Florida Public Service Commission native order document 09139-2024

OCR transcription for search; preserved printed pages are authoritative

FILED 9/20/2024
DOCUMENT NO. 09139-2024
FPSC - COMMISSION CLERK

BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION

In re: Commission review of numeric DOCKET NO. 20240017-EG
conservation goals (Orlando Utilities ORDER NO, PSC-2024-0433-FOF-EG
Commission). ISSUED: September 20, 2024

The following Commissioners participated in the disposition of this matter:

MIKE LA ROSA, Chairman
ART GRAHAM
GARY F. CLARK
ANDREW GILES FAY
GABRIELLA PASSIDOMO

FINAL ORDER APPROVING NUMERIC CONSERVATION GOALS
FOR ORLANDO UTILITIES COMMISSION

APPEARANCES:

ROBERT SCHEFFEL WRIGHT and JOHN T. LAVIA, III, ESQUIRES,
Gardner, Bist, Bowden, Dee, LaVia, Wright, Perry & Harper, P.A., 1300
Thomaswood Drive, Tallahassee, Florida 32308

On behalf of Orlando Utilities Commission (OUC).

SEAN T. GARNER, ERIK SAYLER and KELLY WRIGHT, ESQUIRES,
Florida Department of Agriculture & Consumer Service, Office of General
Counsel, The Mayo Building, 407 S. Calhoun Street, Suite 520, Tallahassee,
Florida 32399-0800

On behalf of Florida Department of Agriculture & Consumer Services (FDACS).

BRADLEY MARSHALL and JORDAN LUEBKEMANN, ESQUIRES,
Earthjustice, 111 S. Martin Luther King Jr. Blvd., Tallahassee, Florida 32301
On behalf of Florida Rising, Inc. (FL Rising).

WILLIAM C. GARNER, ESQUIRE, Law Office of William C. Garner, PLLC,
3425 Bannerman Road, Unit 105, No. 414, Tallahassee, Florida 32312
On behalf of Southern Alliance for Clean Energy (SACE).

STEPHANIE U. EATON, ESQUIRE, Spilman, Thomas & Battle, PLLC, 110
Oakwood Drive, Suite 500, Winston-Salem, North Carolina 27103

ORDER NO. PSC-2024-0433-FOF-EG
DOCKET NO. 20240017-EG
PAGE 2
STEVEN W. LEE, ESQUIRE, Qualified Representative, Spilman, Thomas &
Battle, PLLC, 1100 Bent Creek Blvd., Suite 101, Mechanicsburg, Pennsylvania
17050
On behalf of Walmart, Inc. (Walmart).
JACOB IMIG, JON RUBOTTOM, and ADRIA HARPER 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.
BY THE COMMISSION:
Background
Enacted in 1980, Sections 366.80 through 366.83, and 403.519, Florida Statutes (F.S.),
are known collectively as the Florida Energy Efficiency and Conservation Act (FEECA).
FEECA requires us to adopt appropriate goals to increase the efficiency of energy consumption
and, pursuant to Section 366.82(6), F.S., we must review the goals of each utility subject to
FEECA at least every five years.
The six electric utilities subject to FEECA, collectively known as the FEECA Utilities,
are Florida Power & Light Company (FPL), Duke Energy Florida, LLC (DEF), Tampa Electric
Company (TECO), Florida Public Utilities Company (FPUC), JEA, and Orlando Utilities
Commission (OUC). Pursuant to Rule 25-17.0021, Florida Administrative Code (F.A.C.),
numeric goals were last established for the FEECA Utilities by Order No. PSC-19-0509-FOF-
EU, issued November 26, 2019. Therefore, new goals must be established by January 2025.
By Order No. PSC-2024-0022-PCO-EG, issued February 28, 2024, the dockets for each
of the FEECA Utilities were consolidated for purposes of hearing and controlling dates and a
tentative list of issues were established.
We acknowledged the intervention of the Office of Public Counsel (OPC) on February
28, 2024.1 We acknowledged the intervention of the Florida Department of Agriculture and
1 Order No. PSC-2024-0051-PCO-EG.

