FERC Filings

MOTION TO INTERVENE OUT OF TIME, REQUEST FOR REHEARING, AND MOTION FOR LIMITED STAY PENDING REHEARING OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: PJM INTERCONNECTION, L.L.C.

REQUEST FOR RELIEF

For the foregoing reasons, EPSA requests that the Commission grant the following relief: (1) grant EPSA’s motion to intervene out of time; (2) grant rehearing of the May 15th Order; and (3) issue a stay of the portion of the May 15th Order accepting the revisions to the MMP pending rehearing and discussions of issues in a stakeholder process.

Dated: June 14, 2002

Respectfully submitted,

/S/___________________________

Julie Simon, Vice President of Policy
Nancy Bagot, Sr. Manager of Policy
Electric Power Supply Association
1401 New York Avenue, 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., June 14, 2002.

/S/______________________

Julie Simon

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