FERC Filings
MOTION FOR LEAVE TO INTERVENE AND COMMENT OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: ENTERGY SERVICES, INC.
MOTION TO INTERVENE
EPSA is the national trade association representing competitive power suppliers, including independent power producers, merchant generators and power marketers. These suppliers, who account for more than a third of the nation’s installed generating capacity, provide reliable and competitively priced electricity from environmentally responsible facilities serving global power markets. EPSA seeks to bring the benefits of competition to all power customers.
Many of EPSA’s members are authorized to sell energy and ancillary services at market-based rates. Certain EPSA members presently own, or are currently developing, generation projects in the Entergy control area or in adjacent regions that are deliverable to the Entergy control area, and EPSA has participated in many of the Commission’s ongoing proceedings on Entergy issues, including the numerous recent filings concerning Entergy’s Purchase Power Agreements (PPAs) with its affiliates. Accordingly, EPSA has a direct and substantial interest in the outcome of this proceeding that cannot be adequately represented by any other party.
All pleadings, correspondence and other communications concerning this proceeding should be directed to:
Julie Simon, Vice President of Policy
Michael Reddy, Policy/Research Coordinator
Electric Power Supply Association
1401 New York Avenue, N.W., 11th Floor
Washington, D.C. 20005
(202) 628-8200
EPSA’s fundamental concern is that the amendment to schedule MSS-4 might be used as a backstop to allow Entergy to implement the PPAs if the Commission denies market-based rate treatment for the PPAs, now pending in numerous other dockets in which EPSA has intervened or other cases Entergy may file. While the purpose of the filing is not clear, Entergy itself states that the amended schedule MSS-4 will “provide the basis for the sale of purchased power from one Operating Company to another.” The Commission must ensure that any amendment to MSS-4 not allow Entergy to circumvent FERC’s review of these affiliate transactions or any FERC decisions on these matters.