FERC Filings
MOTION FOR LEAVE TO INTERVENE AND PROTEST ONE DAY OUT-OF-TIME OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: MIDWEST INDEPENDENT TRANSMISSION SYSTEM OPERATOR, INC. AND AMERICAN TRANSMISSION COMPANY LLC
CONCLUSION
EPSA respectfully requests permission to intervene in and become a party to this proceeding, and be afforded all rights appropriate to that status. For the reasons discussed above, the Commission should closely consider Applicants’ request for such a broad limitation on liability. This proposal raises significant issues that require further consideration. For that reason, EPSA recommends that the Commission send this matter back to the Midwest ISO for further study in a stakeholder process. In the event, that the MISO and the stakeholders cannot agree, then EPSA recommends that the Commission hold a technical conference, prior to any further action, in order for the Commission to hear the views of a variety of interested parties on this important issue.
June 27, 2002
Respectfully submitted,
/s/Julie Simon via electronic filing
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., June 27, 2002.
/s/Julie Simon via electronic filing
Julie Simon