FERC Filings

EPSA's Motion For Leave to Protest Out of Time and Protest PJM Interconnection, LLC. Compliance Filing

PREFACE

Pursuant to Rule 211 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (FERC or Commission), 18 C.F.R. §§ 385.211, and the Commission’s July 21, 2004 Notice of Filing, the Electric Power Supply Association (EPSA) hereby requests leave to protest out of time in the above-captioned proceeding. EPSA is already a party to this proceeding, having filed an unopposed motion to intervene which was granted by the Commission on December 19, 2003. EPSA seeks leave to file the protest beyond the date specified by the Commission in its July 21, 2004 notice. EPSA has engaged economic consultants to prepare evidence responding to that offered by PJM in its filing. Due to the extensive review process necessary within an industry-wide trade association, the preparation of the attached affidavit could not be completed in a more compact timeframe. The evidence included in this filing and affidavit, however, addresses issues of mitigation and market power that are under consideration by the Commission in this proceeding and will inform or shape precedent for numerous markets. Thus, EPSA submits that these comments will assist the Commission in this matter. Furthermore, no party will be prejudiced by the acceptance of these comments given the slight delay. Accordingly, EPSA submits that good cause exists to grant this motion for leave to file a protest out of time.

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