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