FERC Filings

Motion for Leave to Intervene and Protest of EPSA re: PJM Interconnection, LLC

Conclusion

WHEREFORE, EPSA respectfully requests that its motion for leave to intervene in, and become a party to, this proceeding be granted and that it be afforded all rights appropriate to that status. EPSA further moves that the Commission dismiss without prejudice the PJM proposal to modify its local market rules for the reasons discussed herein. Rather, FERC should convene a technical conference to allow all parties participation in a comprehensive discussion of any and all local market power proposals and how such proposals may work within the PJM market. Following the technical conference, PJM should file a new proposal by December 31, 2003.

October 30, 2003

Respectfully submitted,

Julie Simon, Vice President of Policy
Nancy Bagot, Senior Manager of Policy
Electric Power Supply Association
1401 New York Avenue, NW, 11th Floor
Washington, DC 20005
202-628-8200

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., October 30, 2003.


________________
Julie Simon

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