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MOTION FOR LEAVE TO INTERVENE AND PROTEST OUT OF TIME: SIERRA PACIFIC POWER V. CALPINE ENERGY SERVICES

CONCLUSION

WHEREFORE, EPSA respectfully requests that its leave to intervene in, and become a party to, this proceeding out of time be granted and that it be afforded all rights appropriate to that status. EPSA further urges the Commission to reject the Complaint filed by the Nevada Parties.

January 11, 2002

Respectfully submitted,

/S/_____________________________
Julie Simon, Vice President of Policy
ELECTRIC POWER SUPPLY ASSOCIATION
1401 New York Avenue, NW, 11th Floor
Washington, DC 20005
202-628-8200

CERTIFICATE OF SERVICE

I hereby certify that I have served a copy of the comments by first class mail, postage prepaid, upon each person designated on the official service list compiled by the Secretary in this proceeding.

Dated at Washington, D.C., January 11, 2002.

/S/__________________

Julie Simon