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Motion for Leave to Answer and Answer of Potomac Electric Power Company

Docket No. EO-05-01: Pursuant to Rule 213 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. § 385.213, Potomac Electric Power Company (“Pepco”) hereby moves for leave to answer and answers the Motion for Leave to File Consolidated Answer and Consolidated Answer of Robert G. Burnley, Director of the Commonwealth of Virginia Department of Environmental Quality filed on November 10, 2005 (“VDEQ Answer”). For the reasons detailed below, Pepco requests that the Commission reject VDEQ’s Answer, or in the alternative, if the Commission accepts the VDEQ Answer, the Commission should also accept Pepco’s answer to correct inaccuracies in the VDEQ Answer, and to clarify the record.