FERC Filings

MOTION TO INTERVENE, PROTEST AND REQUEST FOR CONSOLIDATION OF THE ELECTRIC POWER SUPPLY ASSOCIATION-California Independent System Operator Corporation-Docket No. RT01-85-000;San Diego Gas & Electric Company-Docket No. RT01-82-000; Pacific Gas & Electric

I. MOTION TO INTERVENE

EPSA is the national trade association representing competitive power suppliers, including independent power producers, merchant generators and power marketers. EPSA members provide reliable, competitively priced electricity from environmentally-responsible facilities in U.S. and global power markets. EPSA seeks to bring the benefits of competition to all power customers.
Certain EPSA members presently participate in the power markets in the Western region of the United States, or are in the process of developing new generating projects in that area. EPSA is interested in protecting the rights of these power suppliers to equal access to transmission facilities in the region, as well as fair and nondiscriminatory pricing for these transmission services. Accordingly, EPSA has a direct and substantial interest in the outcome of the instant proceedings, which cannot adequately be represented by any other party. EPSA submits that good cause exists for granting this timely motion to intervene, and that its intervention is in the public interest, and should thus be granted.
All pleadings, correspondence and other communications concerning this proceeding should be directed to:

Julie Simon, Vice President of Policy
Erin Perrigo, Manager of Policy
Electric Power Supply Association
1401 New York Ave., N.W., 11th Floor
Washington, D.C. 20005
Tel:(202) 628-8200
Fax: (202) 628-8260

Michael J. Rustum
Dickstein Shapiro Morin & Oshinsky, LLP
2101 L Street, N.W.
Washington, D.C. 20037
Tel:(202) 785-9700
Fax:(202) 887-0689