FERC Filings

MOTION TO INTERVENE AND COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON TRANSLINK'S PROPOSAL TO FORM AN INDEPENDENT TRANMISSION COMPANY

CONCLUSION

WHEREFORE, it is clear that the TRANSLink proposal fails on the Commission’s independence requirement and several other aspects of Order No. 2000, including tariff administration and design and congestion management. Additionally the proposal attempts to preempt other Order No. 2000 functions such as operational authority, ancillary services and planning and expansion without sufficient deference to the authorities and responsibilities of the MISO. Balancing itself between two RTOs, TRANSLink’s proposes to add inefficient layers in an emerging regional market. The Commission should make sure that the ITC sufficiently complies with its requirements in order to ensure equal and nondiscriminatory treatment of all users of the grid on an equal basis. EPSA respectfully requests leave to intervene in, and become a party to, this proceeding, and to be afforded all rights appropriate to that status.

Dated: November 28, 2001

Respectfully submitted,

/S/___________________________
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 28th day of November, 2001.

/S/_________________________________
Julie Simon