ORDER NO. PSC-2024-0433-FOF-EG
DOCKET NO. 20240017-EG
PAGE 3
Consumer Services (FDACS) on April 24, 2024.2 Florida Rising, Inc. (Florida Rising) were
granted leave to intervene on April 25, 2024.3 The Southern Alliance for Clean Energy (SACE)4
and Walmart Inc. (Walmart)5 were granted leave to intervene on April 30, 2024. OPC withdrew
from the proceeding on May 22, 2024.6
Pursuant to Notice and in accordance with Rule 28-106.209, F.A.C., a hearing was held
on August 8, 2024, in Tallahassee, Florida, before the above commissioners.
Decision
Legal Background
FEECA directs us to promote four key priorities: (1) reducing and controlling the growth
rates of weather-sensitive peak demand and electricity usage, (2) increasing the efficiency and
cost-effectiveness 	of 	the 	production 	and 	consumption 	of 	electricity 	and 	natural 	gas, 	(3)
encouraging demand-side renewable energy systems, and (4) conserving expensive resources,
particularly petroleum fuel.7 The Legislature emphasized that it is critical to utilize “efficient and
cost-effective” conservation systems.8 Section 366.82, F.S., bifurcates our responsibility under
FEECA into two separately docketed proceedings. First, in the goalsetting dockets, we must
establish appropriate goals for increasing the efficiency of energy consumption and increasing
the development of demand-side renewable energy systems. Following the adoption of goals, in
the plan approval dockets, each FEECA Utility must file plans and programs to meet the goals
within its service area. The present docket was opened to address the first, goalsetting portion of
our FEECA proceedings for OUC.
FEECA requires that we establish goals designed to increase the conservation of
expensive resources, such as petroleum fuels; reduce and control the growth rates of electric
consumption; reduce the growth rates of weather-sensitive peak demand; and encourage
development of demand-side renewable energy resources.9 Section 366.82(3), F.S., prescribes
the following criteria for our evaluation of the conservation goals:
In developing the goals, the commission shall evaluate the full technical potential
of 	all 	available 	demand-side 	and 	supply-side 	conservation 	and 	efficiency
measures, including demand-side renewable energy systems. In establishing the
goals, the commission shall take into consideration:
(a) 	The costs and benefits to customers participating in the measure.
2 Order No. PSC-2024-0128-PCO-EG.
3 Order No. PSC-2024-0135-PCO-EG.
4 Order No. PSC-2024-0139-PCO-EG.
5 Order No. PSC-2024-0194-PCO-EG.
6 DN 00854-2024.
7 See Sections 366.81-366.82, F.S.
8 Section 366.81, F.S.
9 Section 366.82(2), F.S.

ORDER NO. PSC-2024-0433-FOF-EG
DOCKET NO. 20240017-EG
PAGE 4
(b) 	The costs and benefits to the general body of ratepayers as a whole,
including utility incentives and participant contributions.
(c) 	The need for incentives to promote both customer-owned and utility-owned
energy efficiency and demand-side renewable energy systems.
(d) 	The costs imposed by state and federal regulations on the emission of
greenhouse gases.
The Commission implements FEECA for electric utilities through Rule 25-17.0021,
F.A.C. Pursuant to that rule, for each FEECA Utility, we establish annual kilowatt (KW) and
kilowatt-hour (KWh) goals for Residential and Commercial/Industrial customer classes.10 The
goals are based on (1) an assessment of the technical potential of available conservation and
efficiency measures, and (2) an estimate of the total cost-effective KW and KWh savings
reasonably achievable through demand-side management (DSM) programs in each utility’s
service area over a ten-year period.11 The goals we establish are annual targets for conservation,
with KW goals relating to seasonal—summer and winter—demand savings, and annual KWh
goals relating to annual energy savings.
Following the last goalsetting proceedings in 2019, after receiving feedback from the
utilities, intervenors, and interested persons, we amended Rule 25-17.0021, F.A.C., to streamline
our FEECA process by requiring utilities to file potential conservation programs along with their
proposed goals. This allows us to analyze the utilities’ proposed goals based upon energy (KWh)
and demand (KW) savings from customer participation in potential programs they plan to
implement, thus giving us better information as to the appropriateness of the goals. Thus,
although utility conservation plans and the underlying programs and measures to implement
those plans are not approved at this time, each utility must include sufficient information related
to the cost-effectiveness of its potential DSM programs to support the appropriateness of its
proposed goals.12
Analysis
Pursuant to Section 366.82, F.A.C., we must evaluate whether the goals requested by
OUC are appropriate. Pursuant to the Prehearing Order, Order No. PSC-2024-0293-PHO-EG,
issued August 2, 2024, a final list of issues was established for the consolidated hearing. Issues
1-7 address whether each utility, in developing its proposed goals, adequately addressed the
considerations prescribed by statute and Commission rule. Issue 8 addresses, for the purpose of
establishing goals for rate-regulated utilities, whether we should consider changing credit levels
for demand response programs in the FEECA goalsetting proceedings or in their base rate
proceedings. Because OUC is a municipal utility, Issue 8 was moot for OUC. Issues 9-11 were
specific only to FPL’s docket and thus not at issue for OUC. Issues 12 and 13 are the ultimate
issues addressing, in light of the preceding issues, what conservation goals we should establish
for OUC as required by Section 366.82, F.S.
10 Rule 25-17.0021(1), F.A.C.
11 Id.
12 Section 366.82(7), F.S., addresses how we must evaluate and approve the utilities’ plans to implement the
Commission-established goals during the subsequent plan approval proceeding.

