FERC Filings
MOTION FOR LEAVE TO INTERVENE AND PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: SeTRANS PETITION
MOTION FOR LEAVE TO INTERVENE
Cleco Power LLC; Dalton Utilities (acting as Agent for the City of Dalton Georgia; Entergy Services, Inc. (acting as agent for Entergy Arkansas, Inc., Entergy Gulf States, Inc., Entergy Louisiana, Inc., Entergy Mississippi, Inc., and Entergy New Orleans, Inc.); Georgia Transmission Corporation; JEA (formerly Jacksonville Electric Authority); MEAG Power; Sam Rayburn G & T Electric Cooperative, Inc.; South Carolina Public Service Authority ("Santee Cooper"); South Mississippi Electric Power Association; Southern Company Services, Inc. (acting as agent for Alabama Power Company, Georgia Power Company, Gulf Power Company, Mississippi Power Company and Savannah Electric and Power Company); and the City of Tallahassee, Florida
Docket No. EL02-101-000
Pursuant to Rules 211, 212 and 214 of the Federal Energy Regulatory Commission’s (Commission or FERC) Rules of Practice and Procedure, the Electric Power Supply Association (EPSA) respectfully submits this motion for leave to intervene and protest the SeTrans Sponsors’ June 27, 2002 “Petition for Declaratory Order Concerning the Proposed SeTrans RTO” (Petition).
EPSA is the national trade association representing competitive power suppliers, including independent power producers, merchant generators and power marketers. These suppliers, who account for more than a third of the nation’s installed generating capacity, provide reliable and competitively priced electricity from environmentally responsible facilities serving global power markets. EPSA seeks to bring the benefits of competition to all power customers. As such, EPSA has a direct and substantial interest in the instant proceeding that cannot adequately be represented by any other party. Accordingly, EPSA submits that good cause exists for granting this timely motion to intervene and that its intervention is in the public interest, and should thus be granted.