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MOTION FOR EXTENSION OF TIME: STANDARDIZING GENERATOR INTERCONNECTION AGREEMENT AND PROCEDURES

BODY

The reasons for this request are twofold. First, the December 14th schedule clearly contemplated allowing parties two weeks from the filing of the documents until the comment deadline. However, since then, a plenary session has been scheduled for January 17th and 18th, which is designed to ensure that the parties fully understand the two documents, which comprise more than 300 pages. The goal is to minimize the filing of comments predicated on an inaccurate or incomplete understanding of the two documents. Thus, to develop comments that best serve the Commission’s needs and goals in the ANOPR, which is to narrow the outstanding issues in the NOPR process, parties in fact have considerably less time than originally contemplated to develop their comments. In addition, the time spent both in the plenary sessions and preparing for them significantly limits parties’ opportunity for developing meaningful comments.

Second, the week between the plenary sessions and the comment deadline has recently been filled with other important industry meetings. In a Notice issued last week, the Commission scheduled two days, January 22nd and 23rd, of public workshops on standard market design (SMD). In addition, a two-day, Commission-hosted meeting on reliability standards setting organizations has been scheduled for January 24th and 25th. For many in the industry, the personnel needed to meaningful participate in these important industry meetings are also needed to develop meaningful ANOPR comments. Because of this unexpected confluence of events, the undersigned respectfully request that the Commission extend the current deadline for ANOPR comments until Friday, February 1, 2002.