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MOTION FOR LEAVE TO INTERVENE AND PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION California Independent System Operator Corp. ) Docket No. L00-95-030

III. CONCLUSION

WHEREFORE, EPSA urges the Commission to reject the Amendment filed by the CAISO and instead enforce the provisions of its December 15th Order requiring the establishment of an independent CAISO Board.


EPSA respectfully requests leave to intervene in, and become a party to, this proceeding, and to be afforded all rights appropriate to that status.


May 24, 2001


Respectfully submitted,

Julie Simon, Vice President of Policy
ELECTRIC POWER SUPPLY ASSOCIATION
1401 New York Avenue, NW, 11th Floor
Washington, DC 20005
202-628-8200