Florida Public Service Commission native order document 07087-2026

FILED 9/30/2026
DOCUMENT NO. 07087-2026
FPSC 	- COMMISSION CLERK
BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
In re: Petition for determination of need for
Andytown-Oasis transmission lines project in
Broward and Miami-Dade Counties, by Florida
Power & Light Company._
DOCKET NO. 20260020-EI
ORDER NO. PSC-2026-0344-FOF-EI
ISSUED: September 30, 2026
The following Commissioners participated in the disposition of this matter:
GARY F. CLARK
BOBBY PAYNE
ANA ORTEGA
ORDER DENYING ENVIRONMENTAL DEFENSE FUND, INC.’S
MOTION FOR RECONSIDERATION AND REQUEST FOR ORAL ARGUMENT
BY THE COMMISSION:
Background
On February 	9, 2026, pursuant 	to 	Section 403.537, 	Florida 	Statutes 	(F.S.), and Rule 25-
22.075, 	Florida Administrative Code 	(F.A.C.), 	Florida Power & Light Company (FPL) 	filed a
Notice of Intent to 	File 	Petition for Transmission Lines Need Determination. FPL subsequently
filed 	its 	Petition 	to Determine Need 	for 	Electrical 	Transmission Lines on March 	11, 	2026, 	in
accordance with Section 403.537, 	F.S., Chapter 120, 	F.S., and Rules 25-22.076 and 28-106.201,
F.A.C.
FPL petitioned for an affirmative determination of need for the construction of four new
high-voltage 	transmission 	lines: 	(a) 	one 	500-kilovolt 	(kV) 	line 	starting 	at 	FPL’s 	existing
Andytown 	substation 	in Broward County and 	ending 	at 	FPL’s 	planned 	Oasis 	substation 	in
Miami-Dade County; 	(b) one 500-kV 	line starting 	at FPL’s existing Quarry substation in Miami-
Dade County and ending at FPL’s planned Oasis substation in Miami-Dade County; 	(c) one 230-
kV line 	starting 	at FPL’s planned Oasis 	substation 	in Miami-Dade County and ending 	at FPL’s
existing Quarry 	substation 	in Miami-Dade County; and 	(d) one 230-kV 	line 	starting 	at FPL’s
planned Oasis substation 	in Miami-Dade County and ending 	at FPL’s existing Levee substation
in Miami-Dade County (collectively, the Andytown-Oasis Transmission Lines Project or AOP).
A formal 	administrative hearing was 	held on April 	23, 	2026. 	Post-hearing 	briefs were
filed 	by 	the 	parties 	on 	April 	29, 	2026. 1 On May 	11, 	2026, 	this 	Florida 	Public 	Service
Commission (Commission) 	held 	a 	Special Commission 	Conference where Commission 	staff
1The parties to this proceeding are FPL, the Office of Public Counsel, and the Environmental Defense Fund, Inc.

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provided an oral recommendation on each issue. After reviewing all the evidence, and with the
benefit of post-hearing briefs as well as Commission staff’s recommendation, we rendered our
official vote and decision for purposes of Section 403.537, F.S., on May 11, 2026, approving
each of the four transmission lines of the AOP. Our Final Order was issued on June 1, 2026.2
On June 8, 2026, pursuant to Rule 25-22.075(1), F.A.C., the Environmental Defense
Fund, Inc. (EDF) filed a Motion for Reconsideration of Order No. PSC-2026-0179-FOF-EI
(Motion for Reconsideration). On that same date, EDF filed a Request for Oral Argument on its
Motion for Reconsideration (Request for Oral Argument). On June 12, 2026, FPL filed a
Response in Opposition to the Motion for Reconsideration (Response in Opposition) and a
Response in Opposition to the Request for Oral Argument. The Office of Public Counsel took no
position.
We have jurisdiction over this matter pursuant to Section 403.537, F.S., as well as Rules
25-22.075(1) and 25-22.060, F.A.C.
Decision
I. 	Request for Oral Argument
Rule 25-22.0022(1), F.A.C., allows a party to request oral argument on a motion for
reconsideration. This request must be filed concurrently with the motion and must state with
particularity why oral argument would aid us in understanding and evaluating the issues to be
decided. Granting or denying oral argument is within our sole discretion, pursuant to Rule 25-
22.0022(3), F.A.C.
