FERC Filings
MOTION TO INTERVENE AND PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION AND THE WESTERN POWER TRADING FORUM re: STATE OF CALIFORNIA REFUND REQUESTS THROUGH ITS ATTORNEY GENERAL
MOTION TO INTERVENE
EPSA and WPTF are joining together in this motion to intervene and protest to provide the Commission with a unified voice as trade associations actively representing the interests of suppliers at the national and regional levels. The breadth of the Joint Parties’ interests are described as follows:
EPSA is the national trade association representing competitive power suppliers, including independent power producers, merchant generators and power marketers. These suppliers, who account for more than a third of the nation’s installed generating capacity, provide reliable and competitively priced electricity from environmentally responsible facilities serving global power markets. EPSA seeks to bring the benefits of competition to all power customers.
WPTF is a California non-profit, mutual benefit organization. It is a broadly based membership organization dedicated to enhancing competition in Western electric markets in order to reduce the cost of electricity to consumers throughout the region while maintaining the current high level of system reliability. WPTF actions are focused on supporting development of competitive electricity markets throughout the region and developing uniform operating rules to facilitate transactions among market participants. WPTF provides a voice through which members can influence the development of market structures throughout the region. The membership of WPTF includes energy service providers, scheduling coordinators, generators, municipal utlilities and a power exchange, all of which are active participants in the restructured California electricity market.
Many of the Joint Parties’ members are authorized to sell energy and ancillary services at market-based rates. They have been active participants in the California markets and the Western markets and the Joint Parties have participated in many of the Commission’s ongoing proceedings on California issues. Accordingly, the Joint Parties have 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 Ave, N.W., 11th Floor
Washington, D.C. 20005
(202) 628-8200
Robert Fallon
Dickstein Shapiro Morin & Oshinsky LLP
2101 L Street, N.W.
Washington, D.C. 20037
(202) 785-9700
Daniel W. Douglass
Law Offices of Daniel W. Douglass
5959 Topanga Canyon Blvd, Suite 244
Woodland Hills, CA 91367
(818) 596-2201
