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

CONCLUSION

For the reasons set forth above, the Commission should promptly reject the Attorney General’s complaint to relitigate issues already decided and focus its scarce resources on improving the California market. Those efforts should include completing comprehensive market reform in California, addressing the lack of independence of the California ISO Board, and facilitating RTO development, not only in California, but the rest of the West.

April 9, 2002

Respectfully submitted,

/S/

Larry F. Eisenstat
Mark Perlis
Robert Fallon
Dickstein Shapiro Morin & Oshinsky LLP
2101 L Street, N.W.
Washington, D.C. 20037
(202) 785-9700

/S/

Julie Simon, Vice President of Policy
Electric Power Supply Association

1401 New York Avenue, NW
11th Floor
Washington, DC 20005
(202) 628-8200

/S/_____________________________
Daniel W. Douglass
Law Offices of Daniel W. Douglass
5959 Topanga Canyon Blvd, Suite 244
Woodland Hill, CA 91367
(818) 596-2201
Attorneys for the Western Power Trading Forum

CERTIFICATE OF SERVICE

I hereby certify that I have served a copy of the comments by first class mail, postage prepaid, upon each person designated on the official service list compiled by the Secretary in this proceeding.

Dated at Washington, D.C., April 9, 2002.

/S/

Julie Simon