Florida Public Service Commission native order document 09043-2024

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FILED 9/17/2024
DOCUMENT NO. 09043-2024
FPSC - COMMISSION CLERK

BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION

DOCKET NO. 20240010-EI
ORDER NO. PSC-2024-0426-PHO-EI
ISSUED: September 17, 2024

In re: Storm protection plan cost recovery
clause.

PREHEARING ORDER

Pursuant to Notice and in accordance with Rule 28-106.209, Florida Administrative Code
(F.A.C.), Commissioner Gabriella Passidomo, as Prehearing Officer, conducted a Prehearing
Conference in this docket on September 9, 2024, in Tallahassee, Florida.

APPEARANCES:

J. JEFFRY WAHLEN, MALCOLM N. MEANS and VIRGINIA L. PONDER,
ESQUIRES, Ausley McMullen, Post Office Box 391, Tallahassee, Florida 32302
On behalf of Tampa Electric Company (TECO).

BETH KEATING, ESQUIRE, Gunster, Yoakley & Stewart, P.A., 215 South
Monroe Street, Suite 601, Tallahassee, Florida 32301
On behalf of Florida Public Utilities Company (FPUC).

CHRISTOPHER T. WRIGHT and DAVID M. LEE, ESQUIRES, Florida Power
& Light Company, 700 Universe Boulevard, Juno Beach, Florida 33408-0420
On behalf of Florida Power & Light Company (FPL).

MATTHEW R. BERNIER and STEPHANIE A. CUELLO, ESQUIRES, 106 East
College Avenue, Suite 800, Tallahassee, Florida 32301

DIANNE M. TRIPLETT, ESQUIRE, Deputy General Counsel, 299 1%' Avenue
North, St. Petersburg, Florida 33701

On behalf of Duke Energy Florida, LLC (DEF).

WALT TRIERWEILER, CHARLES REHWINKEL, PATRICIA A.
CHRISTENSEN, MARY A. WESSLING, OCTAVIO SIMOES-PONCE, and
AUSTIN A. WATROUS, ESQUIRES, Office of the Public Counsel, c/o The
Florida Legislature, 111 West Madison Street, Suite 812, Tallahassee, Florida
32399-1400

On behalf of Office of Public Counsel (OPC).

JON C. MOYLE, JR. and KAREN A. PUTNAL, ESQUIRES, Moyle Law Firm,
P.A., 118 North Gadsden Street, Tallahassee, Florida 32301
On behalf of Florida Industrial Power Users Group (FIPUG).

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 2
PETER J. MATTHEIS, MICHAEL K. LAVANGA, and JOSEPH R. BRISCAR,
ESQUIRES, Stone, Mattheis, Xenopoulos & Brew, PC, 1025 Thomas Jefferson
Street, NW, Eighth Floor, West Tower, Washington, DC 20007
On behalf of Nucor Steel Florida, Inc. (Nucor).
JAMES W. BREW, LAURA WYNN BAKER and SARAH B. NEWMAN,
ESQUIRES, Stone, Mattheis, Xenopoulos & Brew, PC, 1025 Thomas Jefferson
Street, NW, Suite 800 West, Washington, DC 20007
On behalf of White Springs Agricultural Chemicals, Inc. d/b/a PCS Phosphate –
White Springs (PCS Phosphate).
SHAW STILLER and DANIEL DOSE, ESQUIRES, Florida Public Service
Commission, 2540 Shumard Oak Boulevard, Tallahassee, Florida 32399-0850
On behalf of the Florida Public Service Commission (Staff).
MARY ANNE HELTON, ESQUIRE, Deputy General Counsel, Florida Public
Service Commission, 2540 Shumard Oak Boulevard, Tallahassee, Florida 32399-
0850
Advisor to the Florida Public Service Commission.
KEITH C. HETRICK, ESQUIRE, General Counsel, Florida Public Service
Commission, 2540 Shumard Oak Boulevard, Tallahassee, Florida 32399-0850
Florida Public Service Commission General Counsel.
I. 	CASE BACKGROUND
The 2019 Florida Legislature enacted Section 366.96, Florida Statutes (F.S.), entitled
“Storm protection plan cost recovery.” Section 366.96(3), F.S., established a new requirement
that each public utility file a transmission and distribution storm protection plan (SPP) covering
the immediate 10-year planning period, and explaining the systematic approach the utility will
follow to achieve the objectives of reducing restoration costs and outage times associated with
extreme weather events and enhancing reliability. Pursuant to Sections 366.96(5) and 366.96(6),
F.S., the Florida Public Service Commission (Commission) is required every three years to
determine whether it is in the public interest to approve, approve with modification, or deny each
utility’s SPP.
In addition to reviewing SPPs at least every three years, the Commission must conduct an
annual proceeding pursuant to Section 366.96(7), F.S., to determine a utility’s prudently incurred
transmission and distribution storm protection plan costs and allow the utility to recover such
costs through a charge separate and apart from its base rates, to be referred to as the storm
protection plan cost recovery clause (SPPCRC). The annual SPPCRC proceeding is a rolling
three-year review that includes a true-up of costs for the prior year, the calculation of
actual/estimated costs for the year of the filing, and projected factors for the following year. If

ORDER NO. PSC-2024-0426-PHO-EI
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the Commission determines that costs were prudently incurred, those costs will not be subject to
disallowance or further prudence review except for fraud, perjury, or intentional withholding of
key information by the public utility.
This docket was opened by Order No. PSC-2024-0010-PCO-EI, issued January 3, 2024,
under the authority of Sections 366.96(5), 366.96(6), and 366.96(7), F.S. The purpose of this
2024 annual proceeding is for the Commission to establish the amount of prudently incurred
costs each utility shall be allowed to recover through the SPPCRC and the specific terms of that
recovery. Tampa Electric Company, Duke Energy Florida, Florida Industrial Power Users
Group, Florida Power & Light, PCS Phosphate – White Springs, Nucor Steel Florida, Inc.,
Office of Public Counsel, and Florida Public Utilities Company each filed a Notice of Intent to
Retain Party Status. No additional parties filed for intervention.
This matter has been scheduled for an evidentiary hearing September 25-27, 2024.
II. 	CONDUCT OF PROCEEDINGS
Pursuant to Rule 28-106.211, F.A.C., this Prehearing Order is issued to prevent delay and
to promote the just, speedy, and inexpensive determination of all aspects of this case.
III. 	JURISDICTION
This Commission is vested with jurisdiction over the subject matter by the provisions of
Chapter 366, F.S. This hearing will be governed by Chapters 120 and 366, F.S., and Chapters 25-
6, 25-22, and 28-106, F.A.C., as well as any other applicable provisions of law.
IV. 	PROCEDURE FOR HANDLING CONFIDENTIAL INFORMATION
Information for which proprietary confidential business information status is requested
pursuant to Section 366.093, F.S., F.S., and Rule 25-22.006, F.A.C., shall be treated by the
Commission as confidential. 	The information shall be exempt from Section 119.07(1), F.S.,
pending a formal ruling on such request by the Commission or pending return of the information
to the person providing the information. 	If no determination of confidentiality has been made
and the information has not been made a part of the evidentiary record in this proceeding, it shall
be returned to the person providing the information. 	If a determination of confidentiality has
been made and the information was not entered into the record of this proceeding, it shall be
returned to the person providing the information within the time period set forth in Section
366.093, 	F.S., 	F.S. 	The 	Commission 	may 	determine 	that 	continued 	possession 	of 	the
information is necessary for the Commission to conduct its business.
It is the policy of this Commission that all Commission hearings be open to the public at
all times. The Commission also recognizes its obligation pursuant to Section 366.093, F.S., F.S.,

ORDER NO. PSC-2024-0426-PHO-EI
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to protect proprietary confidential business information from disclosure outside the proceeding.
Therefore, any party wishing to use any proprietary confidential business information, as that
term is defined in Section 366.093, F.S., F.S., at the hearing shall adhere to the following:
(1) 	When confidential information is used in the hearing that has not been filed as
prefiled 	testimony 	or 	prefiled 	exhibits, 	parties 	must 	have 	copies 	for 	the
Commissioners, necessary staff, and the court reporter, in red envelopes clearly
marked with the nature of the contents and with the confidential information
highlighted. 	Any party wishing to examine the confidential material that is not
subject to an order granting confidentiality shall be provided a copy in the same
fashion as provided to the Commissioners, subject to execution of any appropriate
protective agreement with the owner of the material.
(2) 	Counsel and witnesses are cautioned to avoid verbalizing confidential information
in such a way that would compromise confidentiality. 	Therefore, confidential
information should be presented by written exhibit when reasonably possible.
At the conclusion of that portion of the hearing that involves confidential information, all
copies of confidential exhibits shall be returned to the proffering party. If a confidential exhibit
has been admitted into evidence, the copy provided to the court reporter shall be retained in the
Office of Commission Clerk’s confidential files. If such material is admitted into the evidentiary
record at hearing and is not otherwise subject to a request for confidential classification filed
with the Commission, the source of the information must file a request for confidential
classification of the information within 21 days of the conclusion of the hearing, as set forth in
Rule 25-22.006(8)(b), F.A.C., if continued confidentiality of the information is to be maintained.
V. 	PREFILED TESTIMONY AND EXHIBITS; WITNESSES
Testimony of all witnesses to be sponsored by the parties and Staff has been prefiled and
will be inserted into the record as though read after the witness has taken the stand and affirmed
the correctness of the testimony and associated exhibits. All testimony remains subject to timely
and appropriate objections. 	Upon insertion of a witness’ testimony, exhibits appended thereto
may be marked for identification. 	Each witness will have the opportunity to orally summarize
his or her testimony at the time he or she takes the stand. 	Summaries of testimony shall be
limited to three minutes.
Witnesses are reminded that, on cross-examination, responses to questions calling for a
simple yes or no answer shall be so answered first, after which the witness may explain his or her
answer. 	After all parties and Staff have had the opportunity to cross-examine the witness, the
exhibit may be moved into the record. All other exhibits may be similarly identified and entered
into the record at the appropriate time during the hearing.

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The Commission frequently administers the testimonial oath to more than one witness at
a time. 	Therefore, when a witness takes the stand to testify, the attorney calling the witness is
directed to ask the witness to affirm whether he or she has been sworn.
The parties shall avoid duplicative or repetitious cross-examination. Further, friendly
cross-examination will not be allowed. 	Cross-examination shall be limited to witnesses whose
testimony is adverse to the party desiring to cross-examine. Any party conducting what appears
to be a friendly cross-examination of a witness should be prepared to indicate why that witness's
direct testimony is adverse to its interests.
VI. 	PROVISION OF EXHIBITS FOR HEARING
With the exception of deposition transcripts used for impeachment exhibits, which will
be discussed further below, all cross-examination, demonstrative, and impeachment exhibits,
except for deposition transcripts, shall be exchanged between the parties and Staff by the close of
business on September 13, 2024, using the process set out in Order No. PSC-2024-0216-PCO-
EI.
Deposition transcripts used for impeachment purposes only are not required to be
exchanged between the parties and Staff. Deposition transcripts that are used for impeachment
purposes will not be loaded into Case Center. Section VI, Part G, of Order No. PSC-2024-0032-
PCO-EI, still applies to those deposition transcripts that parties seek to admit into the record.
By Section VI, Part H, of Order No. PSC-2024-0216-PCO-EI, the Commission intended
to require all parties and Staff to exchange exhibits prior to the hearing so that all hearing
participants are on notice of all exhibits to be used during the hearing. Notice prior to the hearing
remains the intent and is the reason for the Exhibit List required by Section VI, Part H, of the
Order.
The following clarifications are offered to assist the parties in preparing for the final
hearing:
 	Parties may use the exhibits identified by Staff on the Comprehensive Exhibit List
(CEL) for cross-examination purposes without listing them on the party’s exhibit list
or exchanging the exhibit with the other parties. Thus, for example, a Staff Exhibit on
the CEL may be used by any party, and should not be duplicated on another party’s
exhibit list or provided in the exchange if the party intends to use that previously
identified exhibit.
 	All hearing participants are already on notice of all prefiled testimony and exhibits.
Thus, no prefiled testimony or prefiled exhibits should be listed on any party’s exhibit
list or exchanged.
 	Parties are not required to submit an exhibit in Excel format if you are satisfied that a
witness can view the PDF conversion of the spreadsheet; please check the PDF
version to ensure legibility. However, if an Excel spreadsheet is submitted in native

ORDER NO. PSC-2024-0426-PHO-EI
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format, the party must also submit a PDF conversion of the exhibit using the same
exhibit name. (i.e., OPC-1 Short Title.pdf and OPC-1 Short Title.xls).
 	Parties are not required to create a separate PDF file or exhibit for each Interrogatory
response. 	Several 	responses 	and 	attachments 	can 	be 	combined 	into 	one 	PDF
document and submitted as one composite exhibit. If a party submits an attachment
separately, the attachment must be numbered as a separate exhibit.
 	The exchange of cross-examination exhibits prior to hearing is consistent with Florida
law and is to afford due process to all parties by avoiding “trial by surprise.” The
Commission expects all parties to respect the process by being judicious about the
cross-examination exhibits provided. Parties should have a reasonable, good faith
expectation of using the exhibit during the hearing.
VII. 	ORDER OF WITNESSES
Each witness whose name is followed by an asterisk (*) has been excused from the final
hearing. Their prefiled testimonies will be inserted into the record as though read.
Witness 	Proffered By 	Issues #
Direct
M. Ashley Sizemore* 	TECO 	1-10
C. David Sweat* 	TECO 	1-10
Phuong T. Nguyen*
(adopted by Michelle Napier)
FPUC 	1C
Mark Cutshaw* 	FPUC 	1C, 2C-3C
Michelle Napier* 	FPUC 	2C-9C
Michael Jarro* 	FPL 	1-4
Richard L. Hume* 	FPL 	1-10
Christopher A. Menendez* 	DEF 	1D-9D
Robert E. McCabe* 	DEF 	1D-3D
Robert E. Brong* 	DEF 	1D-3D
Tomer Kopelovich* 	Staff 	1A

