Florida Public Service Commission native order document 06307-2024

Order No. PSC-2024-0190-FOF-EIFlapubserv

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FILED 6/13/2024
DOCUMENT NO. 06307-2024
FPSC - COMMISSION CLERK
BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
In re: Petition for recovery of costs associated
with named tropical systems during the 2018-
2022 hurricane seasons and replenishment of
storm reserve, by Tam a Electric Com any.
DOCKET NO. 20230019-EI
ORDER NO. PSC-2024-0190-FOF-EI
ISSUED: June 13, 2024
The following Commissioners participated in the disposition of this matter:
APPEARANCES:
MIKE LA ROSA, Chairman
ARTGRAHAM
GARYF.CLARK
ANDREW GILES FAY
GABRIELLA P ASSIDOMO
J. 	JEFFRY 	WAHLEN, 	MALCOLM 	MEANS, 	and 	VIRGINIA 	PONDER,
ESQUIRES, Ausley McMullen, Post Office Box 391, Tallahassee, Florida 32302
On behalf of Tampa Electric Company (TECO).
WALT TRIERWEILER, Public Counsel, CHARLES REHWINKEL, and MARY
WESSLING, ESQUIRES, Office of Public Counsel, c/o The Florida Legislature,
111 W. Madison Street, Room 812, Tallahassee, Florida 32399
On behalf of the Office of Public Counsel (OPC).
STEPHANIE U. EATON, ESQUIRE, Spilman, Thomas & Battle, PLLC , 110
Oakwood Drive, Suite 500, Winston-Salem, North Carolina 27103
On behalf of Walmart, Inc. (Walmart).
DERRICK PRICE WILLIAMSON and STEVEN W. LEE, ESQUIRES, Spilman,
Thomas & Battle, PLLC, 1100 Bent Creek Blvd., Suite 101, Mechanicsburg,
Pennsylvania 17050
On behalf of Walmart, Inc. (Walmart).
MAJOR R. THOMPSON and RYAN P. SANDY, ESQUIRES, Florida Public
Service Commission, 2540 Shumard Oak Boulevard, Tallahassee, Florida 32399
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
Advisor to the Florida Public Service Commission.
ORDER NO. PSC-2024-0190-FOF-EI
DOCKET NO. 20230019-EI
PAGE 2
KEITH C. HETRICK, ESQUIRE, General Counsel, Florida Public Service
Commission, 2540 Shumard Oak Boulevard, Tallahassee, Florida 32399
Florida Public Service Commission General Counsel
ORDER APPROVING TAMPA ELECTRIC COMPANY’S PETITION FOR
RECOVERY OF COSTS ASSOCIATED WITH NAMED TROPICAL SYSTEMS
AND DENYING WALMART’S MOTION FOR RECONSIDERATION
BY THE COMMISSION:
Background
On 	January 	23, 	2023, 	pursuant 	to 	Rules 	28-106.201 	and 	25-6.0143, 	Florida
Administrative Code (F.A.C.), Tampa Electric Company (TECO or Utility) filed its Petition for
Recovery of Costs Associated with Named Tropical Systems During the 2018-2022 Hurricane
Seasons and Replenishment of Storm Reserve with actual incremental storm costs for the 2018
through 2021 storm seasons and estimated incremental storm costs for the 2022 storm season.
We approved TECO’s interim storm restoration charge on March 27, 2023, subject to final true-
up.1
On August 16, 2023, TECO filed a Supplemental Petition to update the total storm
restoration costs to include updated accrued costs and to propose a modified recovery period. On
September 29, 2023, TECO filed a Petition for Approval of Actual Storm Restoration Costs
Associated with Named Tropical Systems During the 2018-2022 Hurricane Seasons and
Associated True-Up Mechanism on September 29, 2023, updating the estimated costs for the
2022 to actual costs and providing the required documentation of actual recoverable storm costs
and to propose a final true-up mechanism for the Interim Storm Restoration Charge.
