FERC Filings

MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-New York Independent System Operator, Inc, Central Hudson Gas & Electric Corporation,Consolidated Edison Company of New York, Inc., New York State Electric & Gas Corporation, Niagara Mo

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.

Certain EPSA members presently participate in NYISO markets, or are in the process of developing new generating projects in NYISO. 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:

Erin Perrigo, Manager of Policy

Michael J. Rustum
Electric Power Supply Association
Dickstein Shapiro Morin & Oshinsky, LLP
1401 New York Ave., N.W., 11th Floor
Washington, D.C. 20005
2101 L Street, N.W.
Tel:(202) 628-8200

Washington, D.C. 20037
Fax:(202) 628-8260

Tel:(202) 861-9178
Fax:(202) 887-0689