Attached for your review and comment is a first draft of the WPTF motion to intervene and protest the WestConnect filing.  The major points made in it are as follows:
 ?      The Commission should convene a technical conference to deals with areas in the WestConnect filing that require further clarification, such as congestion management.  Moreover, the analysis of congestion management issues must focus on the equitable allocation of transmission rights;

?      The Commission should require WestConnect to establish an independent board, with an accompanying stakeholder process that complies with commission precedent;

?      All load should be required to take service under the WestConnect tariff; 

?      Interconnection issues should be deferred until completion of the Commission's generic proceeding on this topic; and

?      Since a for-profit Transco has an inherent incentive to maximize transmission revenue, there are certain RTO functions that an entity such as WestConnect should not perform.

I am indebted to Karen Shea of Dynegy and Glenn Martin of Mirant for their very helpful assistance.  Our draft also draws upon concepts contained in the EPSA filing that Gary Ackerman provided.  The filing is due at FERC on Thursday the 15th.  I therefore need any comments from you no later than early that morning.  Thanks!

Dan

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