ORDER NO. PSC-2024-0426-PHO-EI
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Witness 	Proffered By 	Issues #
Ron Mavrides* 	Staff 	1B
Donna D. Brown* 	Staff 	1C and 1D
VIII. 	BASIC POSITIONS
TECO: 	In 	Order 	No. 	PSC-2022-0386-FOF-EI, 	issued 	November 	10, 	2022, 	the
Commission found that Tampa Electric’s 2022-2031 Storm Protection Plan
(“2022 	SPP”) 	is 	in 	the 	public 	interest 	and 	approved 	that 	plan 	with 	one
modification – elimination of the company’s existing Transmission Access
Enhancement Program as of December 31, 2022.
The Commission is currently scheduled to conduct a hearing regarding the Storm
Protection Cost Recovery Clause on September 25, 2024, to review and approve
the proposed cost recovery factors to be used for the January 2025 through
December 2025 period.
The Commission should determine that Tampa Electric has properly calculated its
Storm Protection Plan cost recovery true-up and projections and the Storm
Protection Plan cost recovery factors set forth in the testimony and exhibits of
witness M. Ashley Sizemore during the period January 2025 through December
2025. These calculations were performed in accordance with the requirements of
Section 	366.96 	of 	the 	Florida 	Statutes 	and 	Rule 	25-6.031 	of 	the 	Florida
Administrative Code. No party has challenged or made any other recommended
adjustments to the company’s calculations. The company’s true-up, projections,
and factors should accordingly be approved. The Commission should also find
that Tampa Electric’s actual 2023 Storm Protection Plan costs were prudently
incurred. No party has challenged the prudence of Tampa Electric’s actual
incurred costs or made any recommended adjustments to any of the projects or
costs included in the 2023 final true-up.
FPUC: 	The factors proposed by the Company have been developed through projections
and calculations made in accordance with Rule 25-6.031, F.A.C., and the
associated depreciation expense has been calculated in accordance with the rates
approved in the Company’s last approved depreciation study. 	The factors are
based upon actual, prudently incurred costs associated with the implementation of
those aspects of FPUC’s Storm Protection Plan (“SPP”) approved by Order No.
PSC-2022-0387-FOF-EI, issued November 10, 2022, as well as reasonable
estimates of costs to be incurred in the remainder of 2024 and in 2025. 	In
addition, the Company has applied an allocation methodology consistent with the
stipulation between FPUC and Walmart approved by Order No. PSC-2022-0418-

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 8
FOF-EI, issued in last year’s SPPCRC proceeding. 	As such, the Company asks
that it be allowed to implement its proposed SPPCRC Factors for the January –
December, 2025 period.
FPL: 	FPL’s final true-up of its 2023 SPP costs is consistent with the actual/estimated
2023 SPP costs approved by Commission Order No. PSC-2023-0364-FOF-EI in
Docket No. 20230010-EI, consistent with the 2023 SPP approved by Commission
Order No. PSC-2022-0389-FOF-EI in Docket No. 20220051-EI, applies the
methodology and prescribed schedules contained in Commission Forms 1A
through 8A, and meets the requirements of Section 366.96, Florida Statutes, and
Rule 25-6.031(7)(a), Florida Administrative Code. No parties challenged or made
any recommended adjustments to any of the SPP projects, costs, or revenue
requirements included in FPL’s 2023 SPPCRC final true-up. 	Therefore, the
Commission should approve FPL’s net final true-up under-recovery amount of
$5,648,042, including interest, for the period of January 2023 through December
2023.
FPL’s actual/estimated true-up of its 2024 SPP costs is consistent with the
projected 2024 SPP costs approved by Commission Order No. PSC-2023-0364-
FOF-EI in Docket No. 20230010-EI, consistent with the 2023 SPP approved by
Commission Order No. PSC-2022-0389-FOF-EI in Docket No. 20220051-EI,
applies the methodology and prescribed schedules contained in Commission
Forms 1E through 8E, and meets the requirements of Section 366.96, Florida
Statutes, and Rule 25-6.031(7)(b), Florida Administrative Code. 	No parties
challenged or made any recommended adjustments to any of the SPP projects,
costs, or revenue requirements included in FPL’s 2024 SPPCRC actual/estimated
true-up. Therefore, the Commission should approve FPL’s actual/estimated true-
up under-recovery amount of $59,670,684, including interest, for the period of
January 2024 through December 2024.
FPL’s projected 2025 SPP costs are consistent with the 2023 SPP approved
Commission Order No. PSC-2022-0389-FOF-EI in Docket No. 20220051-EI,
apply the methodology and prescribed schedules contained in Commission Forms
1P through 7P, and meet the requirements of Section 366.96, Florida Statutes, and
Rule 25-6.031(2) and (7)(c), Florida Administrative Code. No parties challenged
or made any recommended adjustments to any of the individual 2025 SPP
projects or associated costs. 	Therefore, the Commission should approve the
$721,264,550 	of 	revenue 	requirements 	associated 	with 	the 	SPP 	programs
projected to be incurred between January 1, 2025, and December 31, 2025.
For these reasons, as further explained in FPL’s direct, supplemental, and rebuttal
testimonies, the Commission should approve the total jurisdictional revenue
requirement of $ 786,583,276, including true-up amounts, for recovery through
FPL’s 2025 SPPCRC Factors for the period of January 2025 through December
2025.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 9
DEF: 	As required by the OEP, on April 1 and May 1, DEF made its 2023 True-Up and
2024 Actual/Estimated and 2025 Projection filings, respectively. Subsequently, in
Docket No. 20240025-EI, DEF filed the Joint Motion for Approval of 2024
Settlement 	Agreement. 	See 	doc. 	no. 	07553-2024. 	The 	2024 	Settlement
Agreement, if approved by the Commission, would authorize DEF to earn a mid-
point 10.3% ROE (9.3%-11.3% authorized range). See id. at Attachment 1, Par. 2.
However, DEF’s May 1 Projection filing incorporated the ROE DEF requested in
its as-filed Rate Case Petition of 11.15%. The Commission is currently scheduled
to hold a hearing to consider the 2024 Settlement Agreement beginning on August
21. Therefore, because DEF cannot know at this time whether the Settlement
Agreement will be approved, and while it urges the Commission to do so,
concurrent with this prehearing statement, DEF is also filing an Updated 2024
Actual/Estimated 	and 	2025 	Projection 	Petition, 	Updated 	Testimony 	of
Christopher Menendez, and an Updated Exhibit CAM-3. The purpose of these
Updated filings is to recalculate applicable projected capital recovery amounts
and revenue requirements for 2025 based on the reduction in ROE as agreed in
the 2024 Settlement Agreement versus as originally filed on May 1 in this docket.
This results in lower capital revenue requirements and SPPCRC recovery factors
in 2025. Below, in the applicable individual issues, DEF will provide its positions
based on the original May 1 filing as well as an “Alternative” position that should
be approved if the Commission approves the 2024 Settlement Agreement.
OPC: 	The Storm Protection Plan Cost Recovery Clause (SPPCRC) is the step in the
ratemaking process where the Commission sets the factors necessary for recovery
for the annual costs for implementing the Companies’ approved Storm Protection
Plan. The process of reviewing and implementing an SPP is an indispensable and
necessary step in the ratemaking process within the meaning and intent of Section
366.06(1) and 366.96, Florida Statutes. Section 366.06(1), Florida Statutes,
establishes the Commission’s rate-making procedure for public utilities in the
State of Florida. Upon application for a change in rates by a utility,
The 	commission 	shall 	investigate 	and 	determine 	the 	actual
legitimate costs of the property of each utility company, actually
used and useful in the public service, and shall keep a current
record of the net investment of each public utility company in such
property which value, as determined by the commission, shall be
used for ratemaking purposes and shall be the money honestly and
prudently invested by the public utility company in such property
used and useful in serving the public, less accrued depreciation,
and shall not include any goodwill or going-concern value or
franchise value in excess of payment made therefor.
Id. (emphasis added).

ORDER NO. PSC-2024-0426-PHO-EI
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The requirement that the Commission evaluate the prudence of investments in all
ratemaking requests before the Commission is embedded in the Commission’s
legislative mandate. The statute does not specify that the Commission must only
consider prudence of investments in base rate cases, cost recovery dockets, or any
other 	specified 	type 	of 	rate-setting 	case 	before 	the 	Commission. 	If 	the
Commission is setting rates, it must consider, among other things, the prudence of
making the investment at issue (including the decisions behind the timing, amount
and locations of the investment(s)), regardless of whether that requirement is
explicitly stated in the other provisions of chapter 366, Florida Statutes, or the
Commission’s rules. Section 366.96, Florida Statutes, sets forth the process for
review and approval of and implementation of the prudent costs for the SPP.
Furthermore, it is worth noting that section 366.96(2)(c), Florida Statutes defines
“transmission and distribution storm protection plan costs” as “the reasonable and
prudent costs to implement an approved transmission and distribution storm
protection plan.”
The positions taken by the Public Counsel in this docket are consistent with and
informed to the greatest extent possible by the unresolved statutory interpretation
issues currently pending before the Florida Supreme Court in Case No. SC 2022-
1733 (consolidated).
FIPUG: 	The petitioners have the burden of proof to establish that expenditures for which
cost recovery is sought are prudent. 	The Commission should reduce the monies
sought by the utilities by the amounts for which it finds insufficient proof or for
costs not properly within the scope of the state’s storm protection plan statute,
section 366.96, Florida Statutes, or the Commission’s rule, Rule 25-6.030, Florida
Administrative Code.
Nucor: 	Rule 25-6.031, F.A.C, details the specific recoverable costs that Duke Energy
Florida, LLC (“DEF”) may collect through the SPPCRC and provides that such
costs must be consistent with the Company’s approved Storm Protection Plan.
Nucor’s basic position is that DEF bears the burden of proof to justify the amount
of costs it seeks to recover through the SPPCRC and show that such costs are
eligible recovery costs under 25-6.031(6) and are consistent with DEF’s approved
Storm Protection Plan. 	Finally, Nucor notes that DEF over-recovered and/or
projects to over-recover its eligible costs through the SPPCRC for 2023 and 2024.
The Commission should carefully review DEF’s projected 2025 SPPCRC rates to
ensure that the rates are properly designed to recover the Company’s forecast
2025 costs.
PCS
Phosphate: 	Only costs prudently incurred and legally authorized may be recovered through
the fuel clause. Florida electric utilities, including in particular Duke Energy
Florida, LLC (“DEF”), must satisfy the burden of proving the reasonableness of
any expenditures for which recovery or other relief is sought in this proceeding.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 11
DEF has filed for recovery of costs of its Storm Protection Plan (“SPP”), which
was approved in 2022.1 DEF’s approved SPPCRC revenue requirement for 2024
was $201.3 million before accounting for prior year true-ups,2 and its projected
period 2025 SPPCRC revenue requirement for 2025 is $301.1 million before
accounting for prior year true-ups.3 This is a 50% overall revenue requirement
increase. According to DEF’s approved Storm Protection Plan, the utility’s SPP
investments are supposed to begin generating substantial system benefits in the
form of reduced outage times and restoration costs.4 The Commission should
begin requiring DEF to include in its annual SPPCRC filings an assessment of
system benefits realized by program.
STAFF: 	Staff's positions are preliminary and based on materials filed by the parties and on
discovery. The preliminary positions are offered to assist the parties in preparing
for the hearing. 	Staff's final positions will be based upon all the evidence in the
record and may differ from the preliminary positions stated herein.
IX. 	ISSUES AND POSITIONS5
ISSUE 1A: 	What jurisdictional amounts should the Commission approve as FPL’s final
2023 	prudently 	incurred 	costs 	and 	final 	true-up 	revenue 	requirement
amounts for the Storm Protection Plan Cost Recovery Clause?
TECO: 	No position.
FPUC: 	No position.
FPL: 	FPL’s final total SPPCRC cost incurred for 2023 is $1,371,442,934, which
includes a total operations and maintenance (“O&M”) expense of $96,591,030
and a total capital expenditure of $1,274,851,904.6 	FPL’s SPPCRC final
jurisdictional revenue requirement true-up for the period January 2023 through
December 2023, including interest, is an under-recovery of $5,648,042.
1 Docket 20220050-EI, Amended Final Order Approving, With Modifications, Duke Energy Florida’s Storm
Protection Plan, Order No. PSC-2022-0388A-FOF-EI (Nov. 14, 2022) (“2022 SPP Approval Order”).
2 See Docket No. 20230010-EI, In re: Storm protection plan cost recovery clause, Final Order Approving Storm
Cost Recovery Amounts and Related Tariffs and Establishing Storm Cost Recovery Factors for the Period January
2024 through December 2024, Order No. PSC-2023-0364-FOF-EI at 17.
3 See Exh. No. __ (CAM-3), Form 1P at page 1 of 118.
4 See 2022 SPP Approval Order.
5 All issues in this docket are the subject of proposed Type 2 stipulations. See Attachments A – D to this Order. A
Type 2 stipulation occurs on an issue when the utility and the staff, or the utility and at least one party adversarial to
the utility, agree on the resolution of the issue and the remaining parties (including staff if they do not join in the
agreement) do not object to the Commission relying on the agreed language to resolve that issue in a final order.
6 The jurisdictional separation factors are applied to the revenue requirements and not the costs incurred. Therefore,
the total jurisdictional cost incurred for the applicable calendar year is not available.

