FERC Filings
MOTION FOR LEAVE TO INTERVENE AND PROTEST OUT OF TIME: SIERRA PACIFIC POWER V. BP ENERGY
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.
Many of EPSA’s members are authorized to sell energy and ancillary services at market-based rates. EPSA members have been active participants in the California markets and the Western markets. EPSA has participated in many of the Commission’s ongoing proceedings on California issues. Accordingly, EPSA has a direct and substantial interest in the outcome of this proceeding that cannot be adequately represented by any other party.
All pleadings, correspondence and other communications concerning this proceeding should be directed to:
Julie Simon, Vice President of Policy
Electric Power Supply Association
1401 New York Avenue, N.W., 11th Floor
Washington, D.C. 20005
(202) 628-8200
Under the circumstances, EPSA submits that good cause exists to grant it leave to Intervene and Protest out of time. First, EPSA’s request is required by the press of other business. The Commission’s agenda is extremely full. Indeed, EPSA has made several critical filings in recent weeks, in addition to participating actively in the ANOPR on generator interconnection. Second, the Nevada Companies’ complaint is related to nine other complaints that needed to be reviewed prior to filing this protest. Third, EPSA’s Motion is out of time by only a few weeks owing to the holiday season, no substantive decisions have been entered in the case, and EPSA will accept the record developed to date. Fourth, as the national voice of the competitive supply industry, EPSA represents a broad perspective on the issues now before the Commission that will enhance the Commission’s decision making in this proceeding. Thus, EPSA’s Motion to intervene and protest out of time is in the public interest and should be granted.