FERC Filings

COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION IN SUPPORT OF THE CALIFORNIA COGENERATION COUNCIL MOTION FOR EMERGENCY RELIEF AND MOTION TO INTERVENE AND COMMENTS IN SUPPORT OF THE CALIFORNIA COGENERATION COUNCIL PETITION FOR PURPA ENFORCEMENT-Removin

2. Docket No. EL01-64-000

EPSA also supports the CCC Petition for an enforcement action. The March 27th decision of the CPUC violates PURPA because it implements PURPA in a manner that is inconsistent with the Commission’s regulations. The Decision specifies a Short Run Avoided Cost (SRAC) formula that fails to allow QFs to fully recover their avoided costs, and which discriminates against QFs and is not in the public interest.

Pursuant to Rule 214 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. 385.214, EPSA hereby moves for leave to intervene in support of CCC’s Petition. As noted above, EPSA is the national trade association representing competitive power suppliers, including QFs, 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. EPSA has been an active participant in the Commission’s proceedings on California. Therefore, EPSA has a direct and substantial interest in the issue presented in this proceeding that cannot be represented by any other party.

All pleadings, correspondence and other communications concerning the docket should be directed to:

Julie Simon, Vice President 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

Respectfully submitted,

Julie Simon, Vice President of Policy
ELECTRIC POWER SUPPLY ASSOCIATION
1401 New York Avenue, NW
Washington, D.C. 20005
(202) 628-8200