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EPSA Comments on the Feb. 4 Reposne of the PJM Interconnection to the FERC Deficiency Notice

Preface

Pursuant to Rule 211 of the Federal Energy Regulatory Commission's (Commission) Rules of Practice and Procedure (18 C.F.R. § 385.211), the Electric Power Supply Association (EPSA) hereby comments on the February 4, 2005 Response of PJM Interconnection, L.L.C. (PJM) to the Commission's Deficiency Notice filed in Docket No. ER04-539-007 (February 4 Filing). The outcome of the Section 206 investigation in Docket Nos. EL03-236-001, et al. regarding the justness and reasonableness of the three pivotal suppliers test must be applied to the Commission's analysis of the February 4 Filing regarding whether certain constraints should be exempted from offer capping.