A Prehearing Conference was held in this docket on April 24, 2024, and Prehearing
Order No. PSC-2024-0137-PHO-EI was issued on April 26, 2024. Among the rulings reflected
in the Prehearing Order was the striking of Walmart’s proposed Issue A: “Should any cost
recovery approved in this docket be recovered from demand-metered customers through the
demand charge?” Having heard the parties’ arguments, the Prehearing Officer struck Issue A,
finding that TECO’s 2021 Settlement Agreement 2 provides that the storm damage recovery that
is at issue in this proceeding shall be made with the rate design and cost allocation methods
approved in the agreement. As the issue was resolved by the 2021 Settlement Agreement,
Walmart’s issue was found to be inappropriate in this proceeding. In keeping with this ruling, the
Prehearing Officer excluded the prefiled testimony of Walmart’s witness Lisa V. Perry, together
with supporting exhibits LVP-1 and LVP-2, which supported Walmart’s position on Contested
1 Order No. PSC-2023-0116-PCO-EI, issued March 27, 2023, in this docket.
2 Order No. PSC-2021-0423-S-EI, issued November 10, 2021, in Docket Nos. 20210034-EI, In re: Petition for rate
increase by Tampa Electric Company and 20200264-EI, In re: Petition for approval of 2020 depreciation and
dismantlement study and capital recovery schedules, by Tampa Electric Company (p. 35-36).
ORDER NO. PSC-2024-0190-FOF-EI
DOCKET NO. 20230019-EI
PAGE 3
Issue A. With the exclusion of Walmart’s witness testimony and exhibits, TECO’s prefiled
testimony of its witness Jordan M. Williams, which rebutted Walmart’s witness, was also
excluded.
On April 30, 2024, Walmart filed a Motion for Reconsideration of the striking of its Issue
A and the testimony and exhibits of witness Perry. As set forth below, the Motion for
Reconsideration was taken up as a preliminary matter at the May 1, 2024 hearing. Having heard
oral argument by the parties, Walmart’s Motion for Reconsideration was denied by the full
Commission, as set forth below.
Also at the final hearing on May 1, 2024, the prefiled testimonies of Chip Whitworth and
Richard Latta on behalf of TECO and Carl Vinson and Ron Mavrides on behalf of Commission
staff were admitted into the record along with exhibits 1 through 3 and 6 through 14.
The parties proposed Type 1 or Type 2 stipulations on all issues. A Type 1 stipulation
occurs on an issue where the utility and intervenors agree on the resolution of the issue. A Type
2 stipulation3 occurs on an issue when the utility and 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. As set forth below, at the May 1, 2024 hearing, we
voted to approve all of the stipulations set forth below, thereby resolving all outstanding issues
for each party in this docket.
We have jurisdiction over this matter pursuant to Sections 366.04, 366.05, 366.06, and
366.076, Florida Statutes (F.S.).
Decision
1. 	Denial of Walmart’s Motion for Reconsideration
Law
The appropriate standard of review for reconsideration of a Commission order is whether
the motion identifies a point of fact or law that the Commission overlooked or failed to consider
in rendering the order under review. See Stewart Bonded Warehouse, Inc. v. Bevis, 294 So. 2d
315 (Fla. 1974); Diamond Cab Co. v. King, 146 So. 2d 889 (Fla. 1962); and Pingree v.
Quaintance, 394 So. 2d 162 (Fla. 1st DCA 1981). It is not appropriate to reargue matters that
have already been considered. Sherwood v. State, 111 So. 2d 96 (Fla. 3d DCA 1959) (citing State
3 The Office of Public Counsel’s (OPC’s) position on each Type 2 stipulation is as follows:
OPC takes no position on these issues, nor does it have the burden of proof related to them. As
such, the OPC represents that it will not contest or oppose the Commission taking action
approving a proposed stipulation between the utility and another party or staff as a final resolution
of the issue. 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-2024-0190-FOF-EI
DOCKET NO. 20230019-EI
PAGE 4
ex. rel. Jaytex Realty Co. v. Green, 105 So. 2d 817 (Fla. 1st DCA 1958)). Furthermore, a motion
for reconsideration should not be granted “based upon an arbitrary feeling that a mistake may
have been made, but should be based upon specific factual matters set forth in the record and
susceptible to review.” Stewart Bonded Warehouse, Inc., 294 So. 2d at 317.
