EPMI protest of Grid Florida RTO filing

Attached is EPMI's protest of GridFlorida's amended Dec. 15 filing. We
protested:

Certain Governance provisions
The allocation to the utilities of the PTRs (physical transmission rights)
The balanced day ahead scheduling requirement (telling FERC that it should
require a real time energy market instead)
Suggest an alternative approach to the ICAP market in which the ICAP is
monitored and a market only established after the icap drops (incentivizing
the LSEs to keep their reserves at the required level)

- 0137379.01