FERC Filings

EPSA's Motion for Leave to Intervene Out of Time and Request for Clarification re: Midwest Independent Transmission System Operator Inc. and Ameren Services Co.

Motion to Intervene

EPSA is the national trade association representing competitive power suppliers, including generators and marketers. These suppliers, who account for nearly 40 percent of the installed generating capacity in the United States, 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, and are active participants in the PJM Interconnection and MISO markets. Accordingly, EPSA has a direct and substantial interest in the outcome of this proceeding that cannot be adequately represented by any other party.

Further, EPSA and its member companies have and continue to engage in Commission dockets involving matters having significant implications for the promotion of non-discriminatory transmission access and competitive power markets. The implementation of the Nov. 17 Order raises such issues. Accordingly, good cause exists to grant EPSA’s motion to intervene out of time. EPSA’s intervention will not prejudice any existing party or intervener, delay or otherwise disrupt this proceeding. Consistent with the Commission’s rules, EPSA will accept the record as it now exists.

All pleadings, correspondence and other communications concerning this proceeding should be directed to:

Julie Simon, Vice President of Policy
Mark Bennett, Senior Manager of Policy
Electric Power Supply Association
1401 New York Avenue, N.W., 11th Floor
Washington, D.C. 20005
(202) 628-8200