Walmart’s Motion for Reconsideration
In its Motion for Reconsideration, Walmart argues that the Prehearing Officer overlooked
the parties’ intent when interpreting TECO’s 2021 Settlement Agreement. Walmart contends that
as a signatory to the 2021 Settlement Agreement, it is not precluded from participating in any
proceedings and opposing the amount of TECO’s claimed storm costs. 4 The 2021 Settlement
Agreement states:
The Parties to this 2021 Agreement are not precluded from participating in any
such proceedings and opposing the amount of Tampa Electric’s claimed costs (for
example, and without limitation, on grounds that such claimed costs were not
reasonable or were not prudently incurred) or whether the proposed recovery is
consistent with this Paragraph [], but not the mechanism agreed to herein.
Specifically, Walmart interprets this language to allow Walmart to challenge the amount of
TECO’s costs charged to demand-metered customers via energy charges. Walmart alleges that
the Prehearing Officer made a mistake of fact or law in failing to ascertain the parties’ intent in
interpreting ambiguous language from a contract. Moreover, Walmart highlights the fact that
none of the signatories to the 2021 Settlement Agreement challenged Walmart’s ability to raise
its proposed issue, which demonstrates that the proposed issue does not violate the terms of the
agreement. Consequently, Walmart requests that we reconsider the striking of Contested Issue
A. 5
Analysis and Conclusion
We have held that a mistake of fact or law standard applies to reconsideration by the
Commission 	of 	a 	Prehearing 	Officer’s 	order.6 	The 	Prehearing 	Officer 	is 	the 	procedural
4 Order No. PSC-2021-0423-S-EI, at p. 36.
5 Walmart also requested the Commission reconsider the Type 2 Stipulation to Issue 13. However, at the hearing, the
parties acknowledged reconsideration was not necessary. TECO provided amended language to Issue 13 which
resulted in a Type 2 Stipulation between the parties as detailed in section 2 of this Order. Consequently, the only
remaining issue raised by Walmart’s Motion for Reconsideration is Contested Issue A.
6 See Order No. PSC-2016-0231-FOF-EI, issued June 10, 2016, in Docket No. 20160021-EI, In re: Petition for rate
increase by Florida Power & Light Company; Order No. PSC-2002-1442-FOF-EI, issued October 21, 2002, in
Docket Nos. 20020262-EI, In re: Petition to Determine Need for an Electrical Power Plant in Martin County by
Florida Power & Light Company and 20020263-EI, In re: Petition to Determine Need for an Electrical Power Plant
in Manatee County by Florida Power & Light Company; Order No. PSC-2001-2021-FOF-TL, issued October 9,
2001, in Docket No. 19960786A-TL, In re: Consideration of BellSouth Telecommunications, Inc.’s entry into
interLATA services pursuant to Section 271 of the Federal Telecommunications Act of 1996; Order No. PSC-1997-
0098-FOF-EU, issued January 27, 1997, in Docket No. 19930885-EU, In re: Petition to Resolve territorial dispute
with Gulf Coast Electric Cooperative, Inc. by Gulf Power Company; Order No. PSC-1996-0133-FOF-EI, issued
ORDER NO. PSC-2024-0190-FOF-EI
DOCKET NO. 20230019-EI
PAGE 5
administrator of a hearing-track case. They rule on motions and procedural matters and conduct
prehearing conferences, prior to referral of such cases to the Commission for final decision.
Pursuant to Rule 28-106.211, F.A.C., the Prehearing Officer may issue any orders necessary to
effectuate discovery, to prevent delay, and to promote the just, speedy, and inexpensive
determination of all aspects of the case.
At the Prehearing, staff recommended to strike Contested Issue A as it was settled and
controlled by the 2021 Settlement Agreement. Walmart disagreed and noted that, in its
interpretation, “the gist of the settlement agreement does allow the signatories of the settlement
agreement to contest the charges.” The Prehearing Officer, having heard all argument, ruled
against Walmart and struck Contested Issue A.
In its Motion for Reconsideration, Walmart repeats the same arguments, noting that
Walmart interprets the 2021 Settlement Agreement “to allow participation . . . to address the
amount of TECO’s costs charged to demand-metered customers via energy charges.” This is
fundamentally the same argument raised by Walmart and considered by the Prehearing Officer at
the Prehearing Conference.
