FERC Filings
MOTION TO INTERVENE AND PROTEST OF EPSA
I. MOTION TO INTERVENE
EPSA is the national trade association representing competitive power suppliers active in U.S. 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.<sup>4</sup>
Certain of EPSA's members presently are, or are in the process of, considering the development of new generating projects in Entergy's service territory which must interconnect to Entergy'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 which 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:
Lynne H. Church, Executive Director
Larry F. Eisenstat
*Julie Simon, Director of Policy
*Gretchen Schott
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. 18 C.F.R. §§ 385.211 and 385.214.
2. Entergy Transmittal Letter, at 11.
3. EPSA acknowledges the Commission's attention to the interconnection issue and appreciates the Commission's recent pronouncements and clarifications with respect to new interconnection. Nonetheless, all industry participants would benefit from a more comprehensive discussion of various interconnection issues.
4. 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.