EDF filed a Request for Oral Argument along with its Motion for Reconsideration. In it,
EDF asserts that oral argument would aid us in fully understanding the “nuances” of EDF’s
positions regarding our jurisdiction, as set forth in the Motion for Reconsideration. FPL counters
that the mere claim by EDF that its jurisdictional arguments are “inherently nuanced” is not a
showing with particularity why oral argument would aid this Commission, but rather is a
conclusion. FPL argues that if a party could satisfy Rule 25-22.0022(1), F.A.C., by simply
labeling its position as “nuanced,” then the rule’s particularity requirement would have no
practical meaning. Furthermore, FPL asserts that EDF’s failure to plead with particularity why
oral argument would aid us cannot be cured through the oral argument itself because the
explanation must have been in the initial request. Thus, FPL concludes, EDF has not met its legal
burden to affirmatively demonstrate why oral argument is warranted.
We find that the information in the Motion for Reconsideration is sufficient for us to
make an informed decision. EDF has not demonstrated with particularity a reason why oral
argument would assist this Commission in understanding and evaluating the issues to be decided.
Therefore, we deny the Request for Oral Argument.
2 Order No. PSC-2026-0179-FOF-EI, issued June 1, 2026, in Docket No. 20260020-EI, In re: Petition for
determination of need for Andytown-Oasis transmission lines project in Broward and Miami-Dade Counties, by
Florida Power & Light Company.

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II. 	Motion for Reconsideration
A motion for reconsideration under Rule 25-22.060(1)(a), F.A.C., may be filed by “[a]ny
party to a proceeding who is adversely affected by an order of the Commission.”3 A party need
not file a motion for reconsideration in every instance prior to taking appeal. A motion should
only be filed where the final order under review on its face demonstrates that we have
overlooked or failed to consider a point of fact or law. See Diamond Cab Co. v. King, 146 So. 2d
889 (Fla. 1962); Pingree v. Quaintance, 394 So. 2d 162 (Fla. 1st DCA 1981). A motion for
reconsideration must be based upon facts in the record and susceptible to review. Stewart
Bonded Warehouse, Inc. v. Bevis, 294 So. 2d 315 (Fla. 1974). A motion for reconsideration is
not a vehicle to reargue matters that have been considered. Sherwood v. State, 111 So. 2d 96
(Fla. 3d DCA 1959) (citing State ex. rel. Jaytex Realty Co. v. Green, 105 So. 2d 817 (Fla. 1st
DCA 1958)).
The Motion for Reconsideration raises four main issues, each of which is addressed in
turn below.
A. 	EDF’s Position Regarding the Grid Bill and FERC Order No. 1000
Positions of the Parties
EDF 	alleges 	we 	inaccurately 	found 	that 	EDF 	argued 	Federal 	Energy 	Regulatory
Commission (FERC) Order No. 1000 is within our jurisdiction to consider “because of” our
jurisdiction under the Grid Bill. EDF asks us to reconsider and either modify or delete language
on pages 4 and 5 of the Final Order. Specifically, EDF takes issue with statements in the Final
Order that EDF argued (1) that FERC Order No. 1000 is within our jurisdiction “because of” our
jurisdiction over planning and the avoidance of uneconomic duplication of transmission facilities
and (2) that Section 366.04(5), F.S., expands our jurisdiction over the issues in this case to
include FERC Order No. 1000.
EDF performed a word search of its post-hearing brief, prehearing statement, and
witnesses’ testimonies and asserts that no reference to FERC Order No. 1000 appears in any
paragraphs where EDF cited to Section 366.04(5), F.S., specifically or to the Grid Bill generally.
EDF asserts that the 11 times it cited to those concepts in the post-hearing brief were generally to
the fact that this Commission has express statutory jurisdiction over the planning, development,
and maintenance of a coordinated grid and the avoidance of further uneconomic duplication of
transmission facilities. Furthermore, EDF performed an additional word search of its post-
hearing brief, prehearing statement, and witnesses’ testimonies and asserts that while 16
instances of the phrases “uneconomic duplication,” “duplication,” or “duplicative” appear in its
post-hearing brief, no such references appear in any paragraph mentioning FERC Order No.
