FERC Filings

EPSA's Motion to Intervene and Supplemental Comments on Alliant's Petition

Preface

Pursuant to Rules 211 and 214 of the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) Rules of Practice and Procedure, the Electric Power Supply Association (“EPSA”) respectfully moves to intervene and to comment on the Petition for Declaratory Order submitted in the above captioned proceeding. In its Petition, Alliant Energy Corporate Services, Inc., on behalf of Interstate Power and Light Company (“IPL”) and Wisconsin Power and Light Company (“WPL”) (collectively, “Alliant”), seeks a declaratory ruling that IPL and WPL shall not be required to enter into a new contract or obligation to purchase electric energy from a qualifying cogeneration facility or qualifying small power production facility (collectively, a “QF”). Alliant argues that IPL and WPL meet the requirements set forth in the recently-enacted § 210(m) of the Public Utility Regulatory Policies Act of 1978, as amended (“PURPA”), 16 U.S.C. § 824a-3(m). EPSA disagrees, and is a member of a group of interested organizations filing a concurrent protest to the Alliant petition as Joint Parties. In addition to that protest, EPSA herein moves to intervene as a party to the proceeding and includes additional comments to reflect our organization’s particular concerns that were not included in the common arguments set forth by the Joint Parties.

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