Walmart also alleges that staff’s recommendation to strike Contested Issue A at the
Prehearing Conference is untimely. Walmart contends that staff raised its objection to Walmart’s
issue more than a year after Walmart filed comments in the docket file addressing its position on
the topic of Issue A.7 However, the Order Establishing Procedure8 in this docket allows staff to
take no position on pending issues, up to and even after the Prehearing Conference. Further, one
of the purposes of the Prehearing Conference is for parties to contest the wording of issues, or to
argue whether issues are even appropriate or relevant to the hearing. The timing of staff’s
recommendation to strike Issue A is not a mistake of fact or law that the Prehearing Officer
overlooked.
Because Walmart failed to demonstrate a mistake of fact or law made in the striking of its
issue and associated testimony and exhibits, Walmart’s Motion for Reconsideration is denied.
2. 	Approval of Stipulations
The stipulations proposed by the parties are the result of negotiations between TECO,
OPC, and Walmart and benefit TECO’s customers by establishing an ongoing, continuous storm
restoration process improvement plan that results in current and future customers only paying for
prudent, cost-effective storm restoration costs incurred due to extreme weather events. Therefore,
we approve the following stipulations as being in the public interest and supported by the
evidence entered at the hearing.
January 29, 1996, in Docket No. 19950110-EI, In re: Standard offer contract for the purchase of firm capacity and
energy from a qualifying facility between Panda-Kathleen, L.P., and Florida Power Corporation.
7 See Document No. 02058-2023.
8 Order No. PSC-2023-0309-PCO-EI, issued October 17, 2023, in Docket No. 20230019-EI.
ORDER NO. PSC-2024-0190-FOF-EI
DOCKET NO. 20230019-EI
PAGE 6
ISSUE 1: 	Should the incremental cost and capitalization approach (ICCA) found in Rule
25-6.0143, F.A.C., be used to determine the reasonable and prudent amounts to be
included in the restoration costs?
Type 1: 	Yes. The Commission should find that the company complied with the rule.
ISSUE 2: 	Have the terms of TECO’s 2019 Stipulation and Settlement, approved by Order
No. PSC-2019-0234-AS-EI, issued June 14, 2019, been complied with? 	If not,
why not?
Type 1: 	Yes. The Commission should find that the company complied with the 2019
Stipulation and Settlement.
ISSUE 3: 	What is the reasonable and prudent amount of regular payroll expense to be
included in the restoration costs?
Type 1: 	The Commission should approve $3,281,788.00 as the reasonable and prudent
amount of regular payroll expense to be included in the restoration costs.
ISSUE 4: 	What is the reasonable and prudent amount of overtime payroll expense to be
included in the restoration costs?
Type 1: 	The Commission should approve $6,832,831.08 as the reasonable and prudent
amount of overtime payroll expense to be included in the restoration costs.
ISSUE 5: 	What is the reasonable and prudent amount of contractor costs to be included in
the restoration costs?
Type 1: 	The Commission should approve $90,569,291.92 as the reasonable and prudent
amount of contractor costs to be included in the restoration costs. This amount is
slightly lower than the previously reported amount of $90,852,788.61 because a
few final invoices came in slightly lower than the accrued expense amounts.
ISSUE 6: 	What is the reasonable and prudent amount of vegetation and line clearing costs
to be included in the restoration costs?
Type 1: 	The Commission should approve $10,884,426.12 as the reasonable and prudent
amount of vegetation and line clearing costs to be included in the restoration
costs.
ISSUE 7: 	What is the reasonable and prudent amount of employee expenses to be included
in the restoration costs?
Type 1: 	Zero. Tampa Electric did not request recovery of Tampa Electric employee
expenses.
ORDER NO. PSC-2024-0190-FOF-EI
DOCKET NO. 20230019-EI
PAGE 7
ISSUE 8: 	What is the reasonable and prudent amount of materials and supplies expense to
be included in the restoration costs?
Type 1: 	Zero. Tampa Electric did not request recovery of materials and supplies expenses.
ISSUE 9: 	What is the reasonable and prudent amount of logistics costs to be included in the
restoration costs?
Type 1: 	The Commission should approve $18,893,127.42 as the reasonable and prudent
amount of logistics costs to be included in the restoration costs. There are
additional costs related to interest income, examination costs, and ARCOS (GPS
tracking technology) implementation costs totaling $3,592,865.25; $381,000; and
$397,518.04 respectively.
ISSUE 10: 	What is the reasonable and prudent total amount of costs to be included in the
restoration costs?