1000. Thus, EDF concludes that there is no evidence in the record to support the contested
3 For transmission line need determinations, Rule 25-22.075(1), F.A.C., requires that motions for reconsideration be
filed within five days of our decision. Other than this shorter filing timeframe superseding the general timeframe,
Rule 25-22.060(1)(a), F.A.C., applies.

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language in the Final Order. EDF maintains that its arguments with respect to Section 366.04(5),
F.S., are standalone arguments grounded solely in those provisions of the Florida Statutes.
FPL responds that the purpose of reconsideration is to bring our attention to a point of
fact or law that we overlooked, but EDF’s argument does not identify an overlooked point of fact
or law. Instead, according to FPL, EDF asks this Commission to revise or delete language
because EDF believes the Final Order did not describe EDF’s position with sufficient precision
or to EDF’s liking. Furthermore, FPL argues that reconsideration is not a vehicle to allow a
disappointed party to revise our written explanation so that it more closely tracks that party’s
preferred framing of its position or argument. FPL asserts that a motion for reconsideration
requires more than stylistic disagreement and that we were not required to adopt EDF’s preferred
wording, accept EDF’s litigation characterizations, or recite EDF’s arguments in the manner
EDF now prefers.
In addition, FPL argues that EDF’s attempt to prove error by conducting key word
searches is not the reconsideration standard. 	FPL submits that we were not required to parse
EDF’s arguments through keyword searches or isolate individual paragraphs from the total
litigation position EDF advanced. FPL states that EDF repeatedly invoked this Commission’s
“planning” jurisdiction and the avoidance of uneconomic duplication as a basis to demand
broader review of alternatives and regional planning issues. Thus, FPL concludes, whether EDF
placed the words “FERC Order No. 1000” in the same paragraph as Section 366.04(5), F.S., is
immaterial.
FPL goes on to state that even were one to assume arguendo that the Motion for
Reconsideration satisfied the reconsideration standard (which FPL maintains it does not), EDF’s
arguments fail on the merits. Finally, FPL argues that none of EDF’s requested revisions would
materially change the Final Order’s findings, conclusions, or ultimate determination that the
AOP is needed to resolve mandatory reliability violations and ensure continued safe, reliable,
and low-cost electric service in Miami-Dade County.
Analysis
The purpose of reconsideration is to bring to our attention a point of fact or law that we
overlooked or failed to consider. However, we find that EDF’s argument does not identify an
overlooked point of fact or law.
We did not inaccurately characterize EDF’s jurisdictional arguments in the Final Order.
With respect to FERC Order No. 1000, EDF’s post-hearing brief position expressed that
“[c]onsideration of the requirements of the FERC’s transmission planning rules is clearly within
the overall jurisdiction of the Commission.” EDF also points to its Prehearing Statement, but
even there it similarly expressed, regarding FERC Order No. 1000, that “[t]he requirements of
the [FERC’s] transmission planning rules are clearly within the overall jurisdiction of the
Commission.” 4 A dictionary definition of the word “overall” shows it to mean “including
4 Document No. 01910-2026, filed March 31, 2026, p. 9.

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everything” or “viewed as a whole.”5 In this case, EDF’s arguments regarding the scope of our
jurisdiction revolved around Sections 403.537, 366.04, and 366.01, F.S., as well as the statutory
language contained therein. Thus, we appropriately took those assertions into account when
analyzing the question of whether a FERC order was or was not within our jurisdiction.
Furthermore, during the Prehearing Conference, EDF argued that the issues related to
FERC Order Nos. 1000, 1920, 1920-A, and 1920-B were appropriate for inclusion because, “As
set 	forth 	in 	multiple 	places 	in 	what 	we 	filed 	with 	the 	Commission, 	we 	believe 	these
considerations . . . . deal with appropriate planning for transmission, and that’s clearly within the
Commission’s jurisdiction to consider.” One such referenced filing could be EDF’s Response in
Opposition to FPL’s Motion in Limine and to Strike.6 There, EDF asserted that the proposed
evidence regarding, and including, FERC Order No. 1000 were “well within the jurisdictional
purview of the Commission under the [Transmission Line Siting Act] and the Florida Grid
Bill.”7 Although the specific term “FERC Order No. 1000” does not appear in that particular
paragraph, it does appear in the two preceding paragraphs under a discussion heading using that
very term.
