FERC Filings
EPSA Motion to Intervene Out of Time on AES Ocean Express LLC v. Florida Gas Transmission Co.
II. 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.
On April 5, 2004, AES Ocean Express, LLC (AES) filed a complaint against Florida Gas Transmission Company (FGT) in this docket, seeking relief from certain pipeline interconnection requirements demanded by FGT related to certain facilities meant to deliver regasified liquefied natural gas (LNG) into FGT’s system. Subsequent to the filing of answers, and other pleadings by various parties in this proceeding, the Commission issued an order on June 18, 2004 (Order on Complaint). The Order on Complaint required, among other things, FGT to submit a tariff filing within 30 days addressing gas quality issues.
Many of EPSA’s members are considering regasified LNG as a viable alternative of fuel sourcing their gas-fired electric generating units. Accordingly, EPSA has a direct and substantial interest in the outcome of this proceeding that cannot be adequately represented by any other party.
EPSA is filing this intervention out of time. EPSA submits that good cause exists for the late intervention. The rulings made by the Commission in this proceeding could impact LNG-related gas quality and interchangeability issues throughout the industry. As many of its members are potential consumers of regasified LNG, EPSA should be given the opportunity to participate in this proceeding so that its members’ interests may be adequately represented. EPSA also seeks the right to comment on the tariff filing FGT has been directed to make by the Commission. EPSA will accept the record in this proceeding as it stands, and accordingly, its intervention out of time will not delay this proceeding nor prejudice any other party.