Type 1: 	The Commission should approve $134,832,847.83 as the reasonable and prudent
total amount of costs to be included in the restoration costs. This is $266,249.88
lower than the total presented in witness Latta’s testimony of $135,099,097.71.
This change is because of final invoice payments and adjustments to accrued
interest income based on the current month’s Commercial Paper interest rate. As
of March 31, 2024, all invoices relevant to this docket have been processed.
ISSUE 11: 	What is the reasonable and prudent amount of storm-related costs that should be
capitalized?
Type 1: 	The Commission should approve $4,799.217.43 as the reasonable an prudent
amount of storm-related costs that should be capitalized.
ISSUE 12: 	What is the appropriate accounting treatment associated with any storm costs
found to have been imprudently incurred?
Type 1: 	The accounting treatment for any storm costs found to be imprudently incurred,
and initially posted to the storm reserve, is to remove the charge from the reserve
and post the charge to the company’s applicable O&M account, or capital as
identified; however, the current total restoration cost presented in this docket does
not contain any imprudently incurred costs.
ISSUE 13: 	If applicable, how should any under-recovery or over-recovery be handled?
Type 2: 	Any under-recovery will be recovered through an adjustment to the energy
conservation cost recovery clause. Any over-recovery will be refunded through a
ORDER NO. PSC-2024-0190-FOF-EI
DOCKET NO. 20230019-EI
PAGE 8
clause billed on an energy basis, such as the fuel clause or the environmental
clause.
ISSUE B: 	What additional storm restoration process improvements should Tampa Electric
follow in future storms?
Type 2: 	In addition to the process improvements in Tampa Electric’s 2019 Storm Cost
Settlement Agreement, Tampa Electric also agrees to follow the additional
process improvements described in Attachment A to this Order.
ISSUE 14: 	Should this docket be closed?
Type 1: 	No. This docket should remain open so the company can file supplemental
testimony 	comparing 	the 	final 	recoverable 	storm 	costs 	approved 	by 	the
Commission with the actual revenues from the Interim Storm Restoration Charge
and calculating the resulting excess or shortfall, so that the true-up amount can be
recovered from or credited to the energy conservation cost recovery clause or
disposed of in some other manner as approved by the Commission.
Based on the foregoing, it is
ORDERED by the Florida Public Service Commission that the findings set forth in the
body of this order, and Attachment A hereto, are hereby approved. It is further
ORDERED that Walmart’s Motion for Reconsideration with respect to the striking of its
Issue A and the testimony and exhibits of witness Lisa V. Perry is denied, as set forth herein. It is
further
ORDERED that this docket shall remain open so Tampa Electric Company can file
supplemental testimony comparing the final recoverable storm costs we approved with the actual
revenues from the Interim Storm Restoration Charge and calculating the resulting excess or
shortfall, so that the true-up amount can be recovered from or credited to the energy conservation
cost recovery clause or disposed of in some other manner as approved by this Commission.
ORDER NO. PSC-2024-0190-FOF-EI
DOCKET NO. 20230019-EI
PAGE9
By ORDER of the Florida Public Service Commission this 13th day of June, 2024.
MRT
Commission Clerk
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-2024-0190-FOF-EI
DOCKET NO. 20230019-EI
PAGE 10
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.
Any party adversely affected by the Commission's final action in this matter denying
Walmart’s request for reconsideration may request 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 by filing a notice of appeal with the Office of Commission Clerk,
2540 Shumard Oak Boulevard, Tallahassee, Florida 32399-0850, and filing a copy of the notice
of appeal and the filing fee with the appropriate court. 	This filing must be completed within
thirty (30) days after the issuance of this order, pursuant to Rule 9.110, Florida Rules of
Appellate Procedure. 	The notice of appeal must be in the form specified in Rule 9.900(a),
Florida Rules of Appellate Procedure.
Any party adversely affected by the Commission's final action in this matter may request:
1) reconsideration of the decision by filing a motion for reconsideration with the Office of
Commission Clerk, 2540 Shumard Oak Boulevard, Tallahassee, Florida 32399-0850, within
fifteen (15) days of the issuance of this order in the form prescribed by Rule 25-22.060, 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 and/or
wastewater utility by filing a notice of appeal with the Office of Commission Clerk, and filing a
copy of the notice of appeal and the filing fee with the appropriate court. 	This filing must be
completed within thirty (30) days after the issuance of this order, pursuant to Rule 9.110, Florida
Rules of Appellate Procedure. 	The notice of appeal must be in the form specified in Rule
9.900(a), Florida Rules of Appellate Procedure.