We were not required to isolate individual paragraphs from EDF’s total litigation
position. The Final Order appropriately addressed the substance of EDF’s positions and
arguments.8 Given EDF’s repeated invocation of our transmission planning jurisdiction and the
avoidance of uneconomic duplication, we reasonably concluded these concepts and the statutes
discussed above were a part of the jurisdictional argument EDF advanced. We find that EDF’s
preference for the Final Order to use EDF’s chosen wording does not identify an overlooked
point of fact or law.
Conclusion
Because EDF failed to identify a point of fact or law that we overlooked in rendering the
Final Order, reconsideration on this issue is denied.
B. 	EDF’s Position Regarding FPL’s Consideration of Alternatives
Positions of the Parties
EDF argues that we inaccurately characterized its position on whether technological
alternatives 	could 	meet 	FPL’s 	customers’ 	needs 	more 	cost-effectively 	than 	the 	AOP.
Specifically, EDF states that it did not argue that there are unspecified, “possible” technological
alternatives that might meet the needs of FPL’s customers. Rather, EDF states it argued that FPL
did not adequately evaluate specific, known technological options that could have either met the
5 Overall, Merriam Webster, https://www.merriam-webster.com/dictionary/overall#dictionary-entry-3 (last visited
July 21, 2026).
6 Document No. 02071-2026, filed on April 7, 2026.
7 Id. at 16 (emphasis added).
8 Indeed, EDF’s requested relief includes the option of merely deleting the identified language. This implies that
even in the absence of such language, we nonetheless adequately addressed EDF’s underlying arguments.

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need more cost-effectively or reduced the need for additional transmission facilities, thereby
benefiting FPL’s customers with a more cost-effective solution. EDF avers that the current
language of the Final Order implies EDF’s proposed alternatives were more open-ended and thus
mischaracterizes EDF’s position. Therefore, EDF asks us to reconsider and revise language on
page 5 of the Final Order to reflect EDF’s actual position: “FPL imprudently failed to consider
specifically identified, available, known, and recognized technological alternatives to the high-
voltage transmission facilities proposed by FPL.”
EDF reiterates that it proposed extending the schedule of this proceeding and offered to
provide additional evidence regarding FPL’s needs and alternatives to meet those needs, but
those requests were denied by procedural orders of this Commission.
FPL responds that EDF’s argument constitutes re-argument dressed as a semantic
objection and should be rejected. FPL argues that EDF has not identified an overlooked fact or
law, but rather identifies language it dislikes which is not enough to warrant reconsideration.
FPL asserts that we were neither required to accept EDF’s characterization that its listed
technologies were concrete, fully developed, technically viable alternatives, nor describe EDF’s
position using EDF’s preferred adjectives. FPL argues we were entitled to evaluate the record
and 	conclude 	that 	EDF’s 	position, 	if 	accepted, 	would 	convert 	every 	transmission 	need
determination 	into 	an 	open-ended 	inquiry 	into 	other 	possible 	technologies 	that 	might
theoretically reduce or defer the need for a proposed project.
FPL adds that while EDF listed technologies, EDF did not present evidence that any of
them were a technically supported, cost-effective alternative that would fully resolve the
identified reliability violations by the required timeframe. FPL argues that such a list of
technologies is not a major alternative and nothing in Rule 25-22.076(4), F.A.C., requires a
utility to perform speculative evaluations of every technology an intervenor identifies. Finally,
FPL argues that EDF’s argument improperly asks us to reweigh evidence we already considered
and rejected when we found the AOP was needed.
Analysis
We did not inaccurately characterize EDF’s position on technological alternatives in the
Final Order. EDF is concerned that the Final Order implies that the advanced technologies it
raised were unspecified, open-ended, or hypothetical. However, such concerns are misplaced.
In its post-hearing brief, EDF pointed to a number of advanced technology options that it
felt FPL had not meaningfully considered. We were aware of the existence of these advanced
technologies but found that they “either did not fully address cost, need, or would not be
available within the required timeframe.”9
For example, FPL witness Yanes testified that FPL considers advanced transmission
technologies and grid-enhancing technologies as part of the design and engineering of major
9 Order No. PSC-2026-0179-FOF-EI, p. 9.

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transmission projects. The evidence confirmed that FPL took these things into account as part of
its analysis, including conductors which FPL views as falling within those technology groupings.
