FERC Filings
PJM Market Monitor
Intervention in PJM's Market Monitoring Unit (MMU) Complaint Proceeding (Docket No. EL07-58-000)
<center>UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION</center>
| Organization of PJM States, Inc.; | ) | |
| District of Columbia Public Service | ) | |
| Commission; Indiana Utility | ) | |
| Regulatory Commission; Kentucky | ) | |
| Public Service Commission; | ) | Docket No. EL07-58-000 |
| Maryland Public Service | ) | |
| Commission; New Jersey Board of | ) | |
| Public Utilities; North Carolina | ) | |
| Utilities Commission; Pennsylvania | ) | |
| Public Utility Commission; and the | ) | |
| Virginia State Corporation | ) | |
| Commission | ) | |
| ) | ||
| 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, the Organization of PJM States and a number of state public service commissions (Joint Complainants) request that the Commission order PJM to ensure the independence of its Market Monitoring Unit (MMU) with respect to funding, infrastructure and staffing levels. In addition, the complaint asks FERC to direct the amendment of PJM's Market Monitoring Plan to remove PJM management from all supervision of the MMU, to modify the reporting relationship of the MMU so that it rests either with a Joint Federal/State Board or alternatively rests solely with the PJM Board of Managers (with notice and review of personnel actions by the Commission). Finally, the Joint Complainants ask the Commission to require that the Market Monitoring Plan be amended to provide "just cause" employment security to the MMU.
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.
OPSI PJM MLI.pdf