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MOTION OF EPSA FOR LEAVE TO INTERVENE AND PROTEST, NYISO

III. CONCLUSION

WHEREFORE, the Commission should reject the NYISO's request for authority to suspend the use of market-based bids for the 10-minute reserve markets.

EPSA respectfully requests leave to intervene in, and become a party to, this proceeding, and to be afforded all rights appropriate to that status.

Dated: April 10, 2000

Respectfully submitted,

_____________________________
Julie Simon, Director of Policy
Mark E. Bennett, Senior Manager of Policy
Electric Power Supply Association
1401 H Street, N.W., Suite 760
Washington, D.C. 20005

CERTIFICATE OF SERVICE

I hereby certify that I have served a copy of the foregoing document by first class United States mail, postage prepaid, upon each person designated on the official service list compiled by the Secretary in this proceeding.

Dated at Washington, D.C. this 10th day of April, 2000.

___________________________________
Julie Simon