FERC Filings
MOTION OF THE ELECTRIC POWER SUPPLY ASSOCIATION FOR LEAVE TO INTERVENE, PROTEST AND CONSOLIDATE RELATED PROCEEDINGS FOR HEARING re: ENTERGY SERVICES, INC., EWO MARKETING, LP, ENTERGY POWER, INC.
INTRODUCTION
Entergy Services, Inc.
EWO Marketing, LP
Entergy Power, Inc.
Docket Nos.
ER03-681-000
ER03-682-000
ER03-583-000
(Not Consolidated)
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. §§ 212 and 214, the Electric Power Supply Association (EPSA) hereby moves for leave to intervene, protest and request consolidation for consideration and hearing of the three above-captioned applications by Entergy Services, Inc. (ESI). All three proceedings involve the transfer (via life-of-unit or long-term purchases) of energy and capacity among Entergy Corporation (Entergy) jurisdictional affiliates. EPSA previously intervened and protested in Docket No. ER03-583-000 (February 28 Application) on March 24, 2003.
In Docket Nos. ER03-681-000 and ER03-682-000 (collectively referred to as the March 31 Applications or Applications), ESI and Entergy Power, Inc. (EPI) have submitted applications for approval of four additional power purchase agreements (PPAs) collectively, each between ESI (as a representative of the Entergy Operating Companies) and EPI, or in two of the three PPAs in ER03-682-000, between various Entergy Operating Companies. In all four cases, the agreements have been entered into between two Entergy jurisdictional affiliates. Entergy is requesting approval for the PPAs, stating that the agreements meet the Commission’s standards for sales between affiliates because they are either the product of a request for proposals (RFP) that solicited and evaluated the purchase of capacity and energy from both affiliates and non-affiliates in an independent and unbiased manner, or they were “executed at price terms that are comparable with those for contemporaneous life-of-unit services bid into the Fall 2002 RFP.” Due to numerous concerns enumerated below, EPSA opposes Commission approval of the instant Applications as submitted and urges the Commission to consolidate and set for hearing all three PPA proceedings.