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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

CONCLUSION

In light of the foregoing, IPPNY and EPSA respectfully request that the Commission reject Con Edison’s proposed revisions to the Mitigation Measures.

Respectfully submitted,

Julie Simon
Electric Power Supply Association
1401 New York Ave. NW
11th Floor
Washington, D.C. 20005

READ AND LANIADO, LLP
25 Eagle Street
Albany, New York 12207
Attorneys for
Independent Power Producers
of New York, Inc.

Dated:
April 4, 2001
Albany, New York.