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FERC Filings

MOTION TO INTERVENE AND PROTEST: WESTCONNECT

INTRODUCTION

Pursuant to Rules 211 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. §§ 385.211 and 385.214, the Electric Power Supply Association (“EPSA”) hereby requests leave to Intervene in and Protests the above-captioned proceeding regarding the request of Arizona Public Service Company, El Paso Electric Company, Public Service Company of New Mexico and Tucson Electric Power Company (collectively, the “Participating Transmission Owners” or “PTOs”) for a Declaratory Order from the Commission that their proposal to form WestConnect RTO, LLC (“WestConnect” or the “RTO”) meets the requirements set forth in Order No. 2000. The PTOs state that Salt River Project Agricultural Power and Improvement District, Western Area Power Administration and Southwest Transmission Power Cooperative, Inc. (“SWTC”) (collectively, the “Non-Jurisdictional Participants”) participated in WestConnect formation efforts.