FERC Filings

MOTION TO INTERVENE AND COMMENT OF THE ELECTRIC POWER SUPPLY ASSOCIATION-RTO West-Docket s No. RT01-35-000, RT01-15-000

Introduction

Pursuant to Rules 211 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. §§ 385.211 and 385.214, the Electric Power Supply Association (“EPSA”) hereby moves to Intervene in and Protests the above captioned proceedings, which in combination, represent the efforts to date to form a Regional Transmission Organization (“RTO”) in the Northwestern United States (hereinafter “RTO West”). Specifically, EPSA moves to intervene and comment in Docket No. RT01-35-000 to create RTO West and in Docket No. RT01-15-000 (hereinafter “TransConnect”), which creates TransConnect LLC, an independent transmission company, that will operate within RTO West and participate as a transmission owner in RTO West.
EPSA generally is pleased with the progress that RTO West has made, but believes the Commission should withhold a final determination of whether RTO West satisfies the requirements of Order No. 2000 until additional filings completed. EPSA addresses below the issues for which Commission guidance is warranted.

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