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UNITED STATES OF AMERICA
BEFORE
THE
FEDERAL
ENERGY REGULATORY COMMISSION
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Midwest Independent Transmission
System Operator, Inc.
PJM Interconnection, L.L.C. |
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Docket No. ER04-375-000
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NOTICE OF INTERVENTION OF THE
ORGANIZATION OF MISO STATES
Pursuant to Rule 214(a)(2) of the Federal Energy Regulatory
Commission’s Rules of Practice and Procedure, 18 C.F.R. § 385.214(a)(2),
the Organization of MISO States (OMS) files its Notice of Intervention
in the above-captioned proceeding. In support thereof, the OMS states
as follows:
I. Communications
1.
Service of all pleadings, documents, and communications in this
matter should be made on the following:
William H. Smith,
Jr.
Executive Director
Organization of MISO
States
100 Court Avenue,
Suite 218
Des Moines, Iowa
50309
Commissioner Robert
Nelson
Michigan Public
Service Commission
Post Office Box
30221
Lansing, Michigan
48909-7721
II. Description of Filing
2.
On December 31, 2003, the Midwest Independent Transmission System
Operator, Inc. (Midwest ISO) and PJM Interconnection, L.L.C (PJM),
submitted for filing a Joint Operating Agreement between Midwest ISO and
PJM.
III. Basis for Intervention
3. The OMS is a
non-profit, self-governing organization of representatives from each
state with regulatory jurisdiction over entities participating in the
MISO, a regional transmission organization as defined by the FERC. The
state regulatory agencies that are member of the OMS are the Illinois
Commerce Commission, the Indiana Utility Regulatory Commission, the Iowa
Utilities Board, the Kentucky Public Service Commission, the Michigan
Public Service Commission, the Minnesota Public Utilities Commission,
the Missouri Public Service Commission, the Montana Public Service
Commission, the Nebraska Power Review Board, North Dakota Public Service
Commission, the Ohio Public Utilities Commission, the Pennsylvania
Public Utility Commission, the South Dakota Public Utilities Commission,
and the Wisconsin Public Service Commission. The Manitoba Public
Utilities Board is also a member of the OMS.
4. The purpose of the OMS is to
coordinate regulatory oversight among the
states; making recommendations to MISO, the MISO Board of Directors, the
FERC, other relevant government entities, and state commissions as
appropriate; and intervening in proceedings before the FERC and in
related judicial proceedings to express the positions of the OMS.
The OMS files this timely Notice of Intervene pursuant to the authority
conferred by its bylaws and the authorization of its Executive
Committee.
5. The Joint Operating Agreement addresses the seams
issues between the
Midwest ISO and PJM. The Joint Operating Agreement is necessary to
increase the
reliability of the transmission systems in the territories of the
Midwest ISO and PJM
However, there are certain issues that are still undecided and OMS
believes that it can
contribute to the ongoing evolution of the Joint Operating Agreement.
6. Based on the foregoing, the OMS respectfully
submits that it has a direct
and substantial interest in these proceedings and that no other party
can adequately
represent the interests of the OMS or its member states in this
proceeding.
WHEREFORE, the OMS respectfully gives notice of its intervention in this
proceeding.
Respectfully
Submitted,
______/s/______
William H.
Smith, Jr.
Executive
Director
Organization
of MISO States
Dated: January 20, 2004
CERTIFICATE OF
SERVICE
I hereby certify that I have this day
served the foregoing Notice of Intervention on all parties on the
official service list compiled by the Secretary in this proceeding.
Dated at Des Moines,
Iowa, this13th day of February, 2004.
______/s/______
William H.
Smith, Jr.
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