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MOTION FOR LEAVE TO INTERVENE AND COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION-New York Independent System Operator, Inc.-Docket No. ER01-2076-000

III. CONCLUSION

WHEREFORE, EPSA urges the Commission to reject the AMP Proposal filed by the NYISO. EPSA respectfully requests leave to intervene in, and become a party to, this proceeding, and to be afforded all rights appropriate to that status.

Dated: May 31, 2001

Respectfully submitted,

Julie Simon, Vice President of Policy
Erin N. Perrigo, Manager of Policy
Electric Power Supply Association
1401 New York Avenue, 11th Floor
Washington, DC 20005
(202) 628-8200