The record further demonstrated that advanced power flow controllers would not resolve the load
need 	identified 	as 	part 	of 	FPL’s 	transmission 	assessment 	studies. 	Likewise, 	topology
optimizations would not create new transmission capacity. Reconductoring facilities would not
resolve the identified reliability need either because it would not sufficiently remedy the voltage
and bulk power delivery limitations to the extent required. Finally, battery storage could
potentially exacerbate the reliability problem by serving as an added load on FPL’s system in
Miami-Dade County during its charging cycle.
Nowhere did we describe the advanced technologies themselves as being non-existent,
unknown, or unspecified. Rather, we reviewed the competing evidence before us and were not
persuaded that the use/application of those possible advanced technologies would resolve the
reliability need in this particular case.10 EDF’s attempt to reframe its list of technologies as major
alternatives that would resolve the reliability need for purposes of Rule 25-22.076(4), F.A.C.,
does not change the evidentiary record or the weight that we assigned to the testimony and
evidence before us.
EDF raises a semantic issue with the Final Order’s choice of words. However, the Final
Order appropriately addressed the substance of EDF’s positions and arguments. EDF also does
not articulate how the requested wording changes would have altered our analysis, findings, or
conclusions. We find that although EDF identifies language it dislikes, EDF has failed to identify
any overlooked point of fact or law.
Conclusion
Because EDF failed to identify a point of fact or law that we overlooked in rendering the
Final Order, reconsideration on this issue is denied.
C. 	EDF’s Position Regarding Applicable State Planning Requirements
Positions of the Parties
EDF asks us to reconsider statements on page 7 of the Final Order concerning EDF’s
position on state planning requirements relative to FERC’s jurisdiction. Specifically, EDF takes
issue with language that “EDF would have us impose non-existent state planning requirements”
in transmission line need proceedings and that “EDF would have us overstep and preemptively
decide the adequacy of regional transmission planning in FERC’s place.” EDF argues that these
statements are inaccurate characterizations of EDF’s positions that have no evidentiary basis.
EDF states that, regarding state planning, EDF’s requests are grounded in our express
jurisdiction over the planning and development of the grid and mandate to avoid uneconomic
duplication of transmission facilities as well as this Commission’s broader authority to ensure
10 Document No. 03190-2026, filed May 29, 2026.

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prudent utility management and decision-making. Thus, EDF states it was advocating for the
application of existing state planning requirements as opposed to non-existent requirements.
Furthermore, EDF argues that nowhere did it ask us to issue any order that would
displace, supplant, or otherwise conflict with FERC’s jurisdiction. EDF further asks us to
reconsider the conclusion that EDF would potentially have us overstep our jurisdiction and
preemptively decide the adequacy of regional planning in light of the state authority previously
referenced. In addition, EDF indicates that we may have overlooked record evidence in FPL’s
FERC 	Open 	Access 	Transmission 	Tariff 	(OATT) 	stating: 	“The 	Florida 	Public 	Service
Commission . . . is an integral part of the planning process by providing input, guidance, and
regulatory oversight under this process.”
FPL counters that EDF’s argument is another request for us to rephrase the Final Order
and does not identify a controlling statute, rule, case, or record fact that we overlooked. FPL
argues that we were neither required to describe EDF’s position in EDF’s preferred terms or to
accept EDF’s attempt to recast its broad planning challenge as merely an ordinary request to
apply state planning law. FPL further states that we did not overlook Section 366.04(5), F.S., or
Rule 25-22.076(4), F.A.C., because the Final Order discussed them. According to FPL, Section
366.04(5), F.S., does not create a specific state-law obligation to conduct the type of regional
transmission planning analysis EDF advocated for.
FPL also asserts that its FERC-approved OATT cannot expand our statutory jurisdiction
beyond what the Florida Legislature has conferred. At most, FPL concludes, the OATT language
recognizes that this Commission has an important role in Florida utility planning within the
scope of its lawful authority.
Finally, FPL argues that despite EDF’s claim to the contrary, the testimony and evidence
EDF presented demonstrates that it was asking for us to decide the adequacy of regional
planning 	in 	FERC’s 	place. 	For 	example, 	EDF’s 	witnesses 	criticized 	Florida 	Reliability
Coordinating Council (FRCC) governance, attacked the efficacy of the FERC Order No. 1000
regional planning process, argued that FRCC’s process has produced no regional projects,
invoked future FERC Order No. 1920 planning obligations, and urged us to deny the AOP and
require further regional planning and stakeholder processes. FPL concludes that EDF’s position
would push this Commission toward precisely the kind of federal regional planning adjudication
that belongs elsewhere.
