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FERC Filings

MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION -Southwest Power Pool, Inc. - Docket No. RT01-34-000

II. PROTEST

As stated above, EPSA generally approves of the efforts made by SPP to comply with the RTO Orders. As a general matter, the SPP RTO proposal shows a commitment to meeting the requirements of the RTO Orders. Nevertheless, because the SPP proposal fails to tackle a number of tough issues required for compliance with the RTO Orders, EPSA must protest those aspects of the SPP proposal. EPSA urges the Commission to condition any approval of the SPP RTO upon SPP further amending its proposal consistent with Order No. 2000.