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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 2 BA2DOCS1\180534.01 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] 3 BA2DOCS1\180534.01 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 4 BA2DOCS1\180534.01 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 5 BA2DOCS1\180534.01