Analysis
We did not inaccurately characterize EDF’s position on state planning requirements
relative to FERC’s jurisdiction.11 We did not portray EDF’s argument as one pointing to non-
existent statutes. In fact, we discussed both Sections 403.537 and 366.04(5), F.S., within the
Final Order, but then went on to discuss the implications of EDF’s argument if accepted. Namely
11 EDF’s challenged language can be found under the jurisdictional subheading in the Final Order related to FERC
Order Nos. 1920, 1920-A, and 1920-B. Order No. PSC-2026-0179-FOF-EI, p. 6–7.

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our view that Section 366.04(5), F.S., does not create a specific state-law obligation to conduct in
this proceeding the type of regional transmission planning contemplated by the FERC orders.
EDF also argues that nowhere has EDF asked us to issue any order that would displace,
supplant, or otherwise conflict with FERC’s jurisdiction. But we were not required to accept
EDF’s attempt to recast its regional planning challenge as an ordinary request to apply state
planning law. We noted that the testimonies of EDF witnesses Cranston and Thomas sought to
call into question the efficacy of the FRCC as a regional planning entity. 12 We noted how we
could not grant the relief requested by EDF’s witnesses as it related to forcing FPL to conduct
FERC regional transmission planning analyses with full and timely opportunities for stakeholder
involvement in that process.13 Nor did we determine that we could adjudicate EDF’s allegation
that FPL violated its OATT. 14 Furthermore, we disagree with EDF’s contention that we
overlooked evidence in FERC’s OATT regarding this Commission’s role in transmission
planning. The language therein stating that we are “an integral part of the planning process by
providing input, guidance, and regulatory oversight” does not translate into expanding our
jurisdiction over FERC’s regional transmission planning process.
The substance of EDF’s arguments were addressed by us in the Final Order. EDF does
not articulate how the requested wording changes would have altered our analysis, findings, or
conclusions. We find that although EDF identifies language it dislikes, EDF has failed to identify
any overlooked point of fact or law.
Conclusion
Because EDF failed to identify a point of fact or law that we overlooked in rendering the
Final Order, reconsideration on this issue is denied.
D. 	EDF’s Position Regarding Facts Potentially Overlooked by the Commission
Positions of the Parties
EDF asks us to reconsider the Final Order to the extent that the Final Order did not
specifically address three issues raised by EDF in its post-hearing brief: (1) FPL’s allocation of
large loads, likely from data centers, to Miami-Dade County in its load projections that formed
the basis for FPL’s projected capacity need upon which its decision to pursue the AOP was
based; (2) the combined effect of this allocation of large loads with the use of a P80 load factor;
and (3) the use of transmission line capacity ratings that are inconsistent with the operating
standards for the contingency events assessed in the NERC TPL-001-5.1 reliability assessment.
Because the Final Order did not address these issues, EDF states that we may have overlooked
relevant facts in reaching our decision and thus requests that we reconsider and modify the Final
Order accordingly.
12 Order No. PSC-2026-0179-FOF-EI, p. 5.
13 Id.
14 Id.

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FPL responds that when we made our affirmative determination of need, we had
available to us EDF’s brief, FPL’s brief, party positions, an evidentiary record, a summary of
issues from Commission staff, and Commission staff’s oral recommendation on the issues. FPL
maintains that we issued a Final Order after considering the record before us, including EDF’s
post-hearing brief raising these specific factual issues. FPL argues that no rule requires a
Commission final order to catalogue and reject every evidentiary contention in a party’s post-
hearing brief. FPL argues that we were required to make findings and explain our decision based
on the statutory need criteria and that we did so.
