FERC Filings

MOTION FOR LEAVE TO INTERVENE AND PROTEST:NYISO AMP AND CON ED LMM

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 AMP and Con Ed’s Revised LMM extension requests. Such repeated extensions and unnecessary layering of market control mechanisms are completely contrary to the needs of competitive markets.

Dated: October 19, 2001
Respectfully submitted,_/s/ Julie Simon_______________

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

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 19th day of October 2001.

_/s/ Julie Simon __________________

Julie Simon