FPL and the SE RTO protests

Attached is the proposed protest that EPMI would file next Monday 11/20
against FPL in its request for continuation of market based rates for its
wholesale merchant function and affiliates. EPMI has already filed detailed
protests (unlike the attached generic protest) against AEP, Entergy and
Southern due to problems with each utility's OASIS system. EPMI plans to
file this generic protest in other large vertically integrated utility
requests for continuation of market based rates. The attachment now includes
a reference to Staff's investigation that states participation in an RTO,
without the proper safeguards, including the elimination of the native load
exception, will not necessarily reduce the utilities' ability to discriminate
against third parties. Plus, there is a reference that Staff found a
perception that the SE is the worst area for discriminatory practices.

Please let me know if you have an issue with EPMI making this filing in FPL's
proceeding.

Also, note: EPMI plans to file this generic protest this Thursday in the
current RTO proposals -- SPP, Entergy transco, Florida RTO, Southern, Grid
south. Then on Monday 11/20, EPMI will be filing its specific protests of
other aspects of each RTO filing.