FERC Filings

PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: NYISO AMP

INTRODUCTION

New York Independent System Operator, Inc.
Docket No. ER01-3155-000

Consolidated Edison Company of New York, Inc.
Docket No. ER01-1385-001 and
EL01-45-001

Pursuant to Rule 211 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. §§ 385.211 and the Secretary’s April 8, 2002, Notice of Extension of Time, the Electric Power Supply Association (EPSA) hereby files this protest in the above-captioned proceeding. On March 20, 2002, the New York Independent System Operator, Inc. (NYISO) filed with the Federal Energy Regulatory Commission (FERC or Commission) its proposal for comprehensive market power mitigation measures (Comprehensive Mitigation Measures or March 20th Filing). The NYISO’s proposed Comprehensive Mitigation Measures are intended to be a response to two Commission Orders issued on November 27, 2001, Order Approving Extension of Automatic Mitigation Procedures Subject to Conditions in Docket No. ER01-3155-000 and Order on Motions Requesting Extensions of the Revised Localized Mitigation Measures in Docket Nos. ER01-1385-001 and EL01-45-001.

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