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MOTION FOR LEAVE TO INTERVENE AND PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: PUBLIC UTILITY DISTRICT NO. 1 OF SNOHOMISH COUNTY V. MORGAN STANLEY CAPITAL GROUP, INC.

CONCLUSION

WHEREFORE, EPSA respectfully requests that its leave to intervene in, and become a party to, this proceeding be granted and that it be afforded all rights appropriate to that status. EPSA further urges the Commission to reject the Complaint filed by Snohomish.

March 4, 2002

Respectfully submitted,

/S/_____________________________
Julie Simon, Vice President of Policy
ELECTRIC POWER SUPPLY ASSOCIATION
1401 New York Avenue, NW, 11th Floor
Washington, DC 20005
202-628-8200

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., March 4, 2002.

/S/__________________

Julie Simon