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.