ORDER NO. PSC-2024-0433-FOF-EG
DOCKET NO. 20240017-EG
PAGE 5
Following a robust discovery process, we were presented with a series of proposed Type
II stipulations,13 set forth below in Attachment A, that fully resolved all issues in this docket.
OUC, Florida Rising, and SACE. Walmart and FDACS took no position on all issues.
Commission staff recommended approval of the proposed stipulations. We approved the
proposed stipulations by a bench vote at the August 8, 2024, hearing.
We find that each of the stipulations are supported by evidence in the record. We also
find that the testimony and exhibits in the record adequately address the statutory considerations
required by Section 366.82(3), F.S., and demonstrate that the goals stipulated for Issues 12 and
13, as set forth in Attachment A, will increase the conservation of expensive resources, such as
petroleum fuels; reduce and control the growth rates of electric consumption; reduce the growth
rates of weather-sensitive peak demand; and encourage development of demand-side renewable
energy resources. In particular, we found the testimony and exhibits of OUC witnesses Jim
Herndon, Kevin Noonan, and Bradley Kushner, as well as the discovery responses provided by
OUC, support our finding that the stipulated goals are reasonable and consistent with the
requirements of Section 366.82, F.S., and Rule 25-17.0021, F.A.C. For these reasons, we find the
stipulated goals to be appropriate.
Conclusion
The 	stipulations 	listed in 	Attachment 	A 	address 	all 	the 	requirements 	of 	FEECA
enumerated in Section 366.82, F.S., and satisfy the requirements of Rule 25-17.0021, F.A.C.
Further, the conservation goals stipulated in Issues 12 and 13 are appropriate to advance the
priorities of FEECA. Therefore, the goals stipulated in Issues 12 and 13 are adopted for OUC for
the period 2025-2034.
Based on the foregoing, it is
ORDERED that Orlando Utilities Commission shall abide by the stipulations, findings,
and rulings herein. 	It is further
ORDERED that Orlando Utilities Commission’s residential and commercial/industrial
summer and winter megawatt (MW) and annual gigawatt-hour (GWh) goals are adopted as set
forth in Attachment A, Paragraph 6, Issue 12. 	It is further
ORDERED 	that 	Orlando 	Utilities 	Commission 	should 	continue 	to 	implement 	the
provisions of Rule 25-6.065, F.A.C., Interconnection and Net Metering of Customer-Owned
Renewable Generation, as an appropriate means to encourage the development of demand-side
renewable energy. It is further
13 A Type II stipulation is one in which the utility and 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-2024-0433-FOF-EG
DOCKET NO. 202400 17- EG
PAGE6
ORDERED that t hi s docket sha ll be closed after th e t im e fo r filin g an appea l has run .
JD!
By ORDER of th e Fl orida Pub li c Service Co mmi ssion thi s 20th day of Se pt ember, 2024.
rv ic e Co mmi ss ion
2540 Shumard Oak Bouleva rd
Ta ll ahassee, Flor ida 32399
(850) 413-6770
www.flor id ap sc.co m
Copies 	furn ished: A copy of thi s doc um ent is
provided to the par ti es of reco rd at the ti me of
issuance a nd , if app li cable, interested persons.

