FERC Filings

EPSA's Request to File Out of Time and Comments on Entergy's ICT Proposal

Preface

Pursuant to Rule 212 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. §§ 385.212, the Electric Power Supply Association (EPSA) hereby moves to file out of time and comment in the above-captioned proceeding. On May 27, 2005, Entergy Services, Inc. (Entergy), acting for Entergy Operating Companies, submitted a filing to the Commission pursuant to Section 205 or the Federal Power Act (FPA).

EPSA submits that good cause exists to grant it leave to file out of time in the instant proceeding and requests that the Commission accept these comments. EPSA has intervened and commented on previous Entergy ICT matters and participated in a June 17, 2005, conference in New Orleans, which led to the instant proposal. The delay in filing these comments has been caused by the need for EPSA’s membership to reach consensus on the broad range of issues in the Entergy filing and on subsequent presentations. While EPSA encourages the Commission to approve the Entergy ICT proposal, EPSA members have serious concerns about various elements and have accepted the challenge to offer constructive criticism to several Entergy positions. Several EPSA member companies have been extensively engaged in the specific details of Entergy’s transmission pricing proposal, the Weekly Procurement Process (WPP) and the ICT proposal over the course of those proceedings, including member companies who joined in the filing submitted by the Generator Coalition. EPSA has worked to reconcile the views of its member companies and to analyze the Generator Coalition filing in order to identify sections of it that EPSA can endorse. EPSA’s late intervention would not prejudice or impose any undue burden on any party, or otherwise disrupt or delay this proceeding. Accordingly, EPSA respectfully submits that it has good cause for filing late in this proceeding.