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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

CONCLUSION

In response to the CAISO’s MD02 filing, Filing Parties urge the Commission to: (1) require the CAISO to accelerate implementation of its proposal to put in place a LMP-based approach to congestion management, (2) reject the mitigation measures sought by the CAISO and adopt a workable approach to market mitigation outlined in EPSA’s principles, (3) decertify the CAISO Board and enforce prior orders requiring an independent Board, (4) take steps to ensure that all three western RTOs take the necessary steps, on a defined timetable, to create a single seamless market in the west, and (5) facilitate a week-long settlement conference for stakeholders to reach consensus on the many different, detailed technical elements of the CAISO’s proposed market redesign. The Commission’s focus should be on ensuring that meaningful action is taken to provide a market structure in California and the West that will encourage new investment, resolve outstanding problems and foster the creation of well-functioning robust energy markets for the West.

May 30, 2002

Respectfully submitted,

Julie Simon, Vice President of Policy
Nancy Bagot, Senior Manager 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 Hills, CA 91367

818) 596-2201

(818) 346-6502 (fax)

douglass@energyattorney.com

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., May 30, 2002.

__________________________
Julie Simon