FERC Filings

MOTION OF THE ELECTRIC POWER SUPPLY ASSOCIATION FOR LEAVE TO INTERVENE AND PROTEST re: PJM INTERCONNECTION, L.L.C.

CONCLUSION

WHEREFORE, EPSA respectfully requests that the Commission grant its timely motion for leave to intervene, as set forth above. EPSA appreciates PJM efforts to revise its rules on transmission upgrades and submits the comments herein on the revisions for the Commission’s consideration. EPSA respectfully requests that the Commission require PJM to revise its filing to address the issues raised herein. Specifically, the Commission should direct revisions that: (1) require a broad stakeholder regional planning process that produces a more detailed filing rather than allowing PJM to be the sole authority over transmission upgrade decisions; (2) include, as part of the decision process, a cost causation analysis of transmission upgrades that determines the beneficiaries for specific transmission upgrades; and, (3) include the full range of supply and demand market-based solutions along with the transmission upgrade alternative in the decision to solve congestion needs.

April 21, 2003

Respectfully submitted,

_______________________
Julie Simon, Vice President of Policy
Jack Cashin, Senior Manager of Policy

Electric Power Supply Association
1401 New York Ave, NW
11th Floor
Washington, D.C. 20005

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., April 21, 2003.

__________________
Julie Simon