First, FPL states that EDF’s large-load/data-center argument should fail on the merits
because FPL presented competent evidence supporting the Miami-Dade County load forecast
and reliability need. Meanwhile, EDF did not rebut that evidence with a competent alternative
load forecast and thus EDF’s argument here is a critique, not evidence. Second, FPL states that
EDF’s P80 argument should also fail because EDF neither offered a competent reliability
analysis showing that a different load forecast assumption would eliminate the mandatory
reliability violations, eliminate the need for all four lines, or materially change our decision, nor
did EDF show the AOP would be unnecessary under a different load forecast assumption. FPL
alleges that EDF’s argument attempts to have us reweigh the evidence based on conjecture,
which is not an appropriate basis for reconsideration. Third, FPL states that EDF’s transmission
line ratings argument also fails because EDF raised the argument already in its post-hearing brief
so that it is not an overlooked fact. Furthermore, FPL adds EDF cannot convert an alleged
federal tariff-compliance dispute into a basis for reconsideration of a state need determination.
FPL adds that while EDF cites to Citizens of State v. Clark, 373 So. 3d 1128 (Fla. 2023),
that case does not authorize parties to file reconsideration motions that merely repeat rejected
factual arguments.
Analysis
We find that EDF has not identified any facts overlooked by us in rendering the Final
Order. “It is not necessary for the lower tribunal to address every claim or subclaim with
particularity in its final order.” Scott v. State, 73 So. 3d 320, 320 (Fla. 1st DCA 2011). The Final
Order confirmed that we had the benefit of the parties’ post-hearing briefs when reaching our
decision.15 And the facts that EDF indicates we potentially or may have overlooked were
mentioned 	in 	EDF’s 	post-hearing 	brief. 	Thus, 	we 	were 	aware 	of 	EDF’s 	assertions 	and
characterizations of the evidentiary record on these points.
All three facts raised by EDF are associated with the transmission modeling conducted by
FPL. We explicitly mentioned the P80 load forecast in the Final Order.16 FPL’s large load
projections were an input variable of the P80 load forecast. FPL utilized the 2025 Ten-Year Site
Plan forecast (which incorporated 732 MW of large load), adjusted from the P50 used in the
Ten-Year Site Plan to the P80, and then ultimately allocated the system values on a substation
15 Id. at 2.
16 Id. at 8.

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level for the transmission modeling. The discussion of the P80 forecast within the Final Order is
inclusive of these forecasts as a whole and was a conservative approach.17 Therefore, FPL’s large
load allocation and the P80 load forecast were not overlooked by us.
Finally, the emergency transmission line ratings were not specifically discussed in the
Final Order because they had no impact on our reliability and integrity findings. The requirement
that 	EDF 	refers 	to 	regarding 	FPL’s 	OATT 	transmission 	line 	ratings 	had 	a 	July 	2025
implementation date, whereas the transmission modeling conducted for the 2025 transmission
system assessments were completed between March and May 2025. Furthermore, as noted in
FERC Order No. 881, the emergency ratings are safe for only a limited period of time, whereas
the normal ratings are continuous and not time-limited. In addition, we find that EDF’s reliance
on FERC Order No. 881 for transmission planning is misplaced because FERC found that
transmission planning and development were outside the scope of the transmission line rating
requirements being addressed in that proceeding.
We ultimately weighed the evidence before us differently than EDF wishes had been
done. However, this does not mean that we overlooked any facts. No rule requires a Commission
final order to catalogue and reject every single evidentiary contention raised in a party’s post-
hearing brief. Therefore, we find that EDF has failed to identify any overlooked point of fact.
Conclusion
Because EDF failed to identify a point of fact that we overlooked in rendering the Final
Order, reconsideration on this issue is denied.
Based on the foregoing, it is
ORDERED by the Florida Public Service Commission that the Environmental Defense
Fund, Inc.’s Request for Oral Argument is DENIED. It is further
ORDERED that the Environmental Defense Fund, Inc.’s Motion for Reconsideration of
Order No. PSC-2026-0179-FOF-EI is DENIED. It is further
ORDERED 	that 	this 	docket 	shall 	remain 	open 	while 	the 	appeal 	filed 	by 	the
Environmental Defense Fund, Inc. is processed by the Florida Supreme Court.
17 See id.

ORDER NO. PSC-2026-0344-FOF-EI
DOCKET NO. 20260020-EI
PAGE 12
By ORDER of the Florida Public Service Commission this 30th day of September, 2026 	.
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.
CMM
NOTICE OF FURTHER PROCEEDINGS OR JUDICIAL REVIEW
The Florida Public Service Commission (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
judicial review by the Florida Supreme Court in the case of an 	electric, 	gas, or telephone 	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.