FERC Filings

REQUEST TO FILE ANSWER OUT OF TIME AND ANSWER OF THE ELECTRIC POWER SUPPLY ASSOCIATION IN SUPPORT OF MOTION OF THE INDEPENDENT ENERGY PRODUCERS ASSOCIATION TO PRECLUDE THE USE OF CERTAIN OUTSIDE EXPERTS

CONCLUSION

It is critically important that the final report in this investigation be free of unnecessary controversy and distraction. The Commission has an obligation to provide a final report that is an important step in restoring confidence in today’s energy markets. Using consultants with preconceived opinions, closely tied to market participants, will simply not further that important goal. The Commission can conduct a thorough and complete investigation, and fulfill the substantial responsibilities it has to the public, without consultants that have ongoing relationships with interested parties, who have pre-established opinions and biases or otherwise fail to satisfy the minimum requirements of impartiality and objectivity. Accordingly, EPSA joins with IEP and El Paso in requesting that all persons associated with the Analysis Group be precluded from participating in the instant investigation.

June 4, 2002



Respectfully submitted,

/S/

Julie Simon, Vice President of Policy
Mark Bennett, Senior Manager of Policy
Electric Power Supply Association
1401 New York Avenue, NW
11th Floor
Washington, DC 20005
(202) 628-8200

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