FERC Filings

MOTION TO INTERVENE AND PROTEST OF ELECTRIC POWER SUPPLY ASSOCIATION-Entergy Services, Inc.-Docket No. RT01-75-000

III. CONCLUSION

WHEREFORE, EPSA respectfully requests that the Commission reject this filing and direct Entergy to modify its Transco proposal in accordance with the points set forth herein. Specifically, the Commission should direct Entergy to restructure its transco proposal to minimize its autonomy and reinstate RTO checks and balances. Unless modified, the proposed structure could result in proliferation of different business practices within the same region, which could lead to a re-balkanization of the grid contrary to the spirit of Order No. 2000. Moreover, approvals of Entergy’s arrangement will establish a precedent for other binary RTO/transco proposals. It is important that the Commission establish an organizational and operational structure that advances, and does not hinder, the development of competitive power markets.

November 20, 2000

Respectfully submitted,

Julie Simon, Vice President of Policy
Erin Perrigo, Manager of Policy
Electric Power Supply Association
1401 H Street, N.W., Suite 760
Washington, D.C. 20005

Larry F. Eisenstat
Michael J. Rustum
Christopher C. O’Hara
Dickstein Shapiro Morin & Oshinsky LLP
2101 L Street, N.W.
Washington, D.C. 20037-1526

Attorneys for the Electric Power Supply Association

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