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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.

INTRODUCTION

PJM Interconnection, L.L.C.

Docket No. EL01-122-001

Pursuant to Rules 211, 212, 214, and 713 of the Federal Energy Regulatory Commission’s (FERC or Commission) Rules of Practice and Procedure, 18 C.F.R. §§ 385.211, -.212, -.214, and -.713, the Electric Power Supply Association (EPSA) hereby files a “Motion to Intervene Out of Time, Request for Rehearing, and Motion for Limited Stay Pending Rehearing” (Motion) in this proceeding. In support of this Motion, EPSA states as follows: