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MOTION FOR LEAVE TO INTERVENE AND PROTEST RE: NYISO TEP BID CAP

INTERVENTION

All pleadings, correspondence and other communications concerning the docket 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

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. Many EPSA members are participants in the NYISO markets, do business in New York, and own, operate and construct generation facilities in New York and will be affected by the NYISO’s proposed continuation of bid caps and TEPs in this docket. Any single party, therefore, cannot adequately represent EPSA’s interest in this proceeding.
In a Notice issued September 12, 2001, the Commission set September 25, 2001, as the deadline for timely filed motions for leave to intervene or protests. EPSA hereby files this timely motion for leave to intervene and protest in this proceeding.