FERC Filings

MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-PJM Interconnection, L.L.C., Allegheny Electric Cooperative, Inc., Atlantic City Electric Company, Baltimore Gas & Electric Company, Delmarva Power & Light Company, Jersey Central Power

I. MOTION TO INTERVENE

EPSA is the national trade association representing competitive power suppliers, including independent power producers, merchant generators and power marketers. EPSA members provide reliable, competitively priced electricity from environmentally-responsible facilities in U.S. and global power markets. EPSA seeks to bring the benefits of competition to all power customers.3

Certain EPSA members presently participate in PJM markets, or are in the process of developing new generating projects in PJM. EPSA is interested in protecting the rights of these power suppliers to equal access to transmission facilities, as well as fair and nondiscriminatory pricing for these transmission services. Accordingly, EPSA has a direct and substantial interest in the outcome of the instant proceedings which cannot adequately be represented by any other party. EPSA submits that good cause exists for granting this timely motion to intervene, and that its intervention is in the public interest, and should thus be granted.

All pleadings, correspondence and other communications concerning this proceeding should be directed to:

*Julie Simon, Vice President of Policy
Electric Power Supply Association

1401 H Street, N.W., Suite 760

Washington, D.C. 20005

Tel:(202) 789-7200
Fax:(202) 789-7201

Larry F. Eisenstat
*Michael J. Rustum
Dickstein Shapiro Morin& Oshinsky, LLP
2101 L Street, N.W.
Washington, D.C. 20037
Tel:(202) 785-9700
Fax:(202) 887-0689

*designated for receipt of service.1 Regional Transmission Organizations, III FERC Stats. and Regs., Regs. Preambles 31,089 (1999) (“Order No. 2000”); order on reh’g, III FERC Stats. and Regs., Regs. Preambles 31,092 (2000) (“Order No. 2000-A”).

2 Staff Report to the Federal Energy Regulatory Commission on the Bulk Power Markets In the United States, Part II, November 1, 2000, at 1-94.

3 The comments contained in this filing represent the position of EPSA as an organization, but not necessarily the view of any particular member with respect to any issue.