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PAGE 12
DEF: 	No position.
OPC: 	OPC takes no position on FPL’s proposed Storm Protection Plan Cost Recovery
Clause Factors, nor does it have the burden of proof related to them. 	As such,
OPC further represents that it takes no position on, and thus will not contest or
oppose the Commission taking action approving a proposed stipulation between
the Company and another party or Staff as to a final resolution of, Issue Nos. 1A,
2A, 3A, 4A, 5A, 6A, 7A, 8A, 9A, and 10. 	No person is authorized to state that
the OPC is a participant in, or party to, a stipulation on these issues, either in this
docket, in an order of the Commission or in a representation to a Court.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 1B: 	What jurisdictional amounts should the Commission approve as TECO’s
final 2023 prudently incurred costs and final true-up revenue requirement
amounts for the Storm Protection Plan Cost Recovery Clause?
TECO: 	Tampa Electric’s final Storm Protection Plan Cost Recovery Clause jurisdictional
revenue requirements are $70,079,782 and jurisdictional cost recovery true-up
under-recovery 	amount 	is 	$459,097 	for 	the 	period 	January 	2023 	through
December 2023 including interest.
FPUC: 	No position.
FPL: 	No position.
DEF: 	No position.
OPC: 	OPC takes no position on Tampa Electric’s proposed Storm Protection Plan Cost
Recovery Clause Factors, nor does it have the burden of proof related to them. As
such, OPC further represents that it takes no position on, and thus will not contest
or oppose the Commission taking action approving a proposed stipulation
between the Company and another party or Staff as to a final resolution of, Issue
Nos. 1B, 2B, 3B, 4B, 5B, 6B, 7B, 8B, 9B, and 10. 	No person is authorized to
state that the OPC is a participant in, or party to, a stipulation on these issues,
either in this docket, in an order of the Commission or in a representation to a
Court.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 13
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 1C: 	What jurisdictional amounts should the Commission approve as the FPUC’s
final 2023 prudently incurred costs and final true-up revenue requirement
amounts for the Storm Protection Plan Cost Recovery Clause?
TECO: 	No position.
FPUC: 	The final, end of period true up amount to be included in the calculation of the
2023 cost recovery factors is an under-recovery of $388,983, which reflects the
difference between the actual, end of period revenue requirement of $246,889
based on actual expenditures, and the projected 2023 over-recovery of $142,094.
FPL: 	No position.
DEF: 	No position.
OPC: 	OPC takes no position on FPUC’s proposed Storm Protection Plan Cost Recovery
Clause Factors, nor does it have the burden of proof related to them. 	As such,
OPC further represents that it takes no position on, and thus will not contest or
oppose the Commission taking action approving a proposed stipulation between
the Company and another party or Staff as to a final resolution of, Issue Nos. 1C,
2C, 3C, 4C, 5C, 6C, 7C, 8C, 9C, and 10. No person is authorized to state that the
OPC is a participant in, or party to, a stipulation on these issues, either in this
docket, in an order of the Commission or in a representation to a Court.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 14
ISSUE 1D: 	What jurisdictional amounts should the Commission approve as the DEF’s
final 2023 prudently incurred costs and final true-up revenue requirement
amounts for the Storm Protection Plan Cost Recovery Clause?
TECO: 	No position.
FPUC: 	No position.
FPL: 	No position.
DEF: 	DEF’s total SPPCRC investments for 2024 is $684,389,980. 7 DEF’s SPPCRC
final jurisdictional revenue requirement true-up for the period January 2023
through December 2023, including interest, is an over-recovery of $5,364,450.
OPC: 	OPC takes no position on DEF’s proposed Storm Protection Plan Cost Recovery
Clause Factors, nor does it have the burden of proof related to them. 	As such,
OPC further represents that it takes no position on, and thus will not contest or
oppose the Commission taking action approving a proposed stipulation between
the Company and another party or Staff as to a final resolution of, Issue Nos. 1D,
2D, 3D, 4D, 5D, 6D, 7D, 8D, 9D, and 10. 	No person is authorized to state that
the OPC is a participant in, or party to, a stipulation on these issues, either in this
docket, in an order of the Commission or in a representation to a Court.
FIPUG: 	Agree with OPC.
NUCOR: 	Agree with OPC.
PCS
Phosphate: 	Agree with OPC.
STAFF: 	Staff has no position at this time.
ISSUE 2A: 	What jurisdictional amounts should the Commission approve as the FPL’s
reasonably estimated 2024 costs and estimated true-up revenue requirement
amounts for the Storm Protection Plan Cost Recovery Clause?
TECO: 	No position.
FPUC: 	No position.
7 The jurisdictional separation factors are applied to the revenue requirements and not the costs incurred. Therefore,
the total jurisdictional cost incurred for the applicable calendar year is not available.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 15
FPL: 	FPL’s total SPPCRC cost estimated for 2024 is $1,540,725,072, which includes a
total 	O&M 	expense 	of 	$126,982,092 	and 	a 	total 	capital 	expenditure 	of
$1,413,742,980.8 	FPL’s 	SPPCRC 	actual/estimated 	jurisdictional 	revenue
requirement 	true-up for 	the 	period 	January 	2024 	through 	December 	2024,
including interest, is an under-recovery of $59,670,684.
DEF: 	No position.
OPC: 	Same as Issue 1A.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 2B: 	What jurisdictional amounts should the Commission approve as TECO’s
reasonably estimated 2024 costs and estimated true-up revenue requirement
amounts for the Storm Protection Plan Cost Recovery Clause?
TECO: 	Tampa Electric’s actual/estimated Storm Protection Plan Cost Recovery Clause
jurisdictional revenue requirements are $90,297,357 and jurisdictional estimated
cost recovery true-up under-recovery amount is $606,964 for the period January
2024 through December 2024 including interest.
FPUC: 	No position.
FPL: 	No position.
DEF: 	No position.
OPC: 	Same as Issue 1B.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
8 See Footnote 3.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 16
STAFF: 	Staff has no position at this time.
ISSUE 2C: 	What jurisdictional amounts should the Commission approve as FPUC’s
reasonably estimated 2024 costs and estimated true-up revenue requirement
amounts for the Storm Protection Plan Cost Recovery Clause?
TECO: 	No position.
FPUC: 	FPUC projects an end of period 2024 under-recovery of $1,120,304, based on a
revised 2024 revenue requirement of $3,481,578, which is net of $975,504
already recovered through base rates.
FPL: 	No position.
DEF: 	No position.
OPC: 	Same as Issue 1C.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 2D: 	What 	jurisdictional 	amounts 	should 	the 	Commission 	approve 	as 	DEF’s
reasonably estimated 2024 costs and estimated true-up revenue requirement
amounts for the Storm Protection Plan Cost Recovery Clause?
TECO: 	No position.
FPUC: 	No position.
FPL: 	No position.
DEF: 	DEF’s total SPPCRC investments for 2024 is $771,943,413. 9 DEF’s SPPCRC
actual/estimated jurisdictional revenue requirement true-up for the period January
9 See Footnote 7.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 17
2024 	through 	December 	2024, 	including 	interest, 	is 	an 	over-recovery 	of
$10,259,107.
OPC: 	Same as Issue 1D.
FIPUG: 	Agree with OPC.
NUCOR: 	Agree with OPC.
PCS
Phosphate: 	Agree with OPC.
STAFF: 	Staff has no position at this time.
ISSUE 3A: 	What 	jurisdictional 	amounts 	should 	the 	Commission 	approve 	as 	FPL’s
reasonably projected 2025 costs and projected revenue requirement amounts
for the Storm Protection Plan Cost Recovery Clause?
TECO: 	No position.
FPUC: 	No position.
FPL: 	FPL’s total SPPCRC cost projected for 2025 is $1,471,820,854, which includes a
total 	O&M 	expense 	of 	$134,563,013 	and 	a 	total 	capital 	expenditure 	of
$1,337,257,841. 10 	FPL’s projected SPPCRC jurisdictional revenue requirement
for the period January 2025 through December 2025 is $721,264,550.
DEF: 	No position.
OPC: 	Same as Issue 1A.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
10 See Footnote 3.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 18
ISSUE 3B: 	What jurisdictional amounts should the Commission approve as TECO’s
reasonably projected 2025 costs and projected revenue requirement amounts
for the Storm Protection Plan Cost Recovery Clause?
TECO: 	The Commission should approve reasonably projected Storm Protection Plan Cost
Recovery Clause jurisdictional revenue requirements are $116,458,022 for the
period January 2025 through December 2025.
Tampa Electric has certain proposals pending in its current base rate case in
Docket No. 20240026-EI that may affect the company’s storm protection plan
cost recovery charges and associated tariffs. The above revenue requirement may
be amended to reflect revisions ordered by the Commission in that docket.
FPUC: 	No position.
FPL: 	No position.
DEF: 	No position.
OPC: 	Same as Issue 1B.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 3C: 	What jurisdictional amounts should the Commission approve as FPUC’s
reasonably projected 2025 costs and projected revenue requirement amounts
for the Storm Protection Plan Cost Recovery Clause?
TECO: 	No position.
FPUC: 	FPUC projects total expenditures of $20.44 million, with a revenue requirement
of $4,153,106, which is net of $975,504 already recovered through base rates.
FPL: 	No position.
DEF: 	No position.
OPC: 	Same as Issue 1C.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 19
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 3D: 	What 	jurisdictional 	amounts 	should 	the 	Commission 	approve 	as 	DEF’s
reasonably projected 2025 costs and projected revenue requirement amounts
for the Storm Protection Plan Cost Recovery Clause?
TECO: 	No position.
FPUC: 	No position.
FPL: 	No position.
DEF: 	DEF’s total SPPCRC projected investments for 2025 is $845,476,201.11 DEF’s
projected SPPCRC jurisdictional revenue requirement for the period January 2025
through December 2025 is $285,580,616, based on the updated 2025 testimony of
Christopher A. Menendez and updated Exhibit CAM-3.
OPC: 	Same as Issue 1D.
FIPUG: 	Agree with OPC.
NUCOR: 	Agree with OPC.
PCS
Phosphate: 	Agree with OPC.
STAFF: 	Staff has no position at this time.
ISSUE 4A: 	What 	are 	the 	Storm 	Protection 	Plan 	Cost 	Recovery 	Clause 	total
jurisdictional cost recovery amounts, including true-ups, to be included in
establishing 2025 Storm Protection Plan Cost Recovery factors for FPL?
TECO: 	No position.
11 See Footnote 7.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 20
FPUC: 	No position.
FPL: 	The projected total SPPCRC jurisdictional revenue requirement for the period
January 	2025 	through 	December 	2025, 	including 	true-up 	amounts, 	is
$786,583,276.
DEF: 	No position.
OPC: 	Same as Issue 1A.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 4B: 	What 	are 	the 	Storm 	Protection 	Plan 	Cost 	Recovery 	Clause 	total
jurisdictional cost recovery amounts, including true-ups, to be included in
establishing 2025 Storm Protection Plan Cost Recovery factors for TECO?
TECO: 	The Storm Protection Plan Cost Recovery Clause total jurisdictional cost recovery
amounts, including true-ups, to be included in establishing Storm Protection Plan
Cost Recovery factors for the period January 2025 through December 2025 is
$117,623,744 .
Tampa Electric has certain proposals pending in its current base rate case in
Docket No. 20240026-EI that may affect the company’s storm protection plan
cost 	recovery 	charges 	and 	associated 	tariffs. 	The 	above 	jurisdictional 	cost
recovery amount may be amended to reflect revisions ordered by the Commission
in that docket.
FPUC: 	No position.
FPL: 	No position.
DEF: 	No position.
OPC: 	Same as Issue 1B.
FIPUG: 	Agree with OPC.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 21
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 4C: 	What 	are 	the 	Storm 	Protection 	Plan 	Cost 	Recovery 	Clause 	total
jurisdictional cost recovery amounts, including true-ups, to be included in
establishing 2025 Storm Protection Plan Cost Recovery factors for FPUC?
TECO: 	No position.
FPUC: 	The 	total 	amount 	upon 	which 	FPUC’s 	proposed 	factors 	are 	calculated 	is
$5,667,195, which is adjusted for taxes.
FPL: 	No position.
DEF: 	No position.
OPC: 	Same as Issue 1C.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 4D: 	What 	are 	the 	Storm 	Protection 	Plan 	Cost 	Recovery 	Clause 	total
jurisdictional cost recovery amounts, including true-ups, to be included in
establishing 2025 Storm Protection Plan Cost Recovery factors for DEF?
TECO: 	No position.
FPUC: 	No position.
FPL: 	No position.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 22
DEF: 	The projected total SPPCRC jurisdictional revenue requirement for the period
January 	2025 	through 	December 	2025, 	including 	true-up 	amounts, 	is
$269,957,058, based on the updated 2025 testimony of Christopher A. Menendez
and updated Exhibit CAM-3.
OPC: 	Same as Issue 1D.
FIPUG: 	Agree with OPC.
NUCOR: 	Agree with OPC.
PCS
Phosphate: 	Agree with OPC.
STAFF: 	Staff has no position at this time.
ISSUE 5A: 	What depreciation rates should be used to develop the depreciation expense
included in the total 2025 Storm Protection Plan Cost Recovery Clause
amounts for FPL?
TECO: 	No position.
FPUC: 	No position.
FPL: 	The depreciation rates used to calculate the depreciation expense should be the
Commission-approved depreciation rates that are in effect during the period the
allowed capital investment is in service. 	For the period January 2025 through
December 2025, FPL’s depreciation rates are those approved by Commission
Order Nos. PSC-2021-0446-S-EI and PSC-2021-0446A-S-EI in Docket No.
20210015-EI.
DEF: 	No position.
OPC: 	Same as Issue 1A.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 23
ISSUE 5B: 	What depreciation rates should be used to develop the depreciation expense
included in the total 2025 Storm Protection Plan Cost Recovery Clause
amounts for TECO?
TECO: 	The depreciation rates from Tampa Electric’s most current Depreciation Study,
approved by Order No. PSC-2021-0423-S-EI issued November 10, 2021, within
Docket No. 20210034-EI, should be and were used to develop the depreciation
expense included in the total Storm Protection Plan Cost Recovery Clause
amounts for 2025.
Tampa Electric has certain proposals pending in Docket No. 20240026-EI that
may affect the company’s storm protection plan cost recovery charges and
associated tariffs. The company’s cost recovery clause factors may be amended to
reflect any changes to depreciation rates and depreciation expense ordered by the
Commission in Docket Nos. 20230139-EI and 20240026-EI.
FPUC: 	No position.
FPL: 	No position.
DEF: 	No position.
OPC: 	Same as Issue 1B.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 5C: 	What depreciation rates should be used to develop the depreciation expense
included in the total 2025 Storm Protection Plan Cost Recovery Clause
amounts for FPUC?
TECO: 	No position.
FPUC: 	The appropriate depreciation rates are those approved in, Order No. PSC-2023-
0384-PAA-EI, issued December 21, 2023, in Docket No. 20230079-EI.
FPL: 	No Position.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 24
DEF: 	No position.
OPC: 	Same as Issue 1C.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 5D: 	What depreciation rates should be used to develop the depreciation expense
included in the total 2025 Storm Protection Plan Cost Recovery Clause
amounts for DEF?
TECO: 	No position.
FPUC: 	No position.
FPL: 	No position.
DEF: 	For the period January 2025 through December 2025, DEF should use the
depreciation rates that were approved in Final Order No. PSC-2021-0202A-AS-
EI, consistent with DEF’s settlement agreement filed on July 15, 2024, in Docket
No. 20240025-EI and reflected in the updated 2025 testimony of Christopher A.
Menendez and updated Exhibit CAM-3.
OPC: 	Same as Issue 1D.
FIPUG: 	Agree with OPC.
NUCOR: 	Agree with OPC.
PCS
Phosphate: 	Agree with OPC.
STAFF: 	Staff has no position at this time.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 25
ISSUE 6A: 	What are the appropriate 2025 jurisdictional separation factors for FPL?
TECO: 	No position.
FPUC: 	No position.
FPL: 	As shown on page 1 of Exhibit RLH-4, FPL’s retail jurisdictional separation
factors for the period January 2025 through December 2025 are:
DEMAND
Transmission 	0.887807
Non-Stratified Production 	0.960110
Intermediate Strata Production 	0.954157
Peaking Strata Production 	0.949428
Distribution 	1.000000
ENERGY
Total Sales 	0.938401
Non-Stratified Sales 	0.957062
Intermediate Strata Sales 	0.939405
Peaking Strata Sales 	0.956020
GENERAL PLANT
Labor 	0.969425
DEF: 	No position.
OPC: 	Same as Issue 1A.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 26
ISSUE 6B: 	What are the appropriate 2025 jurisdictional separation factors for TECO?
TECO: 	The appropriate jurisdictional separation factors are as follows:
FPSC Jurisdictional Factor: 	93.5213%
FERC Jurisdictional Factor: 	6.4787%
FPUC: 	No position.
FPL: 	No position.
DEF: 	No position.
OPC: 	Same as Issue 1B.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 6C: 	What are the appropriate 2025 jurisdictional separation factors for FPUC?
TECO: 	No position.
FPUC: 	There is no jurisdictional separation applicable to FPUC.
FPL: 	No position.
DEF: 	No position.
OPC: 	Same as Issue 1C.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 27
ISSUE 6D: 	What are the appropriate 2025 jurisdictional separation factors for DEF?
TECO: 	No position.
FPUC: 	No position.
FPL: 	No position.
DEF: 	As shown in updated Exhibit CAM-3, DEF’s retail jurisdictional separation
factors for the period January 2025 through December 2025 are:
DEMAND
Transmission: 0.703692
Distribution: 	1.000000
OPC: 	Same as Issue 1D.
FIPUG: 	Agree with OPC.
NUCOR: 	Agree with OPC.
PCS
Phosphate: 	Agree with OPC.
STAFF: 	Staff has no position at this time.
ISSUE 7A: 	What are the appropriate 2025 Storm Protection Plan Cost Recovery Clause
factors for each rate class for FPL?
TECO: 	No position.
FPUC: 	No position.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 28
FPL: 	As shown on Form 5P of Exhibit RLH-3, p. 15, the appropriate FPL 2025
SPPCRC factors for each rate class are as follows:
Rate Class
SPP
Factor
($/kW)
SPP
Factor
($/kWh)
RDC
($/KW)
SDD
($/KW)
RS1/RTR1 	0.00810
GS1/GST1 	0.00730
GSD1/GSDT1/HLFT1/GSD1-EV 	1.42
OS2 	0.02199
GSLD1/GSLDT1/CS1/CST1/HLFT2/GSLD1-EV 	1.44
GSLD2/GSLDT2/CS2/CST2/HLFT3 	1.32
GSLD3/GSLDT3/CS3/CST3 	0.16
SST1T 	0.02 	0.01
SST1D1/SST1D2/SST1D3 	0.23 	0.10
CILC D/CILC G 	1.34
CILC T 	0.17
MET 	1.60
OL1/SL1/SL1M/PL1/OSI/II 	0.00558
SL2/SL2M/GSCU1 	0.00683
DEF: 	No position.
OPC: 	Same as Issue 1A.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 7B: 	What are the appropriate 2025 Storm Protection Plan Cost Recovery Clause
factors for each rate class for TECO?
TECO: 	The appropriate January 2025 through December 2025 cost recovery clause
factors 	utilizing 	the 	appropriate 	recognition 	of 	Federal 	Energy 	Regulatory
Commission transmission jurisdictional separation, revenue tax factors and the
rate design and cost allocation as put forth in Docket No. 20210034-EI are as
follows:

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 29
Cost Recovery Factors
Rate Schedule 	(cents per kWh)
RS 	0.838
GS and CS 	1.040
GSD Optional – Secondary 	0.188
GSD Optional – Primary 	0.186
GSD Optional – Subtransmission 	0.184
LS-1, LS-2 	5.246
Cost Recovery Factors
Rate Schedule 	(dollars per kW)
GSD – Secondary 	0.77
GSD – Primary 	0.76
GSD – Subtransmission 	0.76
SBD – Secondary 	0.77
SBD – Primary 	0.76
SBD – Subtransmission 	0.76
GSLD - Primary 	0.64
GSLD - Subtransmission 	0.15
Tampa Electric has certain proposals pending in its current base rate case in
Docket No. 20240026-EI that may affect the company’s storm protection plan
cost recovery charges and associated tariffs. The above cost recovery clause
factors may be amended to reflect revisions ordered by the Commission in that
docket.
FPUC: 	No position.
FPL: 	No position.
DEF: 	No position.
OPC: 	Same as Issue 1B.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 30
ISSUE 7C: 	What are the appropriate 2025 Storm Protection Plan Cost Recovery Clause
factors for each rate class for FPUC?
TECO: 	No position.
FPUC:
Rate Schedule 	SPP
FACTORS
PER KWH
Residential 	$0.00997
General Service 	$0.01100
General Service Demand 	$0.00594
General Service Large Demand 	$0.00508
Industrial/Standby 	$0.01402
Lighting Service 	$0.06177
FPL: 	No position.
DEF: 	No position.
OPC: 	Same as Issue 1C.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 7D: 	What are the appropriate 2025 Storm Protection Plan Cost Recovery Clause
factors for each rate class for DEF?
TECO: 	No position.
FPUC: 	No position.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 31
FPL: 	No position.
DEF: 	As shown in Form 6P of updated Exhibit CAM-3, the appropriate DEF 2025
SPPCRC factors for each rate class are as follows:
Customer Class 	SPPCRC Factor
Residential 	0.801 cents/kWh
General Service Non-Demand 	0.694 cents/kWh
@ Primary Voltage 	0.687 cents/kWh
@ Transmission Voltage 	0.680 cents/kWh
General Service 100% Load Factor 	0.355 cents/kWh
General Service Demand 	1.92 $/kW
@ Primary Voltage 	1.90 $/kW
@ Transmission Voltage 	0.33 $/kW
Curtailable 	1.15 $/kW
@ Primary Voltage 	1.14 $/kW
@ Transmission Voltage 	1.13 $/kW
Interruptible 	1.54 $/kW
@ Primary Voltage 	1.26 $/kW
@ Transmission Voltage 	0.25 $/kW
Standby Monthly 	0.170 $/kW
@ Primary Voltage 	0.168 $/kW
@ Transmission Voltage 	0.167 $/kW
Standby Daily 	0.081 $/kW
@ Primary Voltage 	0.080 $/kW
@ Transmission Voltage 	0.079 $/kW
Lighting 	0.586 cents/kWh
OPC: 	Same as Issue 1D.
FIPUG: 	Agree with OPC.
NUCOR: 	Agree with OPC.
PCS
Phosphate: 	Agree with OPC.
STAFF: 	Staff has no position at this time.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 32
ISSUE 8A: 	What should be the effective date of the 2025 Storm Protection Plan Cost
Recovery Clause factors for billing purposes for FPL?
TECO: 	No position.
FPUC: 	No position.
FPL: 	The 2025 SPPCRC Factors should become effective for application to bills
beginning the first billing cycle in January 2025 through the last billing cycle
December 2025 and continuing until modified by subsequent order of this
Commission.
DEF: 	No position.
OPC: 	Same as Issue 1A.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 8B: 	What should be the effective date of the 2025 Storm Protection Plan Cost
Recovery Clause factors for billing purposes for TECO?
TECO: 	The effective date of the new Storm Protection Plan Cost Recovery Clause factors
should be January 1, 2025.
FPUC: 	No position.
FPL: 	No position.
DEF: 	No position.
OPC: 	Same as Issue 1B.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 33
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 8C: 	What should be the effective date of the 2025 Storm Protection Plan Cost
Recovery Clause factors for billing purposes for FPUC?
TECO: 	No position.
FPUC: 	The effective date for FPUC's cost recovery factors should be the first billing
cycle for January 1, 2025, which could include some consumption from the prior
month. 	Thereafter, customers should be billed the approved factors for a full 12
months, unless the factors are otherwise modified by the Commission.
FPL: 	No position.
DEF: 	No position.
OPC: 	Same as Issue 1C.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 8D: 	What should be the effective date of the 2025 Storm Protection Plan Cost
Recovery Clause factors for billing purposes for DEF?
TECO: 	No position.
FPUC: 	No position.
FPL: 	No position.
DEF: 	The factors shall be effective beginning with the specified Storm Protection Plan
Cost Recovery Clause cycle and thereafter for the period January 2025 through
December 2025. Billing cycles may start before January 1, 2025, and the last
cycle may be read after December 31, 2025, so that each customer is billed for