ORDER NO. PSC-2024-0433-FOF-EG
DOCKET NO. 20240017-EG
PAGE 7
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 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-2024-0433-FOF-EG Attachment A
DOCKET NO. 20240017-EG
PAGE 8

BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION

Inre: Commission Review of Numeric DOCKET NO. 20240017-EG
Conservation Goals for

Orlando Utilities Commission Filed: August 6, 2024

eee ee

STIPULATIONS
Orlando Utilities Commission (“OUC”), Florida Rising, Inc. (“Florida Rising”), and the
Southern Alliance for Clean Energy, Inc. (“SACE”) (hereinafter referred to individually as “Party”
or collectively as “Parties”), hereby agree to submit for approval by the Florida Public Service
Commission (“Commission”) the following stipulations to fully resolve the Parties’ respective
issues in Docket No. 20240017-EG (the “OUC Goals Docket”) on the following terms and
conditions:
L. 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 OUC witness Jim Herndon, along with Exhibits JH-1
through JH-16;
b. The Direct Testimony of OUC witness Kevin M. Noonan, along with Exhibits
KMN-1 through KMN-5;
c. The Direct Testimony of OUC witness Bradley E. Kushner, along with Exhibits
BEK-} through BEK-3;
d. The Rebuttal Testimony of OUC witness Kevin M, Noonan, along with Exhibit
KMN-6; and
e. The Direct Testimony of Florida Rising witness MacKenzie Marcelin, along with

Exhibits MM-1 through MM-14, MM-19, MM-24 through MM-25, and MM-35.

ORDER NO. PSC-2024-0433-FOF-EG Attachment A
DOCKET NO. 20240017-EG

PAGE 9

The Parties agree to waive cross-examination of all witnesses in Docket No. 20240017-EG
and, upon Commission approval, have no objection to all of the above-named witnesses
being excused from appearing at the hearing.

The Parties stipulate to having the following exhibits identified on Staff's Comprehensive
Exhibit List entered into the record for Docket No. 20240017-EG: 74-87, 88-101, 106,
111-112, 122, 148, 214-222, 223-224, 714-747, 767, 772, and 783.

The Parties stipulate and agree that OUC’s proposed DSM Goals for the ten-year period of
2025-2034 shall be modified as follows:

a. The annual megawatt-hour (MWH) goal for OUC’s proposed Residential
Efficiency Delivered program for 2025 shall be 110 MWH, and the annual
goal shal] be increased by 5 MWH per year each year thereafter through
2034, such that the goal in 2034 shall be 155 MWH, and OUC’s Residential
sector and total summer peak demand and winter peak demand reduction
goals shall be increased correspondingly, with OUC’s new MWH and peak
demand MW goals being as shown in the stipulated position on Issue 12
below; provided, however, the Parties agree that OUC’s DSM Goals
associated participation levels shall be reassessed and reset in the next DSM
Goals docket to be filed in 2029.

b. Additionally, to enhance OUC’s energy conservation outreach efforts to
OUC’s low-income customers, OUC will commit to distribute 1,000
Energy Efficiency Kits per year to low-income-customers through
appropriate marketing channels, neighborhood association meetings,
partnering low-income service agencies, and related means. These Kits will
be over and above the Energy Efficiency Kits that OUC already distributes
to customers with its Residential Energy Surveys (energy audits). Each Kit
distributed pursuant to this low-income customer initiative will include four
(4) 9-watt (9W) LED light bulbs, 17 feet of weather-stripping, and two LED
night-lights. (For clarity, GUC will continue to distribute its remaining
inventory of Kits that contain 2 9W LED bulbs to customers receiving a
Home Energy Survey, until that inventory is exhausted, after which all
Energy Efficiency Kits, both those distributed through this low-income
initiative and those distributed through OUC’s Home Energy Surveys, will
contain 4 9W LED bulbs.) This Energy Efficiency Kits measure is a
behavioral measure that will not be reflected in changes to OUC’s numeric
MWH and MW goals, but the numeric participation goal is part of the
stipulation that the Parties ask the PSC to approve as part of its order

2

ORDER NO. PSC-2024-0433-FOF-EG Attachment A
DOCKET NO. 20240017-EG
PAGE 10

approving OUC’s Energy Conservation Goals in the Goals Docket. Any
Party to these Stipulations may propose changes to this behavioral measure
and participation goal in OUC’s next (2029) Energy Conservation Goals
Docket.

c. The programs included in OUC’s DSM portfolio will not be capped or
discontinued if the sector-level goals are achieved.

