FERC Filings

MOTION OF EPSA FOR LEAVE TO INTERVENE AND PROTEST OUT OF TIME IN OPPOSITION TO IMPLEMENT OF BID CAPS

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.

Many of EPSA's members are authorized to sell energy and ancillary services at market-based rates. EPSA members engage in numerous transactions within the New York markets and would be affected by the bid caps proposed by the NYISO. Accordingly, EPSA has a direct and substantial interest in the outcome of this proceeding that cannot be adequately represented by any other party. Further, good cause exists for allowing EPSA to intervene out of time. NYISO's filing on a Friday prior to a long holiday weekend created particular burdens on EPSA. As a national trade association, EPSA must give its members an opportunity to review the motion, which required a few more days than the expedited return date provided. EPSA's intervention at this time will not unduly delay or disrupt this matter, and the points raised herein will assist the Commission in its consideration of this important issue.

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