DRAFT IPPNY/EPSA Protest of Con Ed Filing

MEMORANDUM

TO: Regulatory Affairs Committee
Power Marketers Working Group

FROM: Joe Hartsoe, Regulatory Affairs Committee Chair
Bob Reilley, Power Marketers Working Group Chair
Julie Simon, Vice President of Policy
Mark Bennett, Senior Manager of Policy
Erin Perrigo, Manager of Policy

DATE: March 19, 2001

RE: Draft IPPNY/EPSA Protest of Con Edison Filing

Attached is a draft of a joint pleading IPPNY and EPSA have prepared in
response to Con Ed's request to revise the market mitigation measures for
in-City generation. The Commission has extended the deadline for
interventions until April 4th, but we will discuss this draft on the
Wednesday call on March 21st. If you have any questions, comments or
suggestions, contact Erin Perrigo at 202-628-8200 or eperrigo@epsa.org.

Attachment

- IPPNYEPSAPrtestConEd.doc