5, The Parties stipulate and agree that the modifications and addition set forth in Paragraph 4
above are a reasonable compromise of competing positions set forth in the testimony and
exhibits submitted by the OUC and Florida Rising witnesses.

6. Subject to the modifications of OUC’s proposed DSM goals as set forth in Paragraph 4
above, the Parties stipulate to the following positions on each of the Issues set forth in the
Prehearing Order:

Issue 1: The Parties stipulate and agree that the record supports a Commission
finding that OUC’s proposed DSM Goals, as modified herein, are based on
an adequate assessment of the full technical potential of all available
demand-side and supply-side conservation and efficiency measures,
including demand-side renewable energy systems.

Issue 2: The Parties stipulate and agree that the record supports a Commission
finding that OUC’s proposed DSM Goals, as modified herein, are based on
savings reasonably achievable through demand-side management programs
over a ten-year period.

Issue 3: The Parties stipulate and agree that the record supports a Commission
finding that OUC’s proposed DSM Goals, as modified herein, adequately
reflect the costs and benefits to customers participating.

Issue 4: The Parties stipulate and agree that the record supports a Commission
finding that OUC’s proposed DSM Goals, as modified herein, adequately
reflect the costs and benefits to the general body of rate payers as a whole,
including utility incentives and participant contributions.

Issue 5: The Parties stipulate and agree that the record supports a Commission
finding that OUC’s proposed DSM Goals, as modified herein, adequately
reflect the need for incentives to promote both customer-owned and utility-
owned energy efficiency and demand side renewable energy systems.

Issue 6: The Parties stipulate and agree that the record supports a Commission
finding that OUC’s proposed DSM Goals, as modified herein, adequately

3

ORDER NO. PSC-2024-0433-FOF-EG
DOCKET NO. 20240017-EG

PAGE 11

Issue 7:

Issue 8a:

Issue 8b:

Issue 9:

Issue 10:

Issue 11:

Issue 12

Attachment A

reflect the costs imposed by state and federal regulations on the emissions of

greenhouse gases,

The Parties stipulate and agree that the record supports a Commission
finding that OUC’s proposed DSM Goals, as modified herein, appropriately

reflect consideration of free riders.

Not an issue in OUC’s Docket No. 20240017-EG.
Not an issue in OUC’s Docket No. 20240017-EG.
Not an issue in OUC’s Docket No. 20240017-EG.
Not an issue in OUC’s Docket No. 20240017-EG.

Not an issue in OUC’s Docket No. 20240017-EG.

: The Parties stipulate and agree that to reflect the modifications agreed to in
Paragraph 4 above, OUC’s proposed numeric DSM Goals for annual energy
(MWH) savings and summer and winter peak MW reductions shall be as
shown in the following table for the period 2025 through 2034.

Orlando Utilities Commission - Proposed Numeric Demand and Energy Goals (2025 - 2034)!
| Residential Commercial / Industrial Total
| Summer Winter Summer Winter Summer | Winter
Peak Peak Annual Peak Peak Annual Peak Peak Annual

