FERC Filings
MOTION TO INTERVENE AND COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON TRANSLINK'S PROPOSAL TO FORM AN INDEPENDENT TRANMISSION COMPANY
INTRODUCTION
Alliant Energy Services, Inc. et al.
Docket Nos. ER01-3154-000 and EC01-156-000
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Pursuant to Rules 214 and 212 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (FERC or Commission), 18 C.F.R. §§ 214 and 212, the Electric Power Supply Association (EPSA) hereby moves for leave to intervene and comments in the above-captioned proceeding.
Pursuant to Sections 203 and 205 of the Federal Power Act, the TRANSLink Participants filed a proposal to form an independent transmission company (ITC), TRANSLink Transmission Company LLC (TRANSLink), that will function as an ITC through which parties committing transmission assets may participate in one or more regional transmission organizations (RTOs). By a Notice issued October 5, 2001, the Commission set October 29, 2001 as the deadline for timely interventions and protests. However, as requested by the Iowa Association of Municipal Utilities on October 16, 2001, the Commission, in a Notice of Extension of Time dated October 24, 2001, set November 28, 2001 as the deadline for timely interventions and protests in this proceeding.
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.
Certain EPSA members presently participate in the TRANSLink markets, or are in the process of developing new generating projects in the TRANSLink service area. EPSA is interested in protecting the rights of these power suppliers to equal access to TRANSLink transmission facilities, as well as fair and nondiscriminatory pricing for these transmission services. Furthermore, many EPSA members are participants in various RTO markets in which the ITC proposes to participate, including the service areas of the Midwest Independent System Operator (MISO), the Southwest Power Pool (SPP), WestConnect RTO (WestConnect) and the Alliance RTO (ARTO). Accordingly, EPSA has a direct and substantial interest in the outcome of the instant proceedings, which cannot adequately be represented by any other party.
All pleadings, correspondence and other communications concerning the docket should be directed to:
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