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

III. CONCLUSION

WHEREFORE, the Commission should rule on the PJM RTO proposal in a manner consistent with EPSA’s comments. As discussed above, EPSA urges the Commission, at the very least, not to approve PJM’s RTO application until the Commission can consider that application alongside the required filings from the New York and New England ISOs.

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
Geoffrey Bestor
Dickstein Shapiro Morin & Oshinsky, LLP
2101 L Street, N.W.
Washington, D.C. 20037

Attorneys for the Electric Power
Supply Association

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