FERC Filings
MOTION FOR LEAVE TO INTERVENE AND PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: KROGER CO. V. DYNEGY POWER MARKETING, INC.
CONCLUSION
WHEREFORE, EPSA respectfully requests that its motion for leave to intervene in, and become a party to, this proceeding be granted and that it be afforded all rights appropriate to that status. EPSA further urges the Commission to reject the Complaint filed by Kroger.
September 18, 2002
Respectfully submitted,
/S/___________________________
Julie Simon, Vice President of Policy
Nancy Bagot, Senior Manager 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., September 18, 2002.
/S/__________________
Julie Simon