ORDER NO. PSC-2024-0190-FOF-EI 	Attachment A
DOCKET NO. 20230019-EI
PAGE 11
Attachment A
Tampa Electric Company’s Prehearing Statement
Ongoing, Continuous Storm Restoration Process Improvements
Tampa Electric Company’s (“Tampa Electric” or the “company”) 2019 Storm Cost
Settlement Agreement includes several “Future Process Improvements” covering a broad range
of storm cost recovery issues, including: (1) contracting and vendor engagement; (2) travel and
work policies; (3) cost documentation; (4) auditing and regulatory recovery processes; and (5) a
methodology for determining incremental costs. See Order No. PSC-2019-0234-AS-EI, issued
June 14, 2019 in Docket No. 20170271-EI.
Since that time, Tampa Electric has continued to document lessons learned from storm
restoration efforts and has as a part of the ongoing, continuous improvement process
implemented several additional process improvements.
Tampa Electric commits that it will continue to apply the 2019 storm process
improvements, as well as the additional new process improvements listed below, whenever such
implementation does not interfere with safe, timely, and cost-effective restoration of service
following a storm, and that they will remain in effect until modified by an order of the Florida
Public Service Commission. The company will meet with OPC to evaluate the company’s storm
restoration processes in the first quarter of 2025 and every two years thereafter.
1. 	Lodging Procurement and Tracking. Tampa Electric retained a third-party booking
agency that provides a disaster lodging service for emergency lodging needs. This
agency provides and books accommodations according to requesters’ specific needs,
utilizing their extensive and detailed database of lodging vendors and pre-negotiated
contracts. They can identify vendors’ specific capabilities such as emergency power,
parking, food, and laundry services. Additionally, their booking software platform can
track detailed information about acquired lodging and utilization rates to help identify
unused accommodation to inform decision making. After the emergency, they provide
comprehensive invoice tracking and payment support to quickly resolve payment to
vendors.
2. 	Storm Surge Damage Mitigation. Tampa Electric developed a new process to
anticipate and mitigate storm surge damage by working with Tampa Electric’s weather
partners, including the National Weather Service (“NWS”) and a Florida-based
meteorologist. Tampa Electric is the first utility in Florida to be recognized as a “Storm
Ready” partner, allowing access to NWS weather data and forecasts. Additionally,
Tampa Electric contracted with a Florida based meteorologist to enhance our
understanding and interpretation of weather data as it relates to our local geographic
conditions. Being able to anticipate the damage more accurately to underground
ORDER NO. PSC-2024-0190-FOF-EI 	Attachment A
DOCKET NO. 20230019-EI
PAGE 12
electrical equipment will allow Tampa Electric to better estimate the correct number of
external resources required to help restore this equipment.
3. 	Base Camp Staging Model. Tampa Electric maintains contracts with several vendors
that supply turn-key emergency accommodations including lodging, meals, sanitation
and transportation management. These base camps can be rapidly deployed (usually
within 24 hours) to staging sites post-storm and mitigate the company’s storm recovery
personnel needs.
4. 	Eliminating Delays. Tampa Electric began pre-staging crews in nearby locations,
allowing the company to utilize responding crews in the working hours immediately
following the passage of storm conditions, even before local staging sites are completely
set up.
5. 	Distribution Control Center (DCC) Process Changes. In storm response scenarios,
Tampa Electric transitions control from the central DCC to the company’s various
service areas. One lesson learned was to reduce the transition time from DCC control to
service area control, which results in less down time for field personnel and faster
restoration of service.
6. 	“Cut and Clear” Improvements. The company improved the locked-out circuit
isolation process (“cut-and-clear”) by creating a mobile app to transmit faster updates
from the field and for easier tracking of work. Re-energizing distribution circuits that
have been locked out as quickly as possible after a storm provides one of the greatest
values in restoring service to customers. Getting clear and faster updates through a
mobile app ensures that this process is carried out without delays.
7. 	Improved Outage Detection. The company improved the detection of outages by
having streetlights turned on as soon as restoration begins.
