Florida Public Service Commission native order document 08438-2024

FILED 8/14/2024
DOCUMENT NO. 08438-2024
FPSC - COMMISSION CLERK
BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
In re: Petition for rate increase by Tampa
Electric Company.
In re: Petition for approval of 2023
depreciation and dismantlement study, by
Tampa Electric Company.
In re: Petition to implement 2024 generation
base rate adjustment provisions in paragraph 4
of the 2021 stipul at ion and settlement
a reement, by Tam a Electric Com any .
DOCKET NO. 20240026-EI
DOCKET NO. 20230139-EI
DOCKET NO. 20230090-EI
ORDER NO. PSC-2024-0351-PHO-EI
ISSUED: August 14, 2024
PREHEARING ORDER
Pursuant to notice and in accordance with Rule 28-106.209, Florida Administrative Code
(F.A.C.), a Prehearing Conference was held on August 8, 2024, in Tallahassee, Florida, before
Commissioner Gary F. Clark, as Prehearing Officer.
APPEARANCES:
J. 	JEFFRY 	WAHLEN, 	MALCOM 	MEANS, 	and 	VIRGINIA 	PONDER,
ESQUIRES, Ausley Law Firm, Post Office Box 391, Tallahassee, FL 32302
On behalf of Tampa Electric Company (TECO)
WALT TRIERWEILER, PATRICIA A. CHR ISTENSEN, OCTAVIO SIMOES-
PONCE, CHARLES REHWINKEL, MARY A. WESSLING, and AUSTIN A.
WATROUS, ESQUIRES, Office of Public Counsel, c/o The Florida Legislature,
111 West Madison St., Suite 812, Tallahassee, FL 32399-1400
On behalf of the Office of Public Counsel (OPC)
BRADLEY 	MARHSALL 	and 	JORDAN 	LUEBKEMANN, 	ESQUIRES,
Earthjustice, 111 S. Martin Luther King, Jr. Blvd., Tallahassee, FL 32301
HEMA LOCHAN, ESQUIRE, Earthjustice, 48 Wall St., 15 th FL, New York, NY
10005
On behalf of Florida Rising, Inc. (Florida Rising) and League of United Latin
American Citizens of Florida (LULAC)
JON C. MOYLE, JR., and KAREN A. PUTNAL, ESQUIRES, Moyle Law Firm,
P.A., 118 North Gadsden Street., Tallahassee, FL 32301
On behalf of the Florida Industrial Power Users Group (FIPUG)

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LESLIE R. NEWTON, ASHLEY N GEORGE, THOMAS A. JERNIGAN, and
MICHAEL A. RIVERA ESQUIRES, 139 Barnes Drive, Suite 1, Tyndall Air
force Base, FL 32403
On behalf of Federal Executive Agencies (FEA)
NIHAL SHRINATH, ESQUIRE, 2101 Webster Street, Suite 1300, Oakland, CA
94612
SARI 	AMIEL, 	ESQUIRE, 	Sierra 	Club, 	50 	F 	Street 	NW, 	Eighth 	Floor,
Washington, DC 20001
On behalf of Sierra Club (Sierra Club)*
ROBERT 	SCHEFFEL 	WRIGHT 	and 	JOHN 	T. 	LAVIA, 	III, 	ESQUIRES,
Gardner, 	Bist, 	Bowden, 	Dee, 	LaVia, 	Wright, 	Perry 	& 	Harper, 	P.A. 	1300
Thomaswood Drive, Tallahassee, FL 32308
On behalf of the Florida Retail Federation (FRF)
FLOYD R. SELF and RUTH VAFEK, ESQUIRES, Berger Singerman, LLP, 313
North Monroe Street, Suite 301, Tallahassee, FL 32301
On behalf of Americans for Affordable Clean Energy, Inc. (AACE), Circle K
Stores, 	Inc., 	RaceTrac 	Inc., 	and 	Wawa, 	Inc. 	(collectively 	hereinafter 	Fuel
Retailers)
STEPHANIE U. EATON, ESQUIRE, Spilman, Thomas & Battle, PLLC, 110
Oakwood Drive, Suite 500, Winston-Salem, NC 27103
STEVEN W. LEE, ESQUIRE, Qualified Representative, Spilman, Thomas &
Battle, PLLC, 1100