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 34
twelve months, regardless of when the adjustment factor became effective. These
charges shall continue in effect until modified by subsequent order of this
Commission.
OPC: 	Same as Issue 1D.
FIPUG: 	Agree with OPC.
NUCOR: 	Agree with OPC.
PCS
Phosphate: 	Agree with OPC.
STAFF: 	Staff has no position at this time.
ISSUE 9A: 	Should the Commission approve revised tariffs reflecting the 2025 Storm
Protection Plan Cost Recovery Clause factors determined to be appropriate
in this proceeding for FPL?
TECO: 	No position.
FPUC: 	No position.
FPL: 	Yes. FPL will submit to Staff for administrative approval revised tariffs reflecting
the SPPCRC amounts and SPPCRC Factors approved in this proceeding.
DEF: 	No position.
OPC: 	Same as Issue 1A.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 35
ISSUE 9B: 	Should the Commission approve revised tariffs reflecting the 2025 Storm
Protection Plan Cost Recovery Clause factors determined to be appropriate
in this proceeding for TECO?
TECO: 	Yes, the Commission should approve revised tariffs reflecting the new Storm
Protection Plan Cost Recovery Clause factors determined to be appropriate in this
proceeding.
The Commission should also grant Staff administrative authority to approve
revised tariffs reflecting amended cost recovery clause factors that incorporate
any revisions that are necessary as a result of the Commission’s decision in
Tampa Electric’s current base rate case in Docket No. 20240026-EI.
FPUC: 	No position.
FPL: 	No position.
DEF: 	No position.
OPC: 	Same as Issue 1B.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 9C: 	Should the Commission approve revised tariffs reflecting the 2025 Storm
Protection Plan Cost Recovery Clause factors determined to be appropriate
in this proceeding for FPUC?
TECO: 	No position.
FPUC: 	The Company will submit, and the Commission should authorize its staff to approve
administratively, revised tariffs reflecting the SPPCRC factors determined to be
appropriate in this proceeding. The Commission should direct staff to verify that the
revised tariffs are consistent with the Commission’s decision.
FPL: 	No position.
DEF: 	No position.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 36
OPC: 	Same as Issue 1C.
FIPUG: 	Agree with OPC.
NUCOR: 	No position.
PCS
Phosphate: 	No position.
STAFF: 	Staff has no position at this time.
ISSUE 9D: 	Should the Commission approve revised tariffs reflecting the 2025 Storm
Protection Plan Cost Recovery Clause factors determined to be appropriate
in this proceeding for DEF?
TECO: 	No position.
FPUC: 	No position.
FPL: 	No position.
DEF: 	Yes. The Commission should approve DEF’s revised tariffs reflecting the Storm
Protection Plan Cost Recovery Clause factors determined to be appropriate in this
proceeding. The Commission should direct Staff to verify that the revised tariffs
are consistent with the Commission’s decision. The Commission should grant
Staff Administrative authority to approve revised tariffs reflecting the new Storm
Protection Plan Cost Recovery Clause factors determined to be appropriate in this
proceeding.
OPC: 	Same as Issue 1D.
FIPUG: 	Agree with OPC.
NUCOR: 	Agree with OPC.
PCS
Phosphate: 	Agree with OPC.
STAFF: 	Staff has no position at this time.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 37
ISSUE 10: 	Should this docket be closed?
TECO: 	No. The storm protection plan cost recovery clause is a continuing docket and
should remain open until a new docket number is assigned next year.
FPUC: 	This is a continuing docket and should remain open.
FPL: 	No. 	While a separate docket number is assigned each year for administrative
convenience, this is a continuing docket and should remain open.
DEF: 	No, this is an on-going docket and should remain open until a subsequent year’s
docket is established.
OPC: 	Same as Issues 1A-1D.
FIPUG: 	Agree with OPC.
NUCOR: 	Agree with OPC.
PCS
Phosphate: 	Agree with OPC.
STAFF: 	Staff has no position at this time.
X. 	EXHIBIT LIST
Witness 	Proffered
By
Description
Direct
M. Ashley Sizemore 	TECO 	MAS-1 	A-Schedules, filed April 1, 2024 -
Schedules Supporting Storm
Protection Cost Recovery Factor,
Actual for the period January 2023 –
December 2023

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 38
Witness 	Proffered
By
Description
M. Ashley Sizemore 	TECO 	MAS-2 	E-Schedules, filed May 1, 2024;
revised July 26, 2024 - Schedules
supporting cost recovery amount,
projected January 2024-December
2024
P-Schedules, filed May 1, 2024;
revised July 26, 2024 - Schedules
supporting costs recovery amount,
projected for the period January
2025–December 2025, Projected -
Current
M. Ashley Sizemore 	TECO 	MAS-3 	P-Schedules, filed May 1, 2024;
revised July 26, 2024 - Schedules
supporting costs recovery amount,
projected for the period January
2025–December 2025, Projected -
Proposed
C. David Sweat 	TECO 	CDS-1 	Tampa Electric Company, 2023
Storm Protection Plan
Accomplishments
C. David Sweat 	TECO 	CDS-2 	Project List and Summary of Costs
Michelle D. Napier
C. David Cutshaw
(Schedule 8A only)
FPUC 	PTN-1
(Exhibit of
Phuong
Nguyen
adopted by
Napier)
SPPCRC Schedules 1A-9A
Michelle D. Napier 	FPUC 	MDN-2 	SPPCRC Schedules E and P
Michael Jarro 	FPL 	MJ-1 	FPL Actual Storm Protection Plan
Work Completed in 2023 (Project
Level Detail)
Michael Jarro 	FPL 	MJ-2 	List of Explanations of Drivers for
Variances in Storm Protection Plan
Programs and Projects
Michael Jarro 	FPL 	MJ-3 	Form 6P – Program Description and
Progress Report

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 39
Witness 	Proffered
By
Description
Michael Jarro 	FPL 	MJ-4 	FPL Actual/Estimated Storm
Protection Plan Work to be
Completed in 2024 (Project Level
Detail)
Michael Jarro 	FPL 	MJ-5 	FPL Storm Protection Plan Work
Projected to be Completed in 2025
(Project Level Detail)
Richard L. Hume 	FPL 	RLH-1
(corrected by
Errata filed
on May 17,
2024)
Forms 1A through 8A for the FPL
2023 SPPCRC Final True-Up
Richard L. Hume 	FPL 	RLH-2 	Forms 1E through 8E for the FPL
2024 SPPCRC Actual/Estimated
True-Up
Richard L. Hume 	FPL 	RLH-3 	Forms 1P through 5P and 7P for
FPL’s Proposed 2025 SPPCRC
Factors
Richard L. Hume 	FPL 	RLH-4 	Retail Separation Factors
Christopher A. Menendez
Robert E. McCabe
Robert E. Brong
DEF 	CAM-1 	True-up costs associated with the
SPPCRC activities for the period
January 2023 through December
2023
Distribution-related costs associated
with DEF’s Storm Protection Plan
(“SPP”) proposed for recovery
through the Storm Protection Plan
Cost Recovery Clause (“SPPCRC”)
for 2023
Transmission-related costs associated
with DEF’s Storm Protection Plan
(“SPP”) proposed for recovery
through the Storm Protection Plan
Cost Recovery Clause (“SPPCRC”)
for 2023

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 40
Witness 	Proffered
By
Description
Christopher A. Menendez
Robert E. McCabe
Robert E. Brong
DEF 	CAM-2 	Actual/estimated true-up for the
period January 2024 through
December 2024
Distribution-related costs associated
with DEF’s Storm Protection Plan
(“SPP”) proposed for recovery
through the Storm Protection Plan
Cost Recovery Clause (“SPPCRC”)
for 2024
Transmission-related costs associated
with DEF’s Storm Protection Plan
(“SPP”) proposed for recovery
through the Storm Protection Plan
Cost Recovery Clause (“SPPCRC”)
for 2024.
Christopher A. Menendez
Robert E. McCabe
Robert E. Brong
DEF 	CAM-3
(Revised
7.31.24)
Projected costs for the SPPCRC for
the period January 2025 through
December 2025, and DEF’s Storm
Protection Plan cost recovery factors
for the period January 2025 through
December 2025
Distribution-related costs associated
with DEF’s Storm Protection Plan
(“SPP”) proposed for recovery
through the Storm Protection Plan
Cost Recovery Clause (“SPPCRC”)
for 2025
Transmission-related costs associated
with DEF’s Storm Protection Plan
(“SPP”) proposed for recovery
through the Storm Protection Plan
Cost Recovery Clause (“SPPCRC”)
for 2025
Tomer Kopelovich 	Staff 	TK-1 	Auditor’s Report - FPL
Ron Mavrides 	Staff 	RM-1 	Auditor’s Report – TECO

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 41
Witness 	Proffered
By
Description
Donna D. Brown 	Staff 	DDB-1 	Auditor’s Report - DEF
Donna D. Brown 	Staff 	DDB-2 	Auditor’s Report – FPUC
XI. 	PROPOSED STIPULATIONS
On September 5, 2024, FPL filed a set of proposed stipulations that would fully resolve
all FPL issues in this docket. A true and correct copy of those stipulations is appended to this
order as Attachment A.
On September 9, 2024, TECO filed a set of proposed stipulations that would fully resolve
all TECO issues in this docket. A true and correct copy of those stipulations is appended to this
order as Attachment B.
On September 9, 2024, FPUC filed a set of proposed stipulations that would fully resolve
all FPUC issues in this docket. A true and correct copy of those stipulations is appended to this
order as Attachment C.
On September 6, 2024, DEF filed a set of proposed stipulations that would fully resolve
all DEF issues in this docket. A true and correct copy of those stipulations is appended to this
order as Attachment D.
XII. 	PENDING MOTIONS
There are no pending motions at this time.
XIII. 	PENDING CONFIDENTIALITY MATTERS
There are no pending confidentiality matters at this time.
XIV. 	POST-HEARING PROCEDURES
If no bench decision is made, each party shall file a post-hearing statement of issues and
positions. A summary of each position, set off with asterisks, shall be included in that statement.
If a party's position has not changed since the issuance of this Prehearing Order, the post-hearing
statement may simply restate the prehearing position. 	If a party fails to file a post-hearing
statement, that party shall have waived all issues and may be dismissed from the proceeding.

PSC-2024-0426-PHO-EI
17th
September 2024
ORDER NO.
DOCKET NO. 20240010-El
PAGE 42
Pursuant to Rule 28-106.215, F.A.C., a party's proposed find ings of fact and conclusions
of law, if any, statement of issues and positions, and brief, sha ll together total no more than 40
pages and shall be fi led at the same time.
XV. 	RU LINGS
Opening statements, if any, shall not exceed three minutes per party.
It is therefore,
ORDERED by Commissioner Gabriella Passidomo, as Prehearing Officer, that this
Prehearing Order sha ll govern the conduct of these proceedings as set forth above unless
modified by the Commission.
By ORDER of Commissioner Gabriella Passidomo, as Prehearing Officer, this __ day
of -------
SPS
Gabrie ll a Passidomo
Commissioner and Prehearing Officer
Florida Public Service Commission
2540 Shumard Oak Boulevard
Tallahassee, Florida 32399
(850) 413-6770
www.floridapsc.com
Copies furnished: 	A copy of this document is
provided to the parties of record at the time of
issuance and, if applicable, interested persons.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 43
NOTICE OF FURTHER PROCEEDINGS OR JUDICIAL REVIEW
The Florida Public Service Commission is required by Section 120.569(1), Florida
Statutes, to notify parties of any administrative hearing or judicial review of Commission orders
that is available under Sections 120.57 or 120.68, Florida Statutes, as well as the procedures and
time limits that apply. 	This notice should not be construed to mean all requests for an
administrative hearing or judicial review will be granted or result in the relief sought.
Mediation may be available on a case-by-case basis. 	If mediation is conducted, it does
not affect a substantially interested person's right to a hearing.
Any 	party 	adversely 	affected 	by 	this 	order, 	which 	is 	preliminary, 	procedural 	or
intermediate in nature, may request: (1) reconsideration within 10 days pursuant to Rule 25-
22.0376, Florida Administrative Code; or (2) judicial review by the Florida Supreme Court, in
the case of an electric, gas or telephone utility, or the First District Court of Appeal, in the case
of a water or wastewater utility. 	A motion for reconsideration shall be filed with the Office of
Commission Clerk, in the form prescribed by Rule 25-22.0376, Florida Administrative Code.
Judicial review of a preliminary, procedural or intermediate ruling or order is available if review
of the final action will not provide an adequate remedy. Such review may be requested from the
appropriate court, as described above, pursuant to Rule 9.100, Florida Rules of Appellate
Procedure.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment A
PAGE 44 Page | of 8

FILED 9/5/2024
DOCUMENT NO. 08878-2024
FPSC - COMMISSION CLERK

Christopher T. Wright
VW Managing Attomey
Florida Power & Light Company
700 Universe Blvd (LAW/JB)
FPL. Juno Beach, FL 33408-0420
é Phone: (561) 691-7144
E-mail: Christopher. Wnght@ fpLcom

Florida Authorized House Counsel;
Admitted in Pennsylvania

Florida Power & Light Company
700 Universe Boulevard, Juno Beach, FL 33408

Page | 1

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment A
PAGE 45 Page 2 of 8

CERTIFICATE OF SERVICE

| HEREBY CERTIFY that a true and correct copies of the foregoing have been furnished by
Electronic Mail to the following parties of record this 5th day of September 2024:

Shaw Stiller Office of Public Counsel

Jennifer Crawford c/o The Florida Legislature
Daniel Dose 111 West Madison Street, Room 812
Florida Public Service Commission Tallahassee, FL 32399-1400

2540 Shumard Oak Boulevard christensen. patty‘@leg. state. fl.us
Tallahassee, FL 32399 ponce. octavio@)leg. state. fl. us
ddose@psc. state. fl.us rehwinkel. charles@lee. state. fl.us
sstiller(@psc.state. fl.us Trierweiler. walt(@ley state. fl.us
jcrawfor‘@psc. state. fl. us watrous.austin(@leg. state. fl_us
discovery-gcl(@ psc. state. fl.us wessling. mary(@leg. state. fl. us

For Commission Staff For Office of Public Counsel

J. Jeffrey Wahlen Beth Keating

Malcolm M. Means Gunster, Yoakley & Stewart, P.A.
Virginia Ponder 215 South Monroe St., Suite 601
Ausley McMullen Tallahassee, FL 32301

