FERC Filings

MOTION TO INTERVENE AND PROTEST: WESTCONNECT

MOTION TO INTERVENE

EPSA is the national trade association representing competitive power suppliers, including independent power producers, merchant generators and power marketers. EPSA members provide reliable, competitively priced electricity from environmentally-responsible facilities in U.S. and global power markets. EPSA seeks to bring the benefits of competition to all power customers.

Certain EPSA members presently participate in the WestConnect markets, or are in the process of developing new generating projects in the WestConnect service area. EPSA is interested in protecting the rights of these power suppliers to equal access to WestConnect transmission facilities, as well as fair and nondiscriminatory pricing for these transmission services.

Accordingly, EPSA has a direct and substantial interest in the outcome of the instant proceedings, which cannot adequately be represented by any other party. EPSA submits that good cause exists for granting this timely motion to intervene, and that its intervention is in the public interest, and should be granted.

All pleadings, correspondence and other communications concerning this proceeding should be directed to:

Erin Perrigo, Manager of Policy
Electric Power Supply Association
1401 New York Avenue, N.W., 11th Floor
Washington, D.C. 20005
Tel:
(202) 789-7200
Fax:
(202) 789-7201

Frederick D. Ochsenhirt
Dickstein Shapiro Morin & Oshinsky LLP
2101 L Street, NW
Washington, DC 20037
Tel: 202-861-9161
Fax: 202-887-0689
OchsenhirtF@dsmo.com