FERC Filings

MOTION OF EPSA FOR LEAVE TO INTERVENE, SKYGEN ENERGY

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 bringing the benefits of competition to all electricity customers. Using a broad spectrum of fossil-fuel and renewable technologies, EPSA members generate reliable, competitively priced electricity, steam and other forms of useful energy from environmentally-responsible facilities.

EPSA members are engaged in the construction of merchant generating facilities across the country, including within Southern's service territories. The allegations raised by SkyGen have significant implications for other project developers. Thus, EPSA has a direct and substantial interest in the outcome of this proceeding that cannot be adequately represented by any other party.

All pleadings, correspondence and other communications concerning this proceeding should be directed to:

Julie Simon, Director of Policy

Mark Bennett, Senior Manager of Policy

Electric Power Supply Association

1401 H Street, N.W., Suite 760

Washington, D.C. 20005