8. 	Improved DCC and Service Area Communications. Tampa Electric implemented
multiple process changes to eliminate confusion and miscommunication between the
DCC and Service Area Restoration teams. The DCC and the service area restoration
teams are the two most critical areas during storm restoration. Clear and up-to-date
communications are vital for a successful restoration effort.
9. 	Circuit Reconfiguration Logs. Performing overnight work reduces the overall time to
restore service to all customers, but poor communication of work performed overnight
to the daytime crews can result in delays. Consequently, the company implemented the
use of “abnormal switching logs” in the Advanced Distribution Management System
(“ADMS”) to communicate circuit reconfigurations performed overnight by the DCC to
the service area restoration teams. This helps ensure clear communication of the
overnight work to the day crews and eliminates potential delays.
10. New Safety Measures. Tampa Electric added steps to reduce the safety risk to field
personnel while performing circuit isolation work, such as opening the terminal pole
switch and adding “men at work” pole wrap. These steps were added as extra safety
ORDER NO. PSC-2024-0190-FOF-EI 	Attachment A
DOCKET NO. 20230019-EI
PAGE 13
measures in addition to steps that were already in place. Given the large amount of field
personnel working during storm restoration, adding several layers of protection shows
Tampa Electric’s commitment to the company’s highest objective: “Safety of life shall
outweigh all other considerations.”
11. Additional Distribution System Operators. The company added more Distribution
System Operators and assigned two per affected service area. This eliminated the need
to train personnel who were not familiar with ADMS/CAD on how to update ADMS
when field restoration is complete. The result is a quicker update of customer outage
counts and more accurate estimated times of restoration (“ETR”) reflected in the
customer-facing outage map. The company believes communications with our
customers are just as important as internal communications, and these changes ensure
that we communicate outages and ETRs to our customers during the times when they
need such information the most.
12. Retaining Some Foreign Crews in Partial Incident Command Structure (“ICS”).
Tampa Electric determined that retaining a small contingent of foreign crews following
the transition to partial ICS can help quickly restore the remaining small pockets of
outages (secondary, service, etc.). It takes longer to find and fix these smaller outages,
and having more crews reduces the time it takes to conduct this effort.
13. Additional Documentation for Foreign Line Crews. Tampa Electric added specific
terms and conditions to the rate schedule template that is provided to and completed by
the foreign companies. In addition, a “Storm Restoration Documentation and Other
Requirements” document and an initial email that outlines requirements are provided to
each foreign company when they are secured. These measures ensure invoiced costs are
fair and meet the requirements of the Storm Cost Settlement Agreement.
14. Foreign Line Crew Rate Schedules. Tampa Electric now collects storm rate schedules
prior to storm season that identify agreed-upon rates with the foreign contractor. The
company has compiled 59 such schedules to date. These schedules are ranked by cost
from lowest cost to highest, and if Tampa Electric directly secures foreign contractors,
the list is contacted in that order. If a foreign contractor is assigned to Tampa Electric by
the SEE, the list is used to determine which companies may be released from restoration
first.
15. Foreign Company “Tracker” Files. During and after restoration, the Resource
Management team updates a “Tracker” file that documents contacts, headcounts, dates,
and other pertinent information by foreign company so that Tampa Electric can ensure
that all required information needed for proper billing has been collected.
Foreign Line Crew Composition Review. Before foreign companies are approved to
deploy, Tampa Electric now examines rosters provided by the foreign companies
immediately after they are secured to ensure that the distribution crew make-ups are no
more than four team members per crew (to ensure fair invoicing), and that the crews
ORDER NO. PSC-2024-0190-FOF-EI 	Attachment A
DOCKET NO. 20230019-EI
PAGE 14
have at least two line workers and a hot apprentice (minimum standard to safely perform
work).
In addition to these process improvements that are already in place, Tampa Electric also
identified two additional improvements that the company commits to implement in future
storms:
1. 	Standardized Rate Schedules. Tampa Electric currently implements a standardized rate
schedule for contracts with line restoration crews. The company also commits to
negotiate for and implement standardized rate schedules for contracts with vegetation
management crews in future storms.
2. 	Formalized Exception Reports. To better implement Section II.A of the Future Process
Improvements in the 2019 Storm Cost Settlement Agreement, Tampa Electric will
formally document all exceptions to standardized requirements that have been
communicated to foreign companies.

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