FERC Filings
PJM Market Monitor
Intervention in Show Cause Request on PJM'S Market Monitoring Unit (MMU) (Docket No. EL07-56-000)
<center>UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION</center>
| Allegheny Electric Cooperative, Inc. | ) | Docket No. EL07-56-000 |
| Borough of Chambersburg, Pennsylvania; | ) | |
| City and Towns of Hagerstown, Thurmont, | ) | |
| And Williamsport, Maryland; | ) | |
| District of Columbia Office of the People's | ) | |
| Counsel; Illinois Citizens Utility Board; | ) | |
| Indiana Office of Utility Consumer | ) | |
| Counsel; Maryland Office of People's | ) | |
| Counsel; New Jersey Division of Rate | ) | |
| Counsel; Office of the Attorney General of | ) | |
| Virginia, Division of Consumer Counsel; | ) | |
| Office Of the Ohio Consumer's Counsel; | ) | |
| Old Dominion Electric Cooperative; Pennsylvania | ) | |
| Office of Consumer Advocate; PJM Industrial | ) | |
| Customer Coalition; Southern Maryland | ) | |
| Electric Cooperative, Inc.; State of Delaware, | ) | |
| Division Of the Public Advocate | ) | |
| ) | ||
| v. | ) | |
| ) | ||
| PJM Interconnection, L.L.C. | ) |
<center>MOTION TO INTERVENE
OF THE ELECTRIC POWER SUPPLY ASSOCIATION</center>
Pursuant to Rules 211 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (FERC or Commission), the Electric
Power Supply Association (EPSA) respectfully moves to intervene in this proceeding. In their complaint, a number of state consumer advocates, public cooperatives and industrials (Joint Complainants) request that the Commission issue a Show Cause Order relating to market monitoring in PJM Interconnection, LLC and requiring related assurances from PJM that it has not violated, and will not violate, its tariff requirements pertaining to market monitoring.
I. MOTION TO INTERVENE
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 global power markets. EPSA seeks to bring the benefits of competition to all power customers.
Due to the significant investment made by EPSA members in the PJM region, EPSA and its members have been active participants in PJM proceedings before the Commission. Also, EPSA has a direct and substantial interest in the development of policy concerning market monitoring and regional market monitoring units, as such policy can affect the market and commercial activities of competitive power supplies. Accordingly, EPSA has a direct and substantial interest in the outcome of this proceeding that cannot be adequately represented by any other party.
All pleadings, correspondence and other communications concerning this proceeding should be directed to:
Nancy E. Bagot, Vice President of Regulatory Policy
Electric Power Supply Association
1401 New York Avenue, N.W., 11th Floor
Washington, D.C. 20005
(202) 628-8200
NancyB@epsa.org
II. Conclusion
WHEREFORE, EPSA respectfully requests that the Commission grant its timely motion for leave to intervene, as set forth above.
Respectfully Submitted,
_______________________________________
Nancy Bagot, Vice President of Regulatory Policy
Tara Ormond, Coordinator of Regulatory Policy
Electric Power Supply Association
1401 New York Avenue, NW, 11th Floor
Washington, DC 2000
(202) 628-8200
April 27, 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 27, 2007.
________________________
Mark Bennett, Esq.
Show Cause_PJM MM_MLI.pdf