FERC Filings

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

III. CONCLUSION

WHEREFORE, the Commission should rule on the RTO West filing in a manner consistent with EPSA’s comments. Specifically, the Commission should authorize the RTO West board, but not the TransConnect Board, and defer final rulings on all substantive issues until after Stage 2 filings are made. Moreover, the Commission should direct that the Stage 2 filings address the concerns and suggestions raised herein. Finally, the Commission should guard against potential balkanization of the Western market. Desert Star and RTO West are taking a similar approaches to RTO development. As such, FERC should direct these two entities to address seams issues in a manner that would allow
these and other entities, including the CAISO to move towards a unified regional market for the Western Interconnection.

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
Robert C. Fallon
Dickstein Shapiro Morin
& Oshinsky, LLP
2101 L Street, N.W.
Washington, D.C. 20037
Attorneys for the Electric Power
Supply Association

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