FERC Filings
Calcasieu Generating Facility
Intervention in Entergy's Proposed Purchase of the Calcasieu Generating Facility (Docket No. EL07-48-000)
<center>UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION</center>
Entergy Services, Inc. ) Docket No. EL07-48-000
<center>MOTION OF THE ELECTRIC POWER SUPPLY ASSOCIATION
FOR LEAVE TO INTERVENE</center<>
Pursuant to Rule 214 of the Commission’s Rules of Practice and Procedure, the Electric Power Supply Association (EPSA) moves to intervene in the above-captioned proceeding.
On March 15, 2007, Entergy Services, Inc. ("Entergy Services"), on behalf of Entergy Operating Companies (collectively, "Entergy"), filed a petition for declaratory order addressing its proposed purchase of the Calcasieu Generating Facility. Entergy is requesting that the Commission find that where a resource has been determined by the Entergy Operating Committee to be devoted to serving system load under the System Agreement and has been approved by its retail regulator(s), such resource shall be a System Resource under the System Agreement and all costs of such facility, including the purchase price, shall be reflected in the applicable formula rates, subject to certain conditions. In the alternative, Entergy is requesting that the Commission determine that the agreement for Entergy Gulf States, Inc. to acquire the Calcasieu Generating Facility is prudent.
I. COMMUNICATIONS
Communications in connection with this filing should be addressed to:
Nancy Bagot Jack Cashin Vice President of Regulatory Policy Senior Manager of Policy Electric Power Supply Association Electric Power Supply Assoc. 1401 New York Ave, NW 1401 New York Ave, NW 11th Floor 11th Floor Washington, D.C. 20005 Washington, D.C. 20005
II. INTERVENTION
EPSA is the national trade association representing competitive power suppliers, including generators and marketers. EPSA is the national trade association representing competitive power suppliers, including generators and marketers. These suppliers, who account for 40 percent of the installed generating capacity in the United States, provide reliable and competitively priced electricity from environmentally responsible facilities serving power markets. EPSA seeks to bring the benefits of competition to all power customers.
EPSA members own or operate billions of dollars worth of assets, or otherwise do business, in the wholesale market in the Entergy region and, hence, have a direct interest in the matters raised by the Entergy Petition. Competitive suppliers represent some 21,300 MW of generation in the Entergy service territory. Entergy's system agreement impacts the utilization of its transmission system for serving native load, and thus impact the interest of EPSA companies that are transmission customers in the Entergy region. In addition, EPSA companies compete with Entergy's generating fleet to serve power customers in the region. Therefore, competitive suppliers have a direct interest in Entergy's procurement practices and market power, both of which are impacted by Entergy's petition that the Commission find Entergy's acquisition of the Calcasieu Generating facility as prudent. As a result, EPSA has a direct and substantial interest in the instant proceeding that cannot be adequately represented by any other party, and allowing EPSA to actively participate in this proceeding would be in the public interest. Accordingly, EPSA respectfully requests that the Commission grant this timely motion to intervene.
III. CONCLUSION
Wherefore, EPSA respectfully request that the Commission grant their timely motion to intervene and be made a party to this proceeding with all the rights pertaining thereto.
Respectfully submitted,
____________________________
Nancy Bagot, Vice President of Regulatory Policy
Jack Cashin, Senior Manager of Policy
Electric Power Supply Association
1401 New York Ave, NW
11th Floor
Washington, D.C. 20005
April 25, 2007
CERTIFICATE OF SERVICE
I hereby certify that I have served a copy of the comments by first class mail, postage prepaid, or via email upon each person designated on the official service list compiled by the Secretary in this proceeding.
Dated at Washington, D.C., April 25, 2007.
________________________
Mark Bennett, Esq.
EPSA for Leave to Intervene (Docket No. EL07-48-000).PDF