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MOTION FOR LEAVE TO INTERVENE AND PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION AND THE WESTERN POWER TRADING FORUM ON THE COMPREHENSIVE MARKET DESIGN PROPOSAL OF THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR

MOTION TO INTERVENE

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. 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 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.

WPTF is a California non-profit, mutual benefit corporation. 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 utilities and a power exchange, all of which are active participants in the restructured California electricity market.

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
jsimon@epsa.org

Daniel W. Douglass
Law Offices of Daniel W. Douglass
5959 Topanga Canyon Blvd., Suite 244Woodland Hills, CA 91367
(818) 596-2201
(818) 346-6502 (fax)
douglass@energyattorney.com