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MOTION FOR LEAVE TO INTERVENE AND PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: CITY OF BURBANK v. CALPINE ENERGY SERVICES, DUKE ENERGY TRADING AND MARKETING AND EL PASO MERCHANT ENERGY

INTRODUCTION

City of Burbank, California

Complainant,

v.

Calpine Energy Services, L.P.

Duke Energy Trading and Marketing, LLC,

El Paso Merchant Energy, L.P.

Respondents.

Docket No. EL02-117-000

Pursuant to Rules 211 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (FERC or Commission), 18 C.F.R. §§ 385.211 and 214, the Electric Power Supply Association (EPSA) hereby requests leave to intervene and protest the complaint filed in the above-captioned proceeding.