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