| Demand | Demand | Energy Demand Demand | Energy Demand | Demand — Energy

| Reduction | Reduction | Reduction | Reduction Reduction | Reduction | Reduction | Reduction Reduction
Year | (MW) (MW) | (MWH) (MW) (MW) (MWH) (MW) | (MW) (MWH)
2025 | 0.111 0.181 1,072 0.485 0.380 3,207 0.597 | 0.561 4,279
2026 | 0.113 0.192 1,129 0.534 0.411 3,508 0.646 0.604 4,638
2027 0.114 0.203 1,186 0.577 0.438 3,769 0.691 0.641 4,955
2028 0.116 0.214 1,243 0.620 0.463 4,019 0.736 0.677 5,262 |
2029 0.118 0.225 1,301 0.661 0.485 4,247 0.779 0.711 5,548
2030 0.121 0.236 1,357 0.697 0.505 4,446 | (0.817 0.741 5,803
2031 0.124 0.247 1,419 0.726 | 0.520 4,605 0.850 0.767 6,024
2032 0.128 0.260 1,489 0.746 | 0.529 4,715 0.874 0.789 6,204
2033 0.133 0.275 1,569 0.755 | 0.532 4,770 0.888 | 0.807 6,339
2034 | 0.139 0.291 1,659 0.754 | 0.529 | «4,767 | 0.893 | 0.820 6425 |

' Totals may not add due to rounding.

Issue 13: The Parties stipulate and agree that the record supports a Commission
finding that no additional goals should be established for demand-side

renewable energy systems.

Issue 14: The Parties stipulate and agree that approval of the stipulations set forth
herein will fully resolve the issues and positions of all Parties to this docket

4

ORDER NO. PSC-2024-0433-FOF-EG Attachment A
DOCKET NO. 20240017-EG
PAGE 12

and, therefore, this docket should be closed upon the issuance of an Order
approving these stipulations.

Ti The Parties stipulate and agree that OUC’s proposed DSM Goals, as modified herein,
deliver meaningful energy-efficiency savings options to all customers including owners,
renters, and low-income customers, and should be approved.

8. The Parties stipulate and agree that OUC’s proposed DSM Goals, as modified herein,
constitute a reasonable approach to meet the requirements of Section 366.82, Florida
Statutes, and Rules 25-17.0021 and 25-17.008, Florida Administrative Code, and will
establish DSM Goals at a reasonable and appropriate level for the period 2025 through
2034 and should be approved.

9, The Parties stipulate and agree that the stipulations and positions set forth herein are limited
and apply only to OUC’s proposed DSM Goals in Docket No. 20240017-EG, and in no
way impact or limit any of the positions that Parties may take in any other current or future
proceedings before the Commission, including, but not limited to, any other DSM Goals
dockets currently pending before the Commission. Further, no Party agrees, concedes, or
waives any position with respect to any of the issues identified in the Prehearing Order.

10. The Parties stipulate and agree that these stipulations fully resolve their respective issues

in this proceeding and request that they be approved by the Commission.

Remainder of page intentionally left blank.

ORDER NO. PSC-2024-0433-FOF-EG
DOCKET NO. 20240017-EG

PAGE 13

Attachment A

In Witness Whereof, OUC, Florida Rising, and SACE evidence their acceptance and

agreement with all provisions of these stipulations by their signature.

Orlando Unlities Commission

By: dis ' ;

Robert Scheffel Wright

Gardner, Bist Bowden,
1300 Thomaswood Drive

Tallahassee, Florida 32308

Florida Rising, Inc.

in Maine

Bradley Marshall/Jordan Luebkemann
Earthjustice

111 8. Martin Luther King Jr. Blvd.
Tallahassee FL 32301

Southern Alliance for Clean Energy, Inc.

By:

William C. Garner

Law Office of William C. Garner, PLLC
3425 Bannerman Rd. Unit 105, No. 414
Tallahassee FL 32312

icé, LaVia, Wright, Perry & Harper, P.A.

ORDER NO. PSC-2024-0433-FOF-EG
DOCKET NO. 20240017-EG

PAGE 14

Attachment A

In Witness Whereof, OUC, Florida Rising, and SACE evidence their acceptance and

agreement with all provisions of these stipulations by their signature.

Orlando Utilities Commission

oe
Robert Scheffel Wright
Gardner, Bist Bowden, Dee, LaVia, Wright, Perry & Harper, P.A.
1300 Thomaswood Drive
Tallahassee, Florida 32308
Florida Rising, Inc.
By:

Bradley Marshall/Jordan Luebkemann
Earthjustice

111 S. Martin Luther King Jr. Blvd.
Tallahassee FL 32301

Southern Alliance for Clean Energy, Inc.

By:

tt ge

William C. Garner

Law Office of William C. Garner, PLLC
3425 Bannerman Rd. Unit 105, No. 414
Tallahassee FL 32312