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FERC Filings

MOTION TO INTERVENE OUT OF TIME OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: NORTHERN NATURAL GAS COMPANY

INTRODUCTION

Northern Natural Gas Company

Docket No. GT02-38-000

This Motion to Intervene Out of Time is filed by the Electric Power Supply Association (EPSA) pursuant to Rules 211 and 214 of the Federal Energy Regulatory Commission’s (Commission or FERC) Rules of Practice and Procedure, 18 C.F.R. §§ 385.211 and 214 (2001), and is in response to the Order issued on September 20, 2002 in the above-referenced docket. EPSA asks that its Motion to Intervene out of time be granted and be acted upon favorably for the reasons set forth below.