Post Office Box 391 BKeatine‘@gunster.com
Tallahassee, Florida 32302

jwahlen@ausley.com Mr. Mike Cassel
mmeans/dausley.com 208 Wildlight Ave.
vponder‘cjausley.com Yulee FL 32097

mceassel(@fpuc. com
Ms. Paula K. Brown

Regulatory Affairs Michelle D. Napier/Phuong Nguyen
P. O. Box 111 1635 Meathe Drive
Tampa FL 33601-0111 West Palm Beach FL 33411
reedept@tecoenergy.com mnapier(@fpuc.com
For Tampa Electric Company pnguyen@chpk.com

For Florida Public Utilities Company
Peter J. Mattheis Dianne M. Triplett
Michael K. Lavanga Deputy General Counsel
Joseph R. Briscar Duke Energy Florida, LLC
Stone Mattheis Xenopoulos & Brew, PC 299 First Avenue North
1025 Thomas Jefferson Street, NW S1. Petersburg, FL 33701
Suite 800 West Dianne. Tripleti‘@:Duke-Energy.com
Washington DC 20007
irb/@jsmx blaw.com Matthew R. Bernier
mkli@smxblaw.com Robert L. Pickels
pim@smxblaw.com Stephanie A. Cuello

106 E. College Avenue, Suite 800
Corey Allain Tallahassee FL 32301
22 Nucor Drive FLReeulatory Legal ‘@jduke-energy.com
Frostproof FL 33843 matthew. bernier@)duke-energy.com
corey. allainf@nucor.com robert. pickels‘@jduke-energy.com
For NaCor Steel Florida, Ine. stephanie. cuello‘@duke-energy.com

For Duke Energy Florida, LLC

ORDER NO. PSC-2024-0426-PHO-EI

DOCKET NO. 20240010-EI Attachment A
PAGE 46 Page 3 of 8

Jon C. Moyle, Jr. James W. Brew

Moyle Law Firm, P.A. Laura Wynn Baker

118 North Gadsden Street Stone Mattheis Xenopoulos & Brew, PC

Tallahassee, Florida 32301 1025 Thomas Jefferson Street, NW

Telephone: (850) 681-3828 Suite 800 West

Facsimile; (850) 681-8788 Washington, DC 20007-5201

imoyle@moylelaw.com jbrew@smxblaw.com

mqualls@moylelaw.com lwbid@smxblaw.com

For Florida Industrial Power Users Group For PCS Phosphate - White Springs

s/ Christopher T. Wright
Christopher T. Wright
Fla. Auth. House Counsel No. 1007055

Attorney for Florida Power & Light Company

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment A
PAGE 47 Page 4 of 8

BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION

In re: Storm Protection Plan Cost Recovery | Docket No. 20240010-EI
Clause

STIPULATIONS AND PROPOSED RESOLUTIONS

Florida Power & Light Company (“FPL” or the “Company”) and the Office of Public

Counsel (“OPC”) (hereinafter collectively referred to as “Parties”) herby agree to submit for

annraval hu tha Elasida Duhkhlia Gariiaa Cameminaian (SO awesiasine!\ tha fallacwdan C4

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment A
PAGE 48 Page 5 of 8

into the record.
4, To the extent there are proposed Type 2 stipulations! for Issue Nos. 1A, 2A, 3A, 4A, 5A,

6A, 7A, 8A, 9A, and 10, FPL supports the proposed stipulations and OPC will take no

As such, OPC further represents that it takes no position on, and thus will not
contest or oppose the Commission taking action approving a proposed
stipulation between the Company and another party or Staff as to a final
resolution of, Issue Nos. 1A, 2A, 3A, 4A, 5A, 6A, 7A, 8A, 9A, and 10. No
person is authorized to state that the OPC is a participant in, or party to, a
stipulation on these issues, either in this docket, in an order of the Commission

Awe in a rancanantatinn tan MT ave

includes a total O&M expense of $96,591,030 and a total capital expenditure of
$1,274,851,904.2 FPL’s SPPCRC final jurisdictional revenue requirement true-
up for the period January 2023 through December 2023, including interest, is
an under-recovery of $5,648,042.

Issue 2A: FPL’s total SPPCRC cost estimated for 2024 is $1,540,725,072, which includes

a tntal ORAA avnancs nf C194 009 NN and a é¢atal nnetenl ner n dee. A

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment A
PAGE 49 Page 6 of 8

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI

PAGE 50

Attachment A
Page 7 of 8
Rate Class A La ED all
(skw) | (g/kWhy | S/S) | KW)
RSI/RTRI 0.00810
GSI/GST1 0.00730
GSDI/GSDTI/HLFT1/GSDI1-EV 1.42
O82 0.02199
GSLDI/GSLDTI/CS1/CST1/HLFT2/GSLDI-EV 1,44
GSLD2/GSLDT2/CS2/CST2/HLFT3 1,32
GSLD3/GSLDT3/CS3/CST3 0.16
SSTIT 0.02 0.01
SSTIDI/SST1D2/SST1D3. 0.23 0.10
CILC D/CILC G 1.34
CILC T 0.17
MET 1.60
OL1/SL1/SLIM/PLI/OSI/IL 0.00558
SL2/SL2M/GSCU1 0.00683

Issue 8A: The 2025 SPPCRC Factors should become effective for application to bills

Issue 9A:

Issue 10:

Yes.

beginning the first billing cycle in January 2025 through the last billing cycle
December 2025 and continuing until modified by subsequent order of this
Commission:

FPL will submit to Staff for administrative approval revised tariffs
reflecting the SPPCRC amounts and SPPCRC Factors approved in this
proceeding.

No. While a separate docket number is assigned each year for administrative
convenience, this is a continuing docket and should remain open.

The Parties stipulate and agree that the issue resolutions set out above address all issues in

Docket No. 20240010-EI with respect to FPL and accordingly, are ripe to be approved by

the Commission.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment A

PAGE 51 Page 8 of 8

In Witness Whereof, FPL and OPC evidence their acceptance and agreement with the aforesaid

stipulations and proposed resolutions by their signature.

Florida ne et

VAte Prewiderit and General Counsel
orida Power & Light Company
00 Universe Boulevard

Juno Beach, FL 33408-0420

Office of Public Counsel

f
f 2, . * r
By: iad? J ianpoln 2 Date: {7 ee4

Walt Trierweiler

Public Counsel

Office of Public Counsel

111 West Madison Street, Room 812
Tallahassee, FL. 32399-1400

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment B
PAGE 52 Page | of 8

FILED 9/9/2024
DOCUMENT NO. 08937-2024
FPSC - COMMISSION CLERK

BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
In re: Storm Protection Plan Cost Recovery DOCKET NO. 20240010-EI

Clause
FILED: September 9, 2024

STIPULATIONS AND PROPOSED RESOLUTION
Tampa Electric Company (“Tampa Electric” or the “company”) and the Office of Public
Counsel (“OPC”) (hereinafter collectively referred to as “Parties”) hereby agree to submit for
Florida Public Service Commission (“Commission”) approval the following Stipulations and
Proposed Resolution for the issues to be addressed in Docket No. 20240010-EI on the following
terms and conditions:
ls The Parties stipulate to entry of the following pre-filed testimony and exhibits filed in this
docket entered into the record:
a. The Direct Testimony of Tampa Electric witness M. Ashley Sizemore and
Exhibit MAS-1, filed April 1, 2024;
b. The Direct Testimony of Tampa Electric witness C. David Sweat and Exhibit
CDS-1, filed April 1, 2024;
c. The Direct Testimony of Tampa Electric witness M. Ashley Sizemore and
Exhibits MAS-2 and MAS-3, as revised on July 26, 2024;
d. The Direct Testimony of Tampa Electric witness C. David Sweat and Exhibit
CDS-2, filed July 26, 2024;

e. The Direct Testimony of Staff witness Ron Mavrides filed on July 1, 2024,

along with Exhibit RM-1.

ORDER NO. PSC-2024-0426-PHO-EI

DOCKET NO. 20240010-EI Attachment B
PAGE 53 Page 2 of 8
2s The Parties agree to waive cross-examination of all Tampa Electric and Staff witnesses in

Docket No. 20240010-EI and, upon Commission approval, have no objection to such
witnesses being excused from appearing at the hearing.

Ep The Parties stipulate to entry of the following exhibits identified on Staff's Comprehensive
Exhibit List into the record for the above-captioned docket: Exhibit Nos. 2-6, 22, and 29-
5h

4, To the extent there are proposed Type 2 stipulations' for Issue Nos. 1B, 2B, 3B, 4B, 5B,
6B, 7B, 8B, 9B, and 10, Tampa Electric supports the stipulations and OPC will take no
position on each issue and thereby will facilitate a Type 2 stipulation on each of these issues
as follows:

OPC takes no position on Tampa Electric proposed Storm Protection Plan Cost
Recovery Clause (SPPCRC) Factors, nor does it have the burden of proof
related to them. As such, OPC further represents that it takes no position on,
and thus will not contest or oppose the Commission taking action approving a
proposed stipulation between the Company and another party or Staff as to a
final resolution of, Issue Nos. 1B, 2B, 3B, 4B, 5B, 6B, 7B, 8B, 9B, and 10. No
person is authorized to state that the OPC is a participant in, or party to, a
stipulation on these issues, either in this docket, in an order of the Commission
or in a representation to a Court.

5. Tampa Electric’s positions subject to the Type 2 stipulations described above, if approved,
are as follows:

Issue 1B: Tampa Electric’s final Storm Protection Plan Cost Recovery Clause
jurisdictional revenue requirements are $70,079,782 and jurisdictional cost
recovery true-up under-recovery amount is $459,097 for the period January
2023 through December 2023 including interest.

Issue 2B: Tampa Electric’s actual/estimated Storm Protection Plan Cost Recovery Clause
jurisdictional revenue requirements are $90,297,357 and jurisdictional

| A Type 2 stipulation occurs on an issue when the utility and the staff, or the utility and at least one party adversarial
to the utility, agree on the resolution of the issue and the remaining parties (including staff if they do not join in the
agreement) do not object to the Commission relying on the agreed language to resolve that issue in a final order.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment B
PAGE 54 Page 3 of 8

estimated cost recovery true-up under-recovery amount is $606,964 for the
period January 2024 through December 2024 including interest.

Issue 3B: Tampa Electric’s projected Storm Protection Plan Cost Recovery Clause
jurisdictional revenue requirements are $1 16,458,022 for the period January
2025 through December 2025.

Tampa Electric has certain proposals pending in its current base rate case in
Docket No. 20240026-El that may affect the company’s storm protection plan
cost recovery charges and associated tariffs. The above revenue requirement
may be amended to reflect revisions ordered by the Commission in that docket.

Issue 4B: The Storm Protection Plan Cost Recovery Clause total jurisdictional cost
recovery amounts, including true-ups, to be included in establishing Storm
Protection Plan Cost Recovery factors for the period January 2025 through
December 2025 is $117,623,744 .

Tampa Electric has certain proposals pending in its current base rate case in
Docket No. 20240026-El that may affect the company’s storm protection plan
cost recovery charges and associated tariffs. The above jurisdictional cost
recovery amount may be amended to reflect revisions ordered by the
Commission in that docket.

Issue 5B: The depreciation rates from Tampa Electric’s most current Depreciation Study,
approved by Order No. PSC-2021-0423-S-El issued November 10, 2021,
within Docket No. 20210034-El, should be and were used to develop the
depreciation expense included in the total Storm Protection Plan Cost Recovery
Clause amounts for 2025.

Tampa Electric has certain proposals pending in Docket No. 20240026-EI that
may affect the company’s storm protection plan cost recovery charges and
associated tariffs. The company’s cost recovery clause factors may be amended
to reflect any changes to depreciation rates and depreciation expense ordered
by the Commission in Docket Nos. 20230139-EI and 20240026-EI.

Issue 6B: The appropriate jurisdictional separation factors are as follows:
FPSC Jurisdictional Factor: 93.5213%
FERC Jurisdictional Factor: 6.4787%

Issue 7B: The appropriate January 2025 through December 2025 cost recovery clause
factors utilizing the appropriate recognition of Federal Energy Regulatory

Commission transmission jurisdictional separation, revenue tax factors and the
rate design and cost allocation as put forth in Docket No. 20210034-EI are as

follows:

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment B
PAGE 55 Page 4 of 8

Cost Recovery Factors

Rate Schedule (cents per kWh)
RS 0.838
GS and CS 1.040
GSD Optional — Secondary 0.188
GSD Optional — Primary 0.186
GSD Optional — Subtransmission 0.184
LS-1, LS-2 5.246

Cost Recovery Factors

Rate Schedule (dollars per kW)
GSD — Secondary 0.77
GSD — Primary 0.76
GSD — Subtransmission 0.76
SBD — Secondary 0.77
SBD — Primary 0.76
SBD — Subtransmission 0.76
GSLD - Primary 0.64
GSLD - Subtransmission 0.15

Tampa Electric has certain proposals pending in its current base rate case in
Docket No. 20240026-E] that may affect the company’s storm protection plan
cost recovery charges and associated tariffs. The above cost recovery clause
factors may be amended to reflect revisions ordered by the Commission in that
docket.

