FERC Filings
Motion of EPSA for Leave to Intervene Out of Time and Comment on PJM Northern Illinois Control Area Mitigation
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. EPSA members have been active participants in PJM and EPSA has participated in many of the Commission’s ongoing proceedings on PJM issues. Accordingly, EPSA has a direct and substantial interest in the outcome of this proceeding that cannot be adequately represented by any other party.
EPSA and its member companies have and continue to engage in Commission proceedings that have significant implications for the promotion of competitive power markets, including the development of capacity markets. The PJM rehearing request and its application of the Commission’s Market Power Policy Order introduce factual material and policy arguments which were not before the Commission or the parties before the issuance of the March 24 Order. This additional material submitted by PJM raises several concerns that implicate national policy development and 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 intervenor, and will not delay or otherwise disrupt this proceeding, given the early stage of the 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
Nancy Bagot, Senior Manager of Policy
Electric Power Supply Association
1401 New York Avenue, N.W., 11th Floor
Washington, D.C. 20005
(202) 628-8200