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FERC Filings

MOTION OF EPSA FOR LEAVE TO INTERVENE, NSTAR SERVICE CO.

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.<sup>1</sup>

Many of EPSA's members are authorized to sell energy and ancillary services at market-based rates. Given that EPSA members are engaged in numerous transactions within the New England markets and, therefore, will be affected by the price caps sought by NSTAR, 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