FERC Filings

MOTION TO INTERVENE OF THE ELECTRIC POWER SUPPLY ASSOCIATION IN SUPPORT OF INDEPENDENT POWER PRODUCERS OF NEW YORK FILING

INTRODUCTION

New York Independent System Operator, Inc.

Docket No. ER03-647-000

Pursuant to Rules 212 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (FERC or Commission), 18 C.F.R. § 385.212 and 385.214, the Electric Power Supply Association (EPSA) respectfully files this motion for leave to intervene in the above-captioned proceeding. On March 21, 2003, the New York Independent System Operator, Inc. (NYISO) filed proposed revisions to its Market Administration and Control Area Services Tariff (Tariff) to implement an installed capacity (ICAP) demand curve (DC Proposal) in the ICAP unforced capacity market in New York (March 21 filing). On March 25, 2003, the Commission issued a notice setting April 11, 2003 as the deadline for filing interventions and protests in this proceeding.

EPSA supports the NYISO’s proposal to implement an ICAP market based on a demand curve in New York and reiterates the support and comments contained in the Independent Power Producers’ of New York (IPPNY) filing in this proceeding. We agree with IPPNY’s assertion that the DC Proposal properly responds to concerns that the current NYISO’s ICAP market is significantly flawed and requires a redesigned ICAP market to sustain existing generation and to encourage the development of much-needed new generation. Given the market situation in New York, EPSA agrees that the NYISO proposal is a proper and sound solution. Additionally, EPSA supports the NYISO’s request for expedited review of its March 21 filing to permit an effective date of May 21, 2003.

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