FERC Filings
MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION -Southwest Power Pool, Inc. - Docket No. RT01-34-000
III. CONCLUSION
WHEREFORE, for the reasons set forth above, EPSA respectfully requests the Commission to reject SPP’s proposed transition period for bundled retail and other grandfathered customers and to reinitiate a collaborative process to develop an alternative proposal. In addition, the Commission should condition any approval of the SPP RTO upon SPP further amending its proposal consistent with this protest so as to fully comply with Order No. 2000.
November 20, 2000
Respectfully submitted,
_______________________________
Julie Simon, Vice President of Policy
Electric Power Supply Association
1401 H Street, N.W., Suite 760
Washington, D.C. 20005
Larry F. Eisenstat
Michael J. Rustum
Dickstein Shapiro Morin & Oshinsky LLP
2101 L Street, N.W.
Washington, D.C. 20037-1526
Attorneys for the Electric Power Supply Association