FERC Filings

MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Southern Company Services, Inc.-Docket No. RT00-77-000

III. CONCLUSION

WHEREFORE, EPSA respectfully requests that the Commission (1) reject the Southern RTO proposal as not conforming with Order No. 2000; (2) take whatever action it deems necessary and appropriate to establish a cross-RTO market design and policy entity; and (3) require Southern to collaborate with interested stakeholders through a Commission sponsored dispute resolution process for the purpose of establishing a fully compliant RTO proposal consistent with EPSA’s comments.

November 20, 2000
Respectfully submitted,

_______________________________
Lynne H. Church, President

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
Christopher C. O’Hara
Dickstein Shapiro Morin & Oshinsky LLP
2101 L Street, N.W.
Washington, D.C. 20037-1526
Attorneys for the Electric Power Supply Association

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