FERC Filings
MOTION TO INTERVENE AND PROTEST OF EPSA
III. CONCLUSION
WHEREFORE, EPSA respectfully requests that it be permitted to intervene in, and be made a party to, this proceeding with all the rights appropriate to that status. EPSA also requests that the Commission issue a policy statement on interconnection consistent with EPSA's attached position paper. In addition, EPSA requests that the Commission facilitate an industry dialogue for the purposes of developing interconnection procedures and a model interconnection agreement for the Commission's consideration.
March 22, 2000
Respectfully submitted,
______________________________
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
Attorneys for the Electric Power Supply Association