FERC Filings

MOTION TO INTERVENE AND PROTEST OF INDEPENDENT POWER PRODUCERS OF NEW YORK, INC. AND ELECTRIC POWER SUPPLY ASSOCIATION-Consolidated Edison Company of New York, Inc.-Docket Nos. ER01-1385-000; EL01-45-000

III. MOTION TO INTERVENE

IPPNY is a not-for-profit trade association represent-ing the independent power industry in New York State. Its members include more than 100 companies involved in the development, operation, marketing and sale of electric power in New York. IPPNY's principal place of business is located at 291 Hudson Avenue, Albany, New York 12210. IPPNY’s members include generating facilities and power marketers that seek to compete in the NYISO’s administered markets and thus may be adversely affected by the Commission’s approval of Con Edison’s request to revise the Mitigation Measures.

EPSA is the national trade association representing competitive power suppliers active in the U.S. and global power markets. EPSA’s members, which include power generators, power marketers, and suppliers of goods and services in the electric power supply industry, share a commitment to bringing the benefits of competition to all electric customers.

IPPNY’s and EPSA’s intervention is in the public interest because the approval of the relief requested in Con Edison’s March 1 filing could discourage the development of critically needed generating capacity in the New York City region and decrease reliability during times of peak demand. Thus, IPPNY and EPSA, by and through their members, have a direct stake in the outcome of this proceeding and may be bound or adversely affected by the Commission’s final determination of this matter.

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