Issue 8B: The effective date of the new Storm Protection Plan Cost Recovery Clause
factors should be January 1, 2025.

Issue 9B: Yes, the Commission should approve revised tariffs reflecting the new Storm
Protection Plan Cost Recovery factors determined to be appropriate in this
proceeding.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment B
PAGE 56 Page 5 of 8

The Commission should also grant Staff administrative authority to approve
revised tariffs reflecting amended cost recovery clause factors that incorporate
any revisions that are necessary as a result of the Commission’s decision in
Tampa Electric’s current base rate case in Docket No. 20240026-EI.

Issue 10: No. The storm protection plan cost recovery clause is a continuing docket and
should remain open until a new docket number is assigned next year.

6. The Parties stipulate and agree that the issue resolutions set out above address all issues in

Docket No. 20240010-EI and accordingly, are ripe for approval by the Commission.

[REMAINDER OF PAGE INTENTIONALLY BLANK]

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI

PAGE 57

Attachment B
Page 6 of 8

In Witness Whereof, Tampa Electric and OPC evidence their acceptance and agreement with the

aforesaid stipulations and proposed resolutions by their signature.

Tampa Electric Company
Name: Malcolm N. Means

Title: Attorney for Tampa Electric Company

Signature: NWL2, h. :

Date: 9/09/24

Office of Public Counsel

Name: Walt Trierweiler, Esquire

Title: Public Counsel

ry &
s naure Ld bu F

Date: Tf 4 2024

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 58

Attachment B
Page 7 of 8

CERTIFICATE OF SERVICE

| HEREBY CERTIFY that a true and correct copy of the foregoing Joint Notice of
Stipulations, filed on behalf of Tampa Electric Company, has been furnished by electronic mail on

this 9th day of September 2024 to the following:

Daniel Dose

Jennifer Crawford

Shaw Stiller

Office of General Counsel

Florida Public Service Commission

Room 390L — Gerald L. Gunter Building

2540 Shumard Oak Boulevard
Tallahassee, FL 32399-0850
ddose@psc.state.fl.us
jcrawfor@psc.state.fl.us
sstiller(@psc.state.fl.us
discovery-gcl@psc.state.fl.us

Walter Trierweiler

Charles Rehwinkel

Ms. Patricia A. Christensen

Mary Wessling

Octavio Ponce

Austin Watrous

Office of Public Counsel

111 West Madison Street, Room 812
Tallahassee, FL 32399-1400
Trierweiler, Walt(@leg.state. fl.us
Rehwinkel.charles@leg.state.fl.us
christensen.patty@leg. state. fl.us
wessling.mary@leg.state.fl.us

ponce.octavio@leg.state.fl.us

watrous.austin@leg.state.fl.us

Dianne M. Triplett

Duke Energy Florida, LLC

299 First Avenue North

St. Petersburg, FL 33701
dianne.triplett(@duke-energy.com

Kenneth A. Hoffman

Florida Power & Light Company
134 W. Jefferson Street
Tallahassee, FL 32301

ken. hoffman@fpl.com

Christopher T. Wright

Florida Power & Light Company
700 Universe Boulevard

Juno Beach, FL 33408-0420

christopher.wright@fplLcom

Jon C. Moyle, Jr.

Karen A. Putnal

Moyle Law Firm, P.A.
118 N. Gadsden Street
Tallahassee, FL 32301
jmoyle@moylelaw.com

kputnal@moylelaw.com

mqualls@moylelaw.com

James W. Brew
Laura Wynn Baker

Stone Mattheis Xenopoulos & Brew, P.C.

1025 Thomas Jefferson Street, NW
Ste. 800 West

Washington, D.C. 20007-5201
jbrew@smxblaw.com

Iwb@smxblaw.com

ORDER NO. PSC-2024-0426-PHO-EI

DOCKET NO. 20240010-EI Attachment B
PAGE 59 Page 8 of 8
Matthew R. Bernier Mike Cassel
Robert Pickels Florida Public Utilities Company
Stephanie A. Cuello 208 Wildlight Avenue
Duke Energy Florida, LLC Yulee, FL 32097
106 E. College Avenue, Suite 800 meassel@fpuc.com
Tallahassee, FL 32301-7740
matthew. bernier@duke-energy.com Peter J. Mattheis
Robert.pickels@duke-energy.com Michael K. Lavanga
stephanie.cuello@duke-energy.com Joseph R. Briscar

FLRegulatoryLegal@duke-energy.com Stone Law Firm

1025 Thomas Jefferson St., NW

Beth Keating Suite 800 West

Gunster Law Firm Washington, DC 20007-5201
215 South Monroe St., Suite 601 jm@smxblaw.com
Tallahassee, FL 32301 mkl@smxblaw.com
bkeating@gunster.com jrb@smxblaw.com

Michelle Napier

Phuong Nguyen

Florida Public Utiltities Company

1635 Meathe Drive

West Palm Beach, FL 33411

mnapier(@fpuc.com
pnguyen@chpk.com

dade, th. esas

ATTORNEY

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment C
PAGE 60 Page | of 7

FILED 9/9/2024
DOCUMENT NO. 08934-2024

GUNSTER FPSC - COMMISSION CLERK

FLORIDA'S LAW FIRM FOR BUSINESS Writer’s Direct Dial Number: (850) 521-1706
Writer's E-Mail Address:
bkeatine@eunster.com

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment C
PAGE 61 Page 2 of 7

BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION

In re: Storm Protection Plan Cost Recovery | DOCKET NO. 20240010-EI

Clause

DATED: September 9, 2024

STIPULATIONS AND PROPOSED RESOLUTIONS

Florida Public Utilities Company (“FPUC,” or “Company”) and the Office of Public
Counsel (“OPC”) (hereinafter collectively referred to as “Parties”) hereby agree to submit for
approval by the Florida Public Service Commission (“Commission”) the following Stipulations
and Proposed Resolutions for the issues to be addressed with respect to FPUC in Docket No.
20240010-EI on the following conditions:

Ie The Parties stipulate to having all pre-filed testimony and exhibits filed in this

docket entered into the record, specifically the following:

Witness - Direct Subject Exhibits

Phuong T. Nguyen, filed April | 2023 Final True Up PTN-1': SPPCRC Schedules
1, 2024 (adopted by Michelle 1A-9A

Napier)

P. Mark Cutshaw, filed April | SPP work performed in May — | Co-sponsor of Schedule 8A in
December 2023 Final True Up

1, 2024 Period Exhibit PTN-1
Michelle Napier, revised | 2024 Estimated and 2025 Revised MDN-2?; SPPCRC
direct, filed August 2, 2024 Projection; Calculation of Schedules E and P

Factors

P. Mark Cutshaw, May 1, | SPP work to be performed in

2024 projection period

/Donna sO: Brown, | Staff Audit of FPUC Exhibit DDB-2
Commission Staff, filed July

1, 2023

! Direct Exhibit PTN-1 of Phuong Nguyen adopted by Witness Napier, substituting for Ms. Nguyen consistent with
Notice filed June 20, 2024.
? Revised MDN-2 filed August 2, 2024

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment C
PAGE 62 Page 3 of 7

Docket No. 20240010-EI
Page 2

De The Parties agree to waive cross-examination of all FPUC and Staff witnesses in Docket
No. 20240010-EI and, upon Commission approval, have no objection to such witnesses being
excused from appearing at the hearing.

By The Parties stipulation to having all of FPUC’s responses to Staff's discovery requests
entered into the record.

4, To the extent there are proposed Type 2 stipulations? for Issue Nos. 1C, 2C, 3C, 4C, 5C,
6C, 7C, 8C, 9C, and 10, FPUC supports the proposed stipulations and OPC will take no position
on each issue, thereby facilitating a Type 2 stipulation on each of these issues as follows:

OPC takes no position on FPUC’s proposed Storm Protection Plan Cost Recovery
Clause (SPPCRC) Factors, nor does it have the burden of proof related to them. Ags
such, OPC further represents that it takes no position on, and thus will not contest or
oppose the Commission taking action approving a proposed stipulation between the
Company and another party of Staff as to a final resolution of Issue Nos. 1C, 2C, 3C,
AC, 5C, 6C, 7C, 8C, 9C, and 10. No person is authorized to state that the OPC is a
participant in, or a party to, a stipulation on these issues, either in this docket, in an
order of the Commission or in a representation to a Court.

Be FPUC’s positions subject to the Type 2 stipulations described above, if approved, are as
follows:

ISSUE 1C: The final, end of period true up amount to be included in the calculation of the
2023 cost recovery factors for FPUC is an under-recovery of $388,983, which
reflects the difference between the actual, end of period revenue requirement of
$246,889 based on actual expenditures, and the projected 2023 over-recovery of
$142,094,

ISSUE 2C: FPUC projects an end of period 2024 under-recovery of $1,120,304, based on a
revised 2024 revenue requirement of $3,481,578, which is net of $975,504

already recovered through base rates.

3 A Type 2 stipulation occurs on an issue when the utility and the Commission staff, or the utility and at least one
party adversarial to the utility, agree on the resolution of an issue and the remaining parties (including staff if they
do not join in the agreement do not object to the Commission relying on the agreed language to resolve that issue in
a final order.

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI

PAGE 63

Docket No. 20240010-EI

Page 3

ISSUE 3C€:

ISSUE 4C:

ISSUE 5C:

ISSUE 6C:

ISSUE 7€:

Attachment C
Page 4 of 7

FPUC projects total expenditures of $20.44 million, with a revenue requirement

of $4,153,106, which is net of $975,504 already recovered through base rates.

The total amount upon which FPUC’s proposed factors are calculated is

$5,667,195, which is adjusted for taxes.

The appropriate depreciation rates are those approved in, Order No, PSC-2023-
0384-PAA-EI, issued December 21, 2023, in Docket No. 20230079-EI.

There is no jurisdictional separation applicable to FPUC,

As reflected on Revised Exhibit MDN-2, page 13 of 36, SPPCRC Form 5P, the

appropriate Storm Protection Plan Cost Recovery Clause factors for 2025 for each

rate class for FPUC are as follows:

Rate Schedule SPPCRC

FACTORS

PER KWH
Residential $0.00997
General Service $0.01100
General Service Demand $0.00594
| General Service Large Demand $0.00508
Industrial/Standby $0.01402
| Lighting Service $0,06177

ISSUE 8C:

The effective date for FPUC's cost recovery factors should be the first billing

cycle for January 1, 2025, which could include some consumption from the prior

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 64

Attachment C
Page 5 of 7

Docket No, 20240010-EI
Page 4

month, Thereafter, customers should be billed the approved factors for a full 12

months, unless the factors are otherwise modified by the Commission.

ISSUE 9C: The Company will submit, and the Commission should authorize its staff to approve
administratively, revised tariffs reflecting the SPPCRC factors determined to be
appropriate in this proceeding. The Commission should direct staff to verify that the

revised tariffs are consistent with the Commission’s decision.

ISSUE 10: — This is a continuing docket and should remain open.

In Witness Whereof, FPUC and OPC evidence their acceptance and agreement with the aforesaid

stipulations and proposed resolutions by their signature,

Florida Public Utilities Company

BY:

Date, 2 7 EAH

Beth Keating

Gunster, Yoakley & Stewart, P.A.

215 South Monroe St., Suite 601

Tallahassee, FL 32301

(850) 521-1706

Attorney for Florida Public Utilities Company

Office of Public Gouiisél

sv. L/abt / al Date: WY. Zo2 f

Walt Trierweiler

Public Counsel

Office of Public Counsel

111 West Madison Street, Room $12
Tallahassee, FL 32399-1400

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 65

Attachment C
Page 6 of 7

Docket No. 202400 10-EI
Page 5

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing discovery responses has
been furnished by Electronic Mail to the following parties of record this 9" day of September,

2024:

Daniel Dose

Shaw Stiller

Florida Public Service Commission
2540 Shumard Oak Boulevard
Tallahassee, FL 32399-0850
Ddose@psc. state. fl.us
sstiller@psc.state.fl.us
discovery-pcl@psc.state. fl.us

J. Jeffry Wahlen/Malcolm Means/Virginia
Ponder

Ausley Law Firm

Post Office Box 391

Tallahassee, FL, 32302
jwahlen@ausley.com
mmeans@ausley.com
yponder@ausley.com

Walt Trierweiler/P, Christensen / Charles
Rehwinkel/Mary Wessling/Octavio
Ponce/Austin Watrous

Office of Public Counsel

c/o The Florida Legislature

111 W. Madison Street, Room 812
Tallahassee, FL 32399-1400
Trierweiler. Walt@leg.state.fl.us
Wessling.Mary@leg state fi.us
Rehwinkel. Charles@leg.state.flus
Christensen, patty @leg.state.fl.us
Ponce. octavio(@leg. state. fl.us
Watrous.austin(@leg. state fl.us

James W, Brew/Laura Baker

Stone Matheis Xenopoulos & Brew, PC
Eighth Floor, West Tower

1025 Thomas Jefferson Street, NW
Washington, DC 20007
jbrew@smxblaw.com
lwb@smxblaw.com
sbn@smxblaw.com

Christopher T, Wright

David Lee

Florida Power & Light Company
700 Universe Boulevard

Juno Beach, FL 33408-0420
Christopher. Wright@fpl.com
David.Lee@fpl.com

Kenneth Hoffman

Florida Power & Light Company
215 South Monroe Street, Suite 810
Tallahassee, FL 32301
Ken.Hoffman@fpt.com

Ms. Paula i, Brown
‘Tampa Electric Company
Regulatory Affairs

P.O. Box Il

Tampa, FL 33601-0111
Regdept(@tecocnergy.com

Florida Industrial Users Power Group
Jon C. Moyle, Jr.

Moyle Law Firm

118 North Gadsden Street
Tallahassee, FL 32301
imoyle@moylelaw.com

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 66

Docket No. 20240010-EI
Page 6

Attachment C

Page 7 of 7

Michelle Napier

Florida Public Utilities Company
1635 Meathe Drive

West Palm Beach FL 33411
mnapier(@fpuc.com

Matthew Bernier

Robert Pickels

Stephanie Cuello

Duke Energy

106 East College Avenue, Suite 800
Tallahassee, FL, 32301
Matthew.Bernier@duke-energy.com
Robert,Pickels(@@duke-energy.com
Stephanie.Cuello@duke-cnergy.com

P. Mattheis/M. Lavanga/J. Briscar
1025 Thomas Jefferson St., NW
Eighth Floor, West Tower
Washington DC 20007
jrb@smxblaw.com
mki@smxblaw,com
_pjm@smxblaw.com

Dianne M. Triplett

Duke Energy

299 First Avenue North

St. Petersburg, FL 33701

Dianne. Triplett@duke-cenergy.com

By:

iting 3

Beth Kea

Gunster, Yoakley & Stéwart, P.A,

215 South Monroe St., Suite 601
Tallahassee, FL 32301
(850) 521-1706

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 67

(DUKE
Se’ ENERGY.

FLORIDA

O ncetneebnan £ WIA

Attachment D
Page | of 7

FILED 9/6/2024
DOCUMENT NO. 08914-2024
FPSC - COMMISSION CLERK

Matthew R. Bernier
Associate General Counsel

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI
PAGE 68

Attachment D
Page 2 of 7

CERTIFICATE OF SERVICE
Docket No, 20240010-E1

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via
electronic mail to the following this 6" day of September, 2024.

Is’ Matthew _R. Bernier

Attorney

Shaw Stiller / Daniel Dose / Jennifer
Crawford

Office of General Counsel

FL Public Service Commission
2540 Shumard Oak Blvd.
Tallahassee, FL 32399-0850
sstillendpsc.state.fl.us
ddose/@psc. state. fl.us
jcrawfor@psc.state.fl.us

Kenneth Hoffman

Florida Power & Light

134 West Jefferson St.
Tallahassee, FL 32301-1713
ken. hoffman@fpl.com

Christopher T, Wright / Davide Lee
Florida Power & Light

700 Universe Boulevard (JB/LAW)
Juno Beach FL 33408-0420
christopher wright@fplcom

david. lee@ifpl.com

Peter J. Mattheis / Michael K. Lavanga /
Joseph R. Briscar

Stone Mattheis Xenopoulos & Brew, PC
NUCOR

1025 Thomas Jefferson Street, NW
Eighth Floor, West Tower

Washington, DC 20007
pim@smxblaw.com
mkIl@smxblaw.com

jro@smxblaw.com

Beth Keating

Gunster, Yoakley, & Stewart, P.A.
FPUC

215 South Monroe Street, Suite 601
Tallahassee, FL 32301

bkeating@gunster.com

Michelle Napier / Phuong Nguyen
Florida Public Utilities Company
1635 Meathe Drive

West Palm Beach, Florida 33411
mnapicr@fpuc.com
pnguyen@chpk.com

Jon C. Moyle Jr.

Moyle Law Firm
FIPUG

118 North Gadsden St.
Tallahassee, FL 32301
imovle@movlelaw.com
mqualls‘@movylelaw.com

James W. Brew / Laura Wynn Baker /
Sarah B. Newman

Stone Matiheis Xenopoulos & Brew, P.C.

PCS Phosphate —White Springs
1025 Thomas Jefferson Street, NW
Eighth Floor, West Tower
Washington, DC 20007
jbrew@smxblaw.com
lwb@smxblaw.com
sbn@smxblaw.com

W. Trierweiler / P. Christensen /
C. Rehwinkel / M. Wessling /
O. Ponce/ A. Watrous

Office of Public Counsel

111 W. Madison St., Room 812
Tallahassee, FL 32399-1400
(nierweiler.wall@leg state.f1.us
christensen. patty @leg state. fl.us
rehwinkel charles@leg.state.fl.us
wessling mary ‘@leg. state fl.us
ponce.octavio@leg. state fl.us
watrous.austin@leg. state. fl.us

Paula K. Brown

Tampa Electric Company
Regulatory Affairs

P.O. Box 11

Tampa, FL 33601-0111

regdepti@tecocnergy.com

J. Wahlen / M. Means / V. Ponder
Ausley McMullen

Tampa Electric Company

P.O. Box 391

Tallahassee, FL 32302
jwahlen@ausley.com
mmeans@ausley.com
vponder‘@ausley.com

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment D
PAGE 69 Page 3 of 7

BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION

In re: Storm Protection Plan Cost Recovery | Docket No. 20240010-EI
Clause
Dated: September 6, 2024

STIPULATIONS AND PROPOSED RESOLUTION

Duke Energy Florida, LLC (“DEF” or the “Company”) and the Office of Public Counsel
(“OPC”) (hereinafter collectively referred to as “Parties”) herby agree to submit for approval by
the Florida Public Service Commission (“Commission”) the following Stipulations and Proposed
Resolution of the issues to be addressed in Docket No. 20240010-EI on the following terms and
conditions:

1. The Parties stipulate to having all pre-filed testimony and exhibits filed in this docket
entered into the record, specifically the following:

a. The Direct Testimony of DEF witnesses Christopher A. Menendez filed on
April 1, 2024, along with Exhibits CAM-1;

b. The Direct Testimony of DEF witnesses Robert E. McCabe filed on April 1,
2024:

c. The Direct Testimony of DEF witnesses Robert E. Brong filed on April 1, 2024;

d. The Direct Testimony of DEF witnesses Christopher A. Menendez filed on
May 1, 2024, along with Exhibits CAM-2 and CAM-3;

e. The updated Direct Testimony of DEF witnesses Christopher A.
Menendez filed on July 31, 2024, along with updated Exhibit CAM-3 to reflect
the updated information based on the effects of DEF’s 2024 Settlement

Agreement in Docket No. 20240025-El,

]

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment D
PAGE 70 Page 4 of 7

f. The Direct Testimony of DEF witnesses Robert E. McCabe filed on May 1,
2024:

g. The Direct Testimony of DEF witnesses Robert E. Brong filed on May 1, 2024;
and

h. The Direct Testimony of Staff witness Donna D. Brown filed on July 1, 2024,
along with Exhibit DDB-1.

2. The Parties agree to waive cross-examination of all DEF and Staff witnesses in Docket No.
20240010-EI and, upon Commission approval, have no objection to such witnesses being
excused from appearing at the hearing.

3. The Parties stipulate to having all of DEF’s responses to Staffs discovery requests entered
into the record.

4. To the extent there are proposed Type 2 stipulations! for Issue Nos. 1D, 2D, 3D, 4D, 5D,
6D, 7D, 8D, 9D, and 10, DEF supports the proposed stipulations and OPC will take no
position on each issue and thereby will facilitate a Type 2 stipulation on each of these issues
as follows:

OPC takes no position on DEF’s proposed Storm Protection Plan Cost
Recovery Clause (SPPCRC) Factors, nor does it have the burden of proof
related to them. As such, OPC further represents that it takes no position on,
and thus will not contest or oppose the Commission taking action approving a
proposed stipulation between the Company and another party or Staff as to a
final resolution of, Issue Nos. 1D, 2D, 3D, 4D, 5D, 6D, 7D, 8D, 9D, and 10.
No person is authorized to state that the OPC is a participant in, or party to, a

stipulation on these issues, either in this docket, in an order of the Commission
or in a representation to a Court.

' A Type 2 stipulation occurs on an issue when the utility and the staff, or the utility and at least one party adversarial
to the utility, agree on the resolution of the issue and the remaining parties (including staff if they do not join in the
agreement) do not object to the Commission relying on the agreed language to resolve that issue in a final order.

2

ORDER NO. PSC-2024-0426-PHO-EI

DOCKET NO. 20240010-EI Attachment D
PAGE 71 Page 5 of 7
5: DEF’s positions subject to the Type 2 stipulations described above, if approved, are as
follows:

Issue 1D: DEF’s final total SPPCRC investments for 2023 is $684,389,980.2_ DEF’s
SPPCRC final jurisdictional revenue requirement true-up for the period January
2023 through December 2023, including interest, is an over-recovery of
$5,364,450.

Issue 2D: DEF’s total SPPCRC investments for 2024 is $771,943,413.7 DEF’s SPPCRC
actual/estimated jurisdictional revenue requirement true-up for the period
January 2024 through December 2024, including interest, is an over-recovery
of $10,259,107.

Issue 3D: DEF’s total SPPCRC projected investments for 2025 is $845,476,201.4 DEF’s
projected SPPCRC jurisdictional revenue requirement for the period January
2025 through December 2025 is $285,580,616, based on the updated 2025
testimony of Christopher A. Menendez and updated Exhibit CAM-3.

Issue 4D: The projected total SPPCRC jurisdictional revenue requirement for the period
January 2025 through December 2025, including true-up amounts, is
$269,957,058, based on the updated 2025 testimony of Christopher A.
Menendez and updated Exhibit CAM-3.

Issue 5D: For the period January 2025 through December 2025, DEF should use the
depreciation rates that were approved in Final Order No. PSC-2021-0202A-AS-
EI, consistent with DEF’s settlement agreement filed on July 15, 2024, in
Docket No, 20240025-EI and reflected in the updated 2025 testimony of
Christopher A. Menendez and updated Exhibit CAM-3.

Issue 6D: As shown in updated Exhibit CAM-3, DEF’s retail jurisdictional separation
factors for the period January 2025 through December 2025 are:

DEMAND
Transmission 0.703692
Distribution 1.000000

Issue 7D: As shown on Form 6P of updated Exhibit CAM-3, the appropriate DEF 2025
SPPCRC factors for each rate class are as follows:

? The jurisdictional separation factors are applicd to the revenue requirements and not the costs incurred. Therefore,
the total jurisdictional cost incurred for the applicable calendar year is not available.
3 See Footnote 2.

4+ See Footnote 2.

ORDER NO. PSC-2024-0426-PHO-EI

DOCKET NO. 20240010-EI Attachment D
PAGE 72 Page 6 of 7
Customer Class SPPCRC Factor
Residential 0.801 cents/kWh
General Service Non-Demand 0.694 cents/kWh
@ Primary Voltage 0.687 cents/kWh
@ Transmission Voltage 0.680 cents/kWh
General Service 100% Load Factor 0.355 cents/kWh
General Service Demand 1,92 S/W
@ Primary Voltage 1.90 S/kW
@ Transmission Voltage 0.33 S/kW
Curtailable 1.15 $/kW
@ Primary Voltage 1.14 S/W
@ Transmission Voltage 1.13 $/kW
Interruptible 1.54 S/kKW
@ Primary Voltage 1.26 S/kW
@ Transmission Voltage 0.25 S/KW
Standby Monthly 0.170 S/kW
@ Primary Voltage 0.168 $/kW
@ Transmission Voltage 0.167 $/kW
Standby Daily 0.081 S/kW
@ Primary Voltage 0.080 S/kW
@ Transmission Voltage 0.079 S$/kW
Lighting 0.586 cents/kWh

Issue 8D: The factors shall be effective beginning with the specified Storm Protection
Plan Cost Recovery Clause cycle and thereafter for the period January 2025
through December 2025. Billing cycles may start before January 1, 2025, and
the last cycle may be read after December 31, 2025, so that each customer Is
billed for twelve months, regardless of when the adjustment factor became
effective. These charges shall continue in effect until modified by subsequent
order of this Commission.

Issue 9D: Yes. The Commission should approve DEF’s revised tariffs reflecting the
Storm Protection Plan Cost Recovery Clause factors determined to be
appropriate in this proceeding. The Commission should direct Staff to verify
that the revised tariffs are consistent with the Commission’s decision. The
Commission should grant Staff Administrative authority to approve revised
tariffs reflecting the new Storm Protection Plan Cost Recovery Clause factors
determined to be appropriate in this proceeding,

Issue 10: No, this is an on-going docket and should remain cpen until a subsequent year’s
docket is established.

6, The Parties stipulate and agree that the issue resolutions set out above address all issues in

Docket No. 20240010-E]I and accordingly, are ripe to be approved by the Commission.
4

ORDER NO. PSC-2024-0426-PHO-EI
DOCKET NO. 20240010-EI Attachment D
PAGE 73 Page 7 of 7

a

In Witness Whereof, DEF and OPC evidence their acceptance and agreement with the aforesaid

stipulations and proposed resolutions by their signature.

Duke Energy we

fo = ke Arte. AA hac \ n\
MATTHEW R. BERNIER
Associate General Counsel
106 East College Avenue, Suite 800
Tallahassee, Florida 32301

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Office of Public Counsel

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Walt Trierweiler

Public Counsel

Office of Public Counsel

111 West Madison Street, Room 812
Tallahassee, FL 32399-1400

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