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COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION ON THE NEW ENGLAND ANSWER PROVIDING ADDITIONAL SUPPORT FOR APPLICATION OF "FIRST LEVEL MITIGATION" IN UNCONSTRAINED AREAS UNDER NEW ENGLAND SMD MITIGATION PLAN

CONCLUSION

WHEREFORE, EPSA requests that the Commission approve New England Market Rule 1 excluding the first level mitigation measure in unconstrained areas as proposed for the reasons discussed herein.

October 28, 2002

Respectfully submitted,
_____________________________
Julie Simon, Vice President of Policy
Nancy Bagot, Senior Manager of Policy
Electric Power Supply Association
1401 New York Ave, NW
11th Floor
Washington, D.C. 20005
Phone: 202-628-8200
Fax: 202-628-8260

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., October 28, 2002.

___________________
Julie Simon
Vice President of Policy