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

III. Conclusion

WHEREFORE, the Commission should reject the NYISO's request for authority to implement bid caps in the NYISO-administered 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: July 13, 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