FERC Filings

MOTION TO PROTEST OUT OF TIME OF THE ELECTRIC POWER SUPPLY ASSOCIATION

INTRODUCTION

SeTrans RTO

Docket No. RT01-100-000

Docket No. RT01-77-000
Docket No. RT01-75-000

Pursuant to Rules 211 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. § 385.211, the Electric Power Supply Association (“EPSA”) hereby requests leave to protest one day out of time the Supplemental Status Report (“Supplemental Report”) filed by the SeTrans Participants on November 20, 2001 in the above-captioned proceeding.

Under the circumstances, EPSA submits that good cause exists to grant it leave to protest one day out of time. EPSA had several critical filings due on December 20, 2002, including a request for intervention, clarification and rehearing of the Commission’s November 20th Order on market-based rate tariffs and authorizations, as well as our comments on the Commission’s Affiliate code of conduct Notice of Proposed Rulemaking.

Additionally, EPSA had a long-planned off-site staff retreat on Thursday, December 20, 2002. As such EPSA’s protest one day out of time is in the public interest and should be granted.

In the Supplemental Report, the SeTrans Participants seek to (1) inform the Commission that Entergy has elected to participate in the SeTrans effort and (2) gain Commission approval of SeTrans’ newly-expanded geographic scope and revised governance structure.