FERC Filings

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

CONCLUSION

EPSA respectfully requests leave to intervene in, and become a party to, this proceeding, and to be afforded all rights appropriate to that status. As discussed above, EPSA respectfully urges the Commission to reject the NYISO’s TEP and bid cap extension requests. Such mechanisms are counterproductive in establishing competitive and efficient wholesale electric markets, and should not be made a permanent feature of the New York markets.

Dated: September 25, 2001
Respectfully submitted,_____________________________

Julie Simon, Vice President of PolicyErin N. Perrigo, Manager of PolicyElectric Power Supply Association1401 New York Avenue, 11th FloorWashington, DC 20005(202) 628-8200


CERTIFICATE OF SERVICE

I hereby certify that I have served a copy of the foregoing document by first class United States mail, postage prepaid, upon each person designated on the official service list compiled by the Secretary in this proceeding.
Dated at Washington, D.C. this 25th day of September, 2001.

___________________________________
Julie Simon

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