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

III. CONCLUSION

The CAISO asserts that once it complies with the December 15th Order, it will be an RTO compliant with Order No. 2000. As discussed above, there are substantial questions whether the CAISO will ever comply with the December 15th Order. The current CAISO does not meet the requirements of Order No. 2000, particularly on the core issues of governance and the size and scope of an RTO needed in the West. As such, much work needs to be done before the CAISO is transformed into an RTO under Order No. 2000. The Commission, therefore, should use this opportunity to give the CAISO clear guidance on these important issues.

February 22, 2001

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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