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EPSA's Motion to Intervene and Comment in Support of Complaint to Implement Interim Reliability Capacity Services Tariff

Preface

Pursuant to Rules 211 and 214 of the Federal Energy Regulatory Commission’s (Commission) Rules of Practice and Procedure, 18 C.F.R. §§ 385.211 and .214 (2004), the Electric Power Supply Association (EPSA) hereby submits this Motion to Intervene and Comments in the above-captioned docket. On August 26, 2005, the Independent Energy Producers Association (IEP) filed a Complaint against the California Independent System Operator, Inc. (CAISO) in which it requests that the Commission issue an order directing the CAISO to eliminate the Must-Offer Obligation (MOO) upon implementation of an interim Reliability Capacity Services Tariff (RCST). In support of this motion, EPSA states as follows: