particular member with respect to any specific issue.