FERC Filings

EPSA's Motion to Intervene Out of Time and Comment on MISO's Compliance Filing to Add Attachments

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.

EPSA submits that good cause exists for this late intervention. The holiday week preceding the November 29 filing deadline, and the attention required on other MISO-related issues, unavoidably delayed review and finalization of these comments. That said, many of EPSA’s members are authorized to sell energy and ancillary services in the Midwest. Certain EPSA members presently own, or are currently developing, generating projects in the Midwest service area or in adjacent regions. Those members would be subject to requests involving emergency redispatch and outage rescheduling. These comments will assist the Commission in assessing MISO’s compliance filing. Accordingly, EPSA has a direct and substantial interest in the outcome of this proceeding that cannot be adequately represented by any other party. No party will be prejudiced by this late intervention given the early stage of MISO’s compliance effort. Accordingly, EPSA’s late intervention should be granted

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

John K. Hawks, Acting Vice President of Policy
Mark Bennett, Director of Policy
Electric Power Supply Association
1401 New York Avenue, N.W., 11th Floor
Washington, D.C. 20005
(202) 628-8200