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

Conclusion

WHEREFORE, EPSA respectfully requests that the Commission grant its motion to intervene and it be made a party to this proceeding with all the rights attendant thereto. EPSA also respectfully requests that the Commission approve the IEP RCST proposal for the reasons set forth above and in the IEP Complaint and that the Commission should convene a technical conference to resolve implementation issues associated with the RCST once it has been approved.

Respectfully submitted,

Nancy Bagot, Vice President of Regulatory Policy
Electric Power Supply Association
1401 New York Ave, NW
11th Floor
Washington, D.C. 20005
Phone: 202-628-8200