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FERC Filings

MOTION TO INTERVENE AND PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION -GridFlorida LLC, Florida Power & Light Co.,Florida Power Corporation,Tampa Electric Co.-Docket No. RT01-67-000

III. Conclusion

WHEREFORE, EPSA respectfully requests that the Commission (1) withhold its final review and determination of RTO status until the Applicants finalize the details of their proposal; (2) offer guidance on the governance and independence issues consistent with the concerns EPSA raised herein; (3) take all action it deems necessary and appropriate to establish a cross-RTO market design and policy entity consistent with EPSA’s comments; and (4) require the Applicants to utilize the resources of the Commisson’s ADR division in the continuation of the collaborative process.

Respectfully submitted,

Julie Simon, Vice President of Policy
Mark E. Bennett, Senior Manager of Policy
ELECTRIC POWER SUPPLY ASSOCIATION
1401 H Street, NW, Suite 760
Washington, D.C. 20005
202-789-7200

Dated: November 20, 2000