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Potomac Electric Power Company's Motion to Intervene and Comment in Support of Emergency Petition and Complaint

Docket No. EO-05-01. Docket No. EL05-145-000: Pursuant to Rules 211 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or the “Commission”), 18 C.F.R. §§ 385.211 and 385.214 (2004), Potomac Electric Power Company (“Pepco”) hereby moves to intervene in the above-captioned proceeding and supports the August 24, 2005 Emergency Petition and Complaint filed by the District of Columbia Public Service Commission (“DC PSC”). As discussed below, Mirant Corporation and its public utility subsidiaries (collectively, “Mirant”) should be required to continue operating the Potomac River generating station in Alexandria, Virginia (the “Potomac River Plant”) because the generation of electricity from the Potomac River Plant is a crucial part of existing contingency plans designed to ensure, among other things, the provision of reliable electric service to Pepco’s retail customers in the District of Columbia, which include many federal institutions.