FERC Filings
REQUEST FOR REHEARING OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: AMEREN ENERGY GENERATING COMPANY AND UNION ELECTRIC COMPANY d/b/a AMERENUE
CONCLUSION
WHEREFORE, for the reasons set forth above, EPSA respectfully requests that the Commission grant its motion for rehearing, suspend the evidentiary hearing, and issue a deficiency letter designed to force Ameren to file a completed application. This is the most reasonable course to pursue prior to proceeding with an expensive and time consuming litigation.
June 4, 2003
Respectfully submitted,
_____________________________
Julie Simon, Vice President of Policy
Mark Bennett Senior Manager of Policy
Electric Power Supply Association
1401 New York Avenue, NW 11th Floor
Washington, D.C. 20005
Tel: 202-628-8200
Fax: 202-628-8260
and
Larry F. Eisenstat
Robert C. Fallon
Dickstein Shapiro Morin & Oshinsky, LLP
2101 L Street NW
Washington, DC 20037-1526
(202) 828-2224
ATTORNEYS FOR ELECTRIC POWER SUPPLY ASSOCIATION
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., June 4, 2003.
________________________
Julie Simon
