Download before the public service commission

February 20, 2002
VIA HAND DELIVERY
Felecia Greer, Esquire
Executive Secretary
Public Service Commission of Maryland
William Donald Schaefer Tower
6 St. Paul Street
Baltimore, Maryland 21202-6806
Re:
Case No. 8908
Dear Ms. Greer:
Enclosed please find the original and 14 copies of Conectiv Energy Supply, Inc.’s
Petition to Intervene and Motion to Intervene Out-of-Time and a diskette containing the same.
Also enclosed is an extra copy of the Petition to Intervene, which I would ask you to date stamp
and return to me in the envelope provided.
Thank you for your attention to this matter. Please do not hesitate to call me if
you have any questions.
Very truly yours,
Christopher R. Mellott
CRM/smr
Enclosures
BA2DOCS1\174031.01\S61
cc:
I. David Rosenstein, Esquire (w/enclosures)
Counsel of Record (w/enclosures)
BEFORE THE PUBLIC SERVICE COMMISSION
OF THE STATE OF MARYLAND
In the Matter of the Commission's Inquiry *
into the Competitive Selection of Electricity *
Supplier/Standard Offer Service.
*
Case No. 8908
Conectiv Energy Supply, Inc.
Petition to Intervene and Motion to Intervene Out-of-Time
Conectiv Energy Supply, Inc. ("CES"), pursuant to the letter dated December 18, 2001,
from the Commission's Executive Secretary, Ms. Felecia L. Greer, hereby submits its late filed
petition to the Commission to intervene in this proceeding as a party. CES submits that its late
intervention will not impair or prejudice the rights of any party because the proceeding has only
just begun and no formal pleadings have been made by any party other than petitions to
intervene. CES agrees that it will accept the record of the proceeding as it currently stands.
In support of its petition to intervene, CES states the following:
1.
CES is a Delaware corporation that engages in energy-related trading and
marketing activities. CES is a subsidiary of Conectiv Energy Holding Company, which is in
turn, a subsidiary of Conectiv, a Delaware corporation and a registered holding company under
the Public Utilities Holding Company Act of 1935. Conectiv also owns Delmarva Power &
Light Company, which provides electric utility services in portions of Maryland, Delaware and
Virginia and gas utility services in portions of Northern Delaware. Conectiv also owns Atlantic
City Electric Company, which is a public utility operating in New Jersey. Conectiv also owns
other subsidiaries that own and operate generation plants and, hence, may be public utilities as
defined by federal statutes. These entities do not, however, have franchised service territories
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and are not utilities for state purposes. Potomac Electric Power Company and Conectiv are
currently before this Commission in a separate proceeding regarding their plan to merge (Case
No. 8890).
2.
CES' primary business is focused on wholesale electric and gas trading at market
prices (i.e., negotiated, non-price regulated prices). CES is licensed in Maryland as a
competitive retail electricity supplier, but does not engage in any retail business in Maryland,
partly due to market conditions and partly due to Maryland Code of Conduct restrictions that
impose special conditions on marketers affiliated with utility companies. CES itself owns no
generation facilities, but has output contracts with other Conectiv entities that do have such
facilities.
3.
Notices and service on CES should be to the following:
I. David Rosenstein, Esq.
Conectiv Energy Supply, Inc.
Christiana Building
252 Chapman Road
P.O. Box 6066
Newark, DE 19714-6066 (U.S. Mail)
Newark, DE 19702 (Overnight)
(302) 452-6232
(302) 452-6449 (Fax)
[email protected]
David M. Velazquez
Conectiv Energy Supply, Inc.
Christiana Building
252 Chapman Road
P.O. Box 6066
Newark, DE 19714-6066 (U.S. Mail)
Newark, DE 19702 (Overnight)
(302) 224-6571
(302) 452-6364 (Fax)
[email protected]
Christopher R. Mellott, Esq.
Venable, Baetjer and Howard, LLP
1800 Mercantile Bank & Trust Building
2 Hopkins Plaza
Baltimore, Maryland 21201
(410) 244-7552
(410) 244-7742 (Fax)
[email protected]
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4.
CES may be directly and immediately affected by the outcome of this proceeding.
No other entity can adequately represent its interests. CES is a company separate from its utility
affiliate and because it is affiliated with a utility, its interests may diverge from those of
marketers without such affiliations. Therefore, CES respectfully requests that it be made a party
to Case No. 8908.
Respectfully submitted,
CONECTIV ENERGY SUPPLY, INC.
________________________________
Christopher R. Mellott
Venable, Baetjer & Howard, LLP
1800 Mercantile Bank & Trust Building
2 Hopkins Plaza
Baltimore, Maryland 21201
(410) 244-7552
Of Counsel:
I. David Rosenstein
Conectiv Energy Supply, Inc.
252 Chapman Road
Newark, Delaware 19702
(302) 452-6232
Counsel for Conectiv Energy Supply, Inc.
cc: Attached service list
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this
day of January, 2002, a copy of the
foregoing Petition to Intervene and Motion to Intervene Out-of-Time has been served by hand or
mailed, first-class, postage prepaid upon all parties of record in Case No. 8908.
Christopher R. Mellott
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