FERC Filings

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

CONCLUSION

WHEREFORE, EPSA respectfully requests that the Commission reject the SeTrans governance proposal, which does not satisfy Order No. 2000’s independence requirements. The Commission should require SeTrans to immediately implement procedures to allow meaningful stakeholder participation in developing necessary details regarding RTO structure, governance and operations, including development of a financial rights-based congestion management scheme similar to that developed in the Southeast RTO mediation proceeding.

December 21, 2001

Respectfully submitted,

/s/____________________________

Julie Simon, Vice President of Policy

Jack Cashin, Senior Manager of Policy

Electric Power Supply Association

1401 New York Avenue, NW 11th Floor

Washington, D.C. 20005

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 21st day of December, 2001.

/s/_____________________________
Julie Simon

• View Previous Section
• Back to Issue Menu