In his January 2013 “Commission Watch” column—“Very Roughly Commensurate: Analyzing the Order 1000 Comply Filings from Non-RTO Regions,” Public Utilities Fortnightly, Jan. 2013, at 16—Bruce W. Radford of PUF spotlighted the issues in filings to comply with Order 1000’s regional planning requirements in regions that do not have regional transmission organizations. The article quotes extensively the protest by Florida Municipal Power Agency and Seminole Electric Cooperative, which points out problems with the Florida’s compliance filing.  The protest, written by Spiegel attorneys Cynthia Bogorad, William Huang, and Rebecca Baldwin, as well as Seminole representatives, points out that

Florida Sponsors’ compliance filings place absolutely no obligation on themselves to identify potential solutions at the regional level that could better meet the needs of the region and evaluate such solutions to determine if they are more cost-effective and efficient means to address the region’s reliability, economic, and public policy-driven needs.

November 26, 2012 Motion to Intervene and Protest at 19. The PUF article may be found here (subscription required).