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FERC Filings

MOTION TO INTERVENE AND PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION -GridFlorida LLC, Florida Power & Light Co.,Florida Power Corporation,Tampa Electric Co.-Docket No. RT01-67-000

D. Status Report on Collaborative Process Efforts: Critical issues identified by market stakeholders, but little progress and questionable effort on the part of the Applicants

In their filing, the Applicants congratulate themselves on the significant concessions that have occurred prior to their October 15th filing and their promise of collaborative efforts to address critical RTO issues prior to December 15th. However, the GridFlorida proposal represents far less compromise and accommodation of participating EPSA members views than the Applicants would have the Commission believe. Accordingly, we can only be guardedly optimistic, at best, regarding the prospects for an acceptable resolution through collaboration of critical issues, including access to scarce Physical Transmission Rights (“PTRs”) by non-incumbent market stakeholders, the adverse impact of Applicants proposed ability to ‘opt out’ of the real time energy imbalance dispatch control of the RTO on the credibility of the ancillary service default markets, and the conflict between the ‘for transmission profit’ motives of the GridFlorida Transco and its Board and neutral market policy decisions.