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					Control Number : 38597



Item Number : 757


Addendum StartPage: 0
                                  SOAH DOCKET NO. 473-11-0072
                                    P.U.C. DOCKET NO. 38597
                                                                                              2:2) 4
APPLICATION OF ONCOR ELECTRIC                       §
DELIVERY COMPANY LLC TO                             §
                                                             BEFORE THE STATE'OFEICE`
AMEND A CERTIFICATE OF                              §
CONVENIENCE AND NECESSITY FOR                       §                        OF
THE KRUM WEST TO ANNA 345-KV                        §
CREZ TRANSMISSION LINE IN                           §       ADMINISTRATIVE HEARINGS
COLLIN, COOKE, DENTON, AND                          §
GRAYSON COUNTIES                                    §

                                       CITY OF FRISCO'S
                                     MOTION TO INTERVENE

         COMES NOW, the City of Frisco ("City" or "Frisco") and files this motion to intervene

and would show:

         1.       Frisco is a municipality and has received notice from Oncor Electric Delivery

Company LLC ("Oncor") that several proposed routes traverse the City. Therefore, Frisco has a

justiciable interest because it will be impacted by the outcome of this proceeding.

        2.        The City's authorized representative in this matter is:

                           Geoffrey M. Gay
                           Lloyd Gosselink Rochelle & Townsend, P.C.
                           816 Congress Avenue, Suite 1900
                           Austin, Texas 78701
                           512-322-5800 Telephone
                           512-472-0532 Facsimile
                           ggay@lglawfirm.com


        3.        Frisco   requests that all correspondence, pleadings, briefs, requests for

information, responses to requests for information, and other documents in this proceeding be

served upon its authorized representative.

        4.        Frisco also requests to be aligned with the Cities of Celina and Prosper.




952/05/ 1204476                                     1

                                                                                                       1   61
         WHEREFORE PREMISES CONSIDERED, the City of Frisco requests that this motion

 to intervene be granted and to all other relief to which it is entitled.


                                                 Respectfully submitted,

                                                 LLOYD GOSSELINK ROCHELLE &
                                                 TOWNSEND, P.C.
                                                 816 Congress Avenue, Suite 1900
                                                 Austin, Texas 78701
                                                 (512) 322-5857
                                                 Fax: (512) 472-0532


                                                   P-4 44nzi Y 0-4 QLt-4                  ^el KA.
                                                 G FFREY M. AY                       (^j^ Z^(0(^bZ.
                                                 State Bar No. 0 74300

                                                 ATTORNEY FOR THE CITY OF FRISCO



                                   CERTIFICATE OF SERVICE

         Pursuant to SOAH Order No. 2, parties are required to access the PUC Interchange for all
filings in this docket.



                                                 Geoffrey M. G40




952/05/1204476                                     2

				
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