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MOTION FOR LEAVE TO INTERVENE AND PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: SeTRANS PETITION

CONCLUSION

WHEREFORE, EPSA respectfully requests that the Commission grant its motion for leave to intervene and, further, reject the SeTrans governance/business model proposal given that it does not satisfy Order No. 2000’s independence requirements. Additionally, EPSA requests that the Commission require SeTrans to immediately implement procedures to allow meaningful Stakeholder participation in developing necessary details for the establishment of an independent board that will ensure a structure that meets the Order No. 2000 independence requirements. Lastly, the Commission should direct SeTrans Sponsors to reconsider their proposals for the treatment of grandfathered contracts, FTRs, and interconnection rules, so as not to further inhibit the realization of a competitive energy market in the Southeast. At a minimum, the Commission must ensure that these proposals do not preempt, but rather adopt, the Commission’s SMD and generation interconnection final rules.

August 5, 2002

Respectfully submitted,

/S/____________________________

Julie Simon, Vice President of Policy

Jack Cashin, Senior Manager of Policy

Electric Power Supply Association

1401 New York Avenue, NW 11th Floor

Washington, D.C. 20005

202-628-8200

CERTIFICATE OF SERVICE

I hereby certify that I have served a copy of the foregoing document by first class United States mail, postage prepaid, upon each person designated on the official service list compiled by the Secretary in this proceeding.

Dated at Washington, D.C. this 5th day of August, 2002.

/S/_____________________________
Julie Simon