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MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Desert STAR, Inc.-Docket No. RT01-44-000

III. CONCLUSION

EPSA appreciates the significant and sustained effort that the participants in the DSTAR process have devoted to the creation of an RTO. Nevertheless, there remain several significant issues that the filing entities will have to address in meeting their commitment to make an RTO filing by the end of the year. EPSA notes, as it has above, that some of the basic RTO issues still remain. Guidance from the Commission would be helpful to the appropriate resolution of those issues.
WHEREFORE, the Commission should rule on the DSTAR filing in a manner consistent with EPSA’s comments.

November 20, 2000

Respectfully submitted,

_____________________________

Julie Simon, Vice President of Policy
Erin Perrigo, Manager of Policy
Electric Power Supply Association
1401 H Street, N.W., Suite 760
Washington, D.C. 20005

Larry F. Eisenstat
Michael J. Rustum
Geoffrey Bestor
Dickstein Shapiro Morin & Oshinsky, LLP
2101 L Street, N.W.
Washington, D.C. 20037

Attorneys for the Electric Power
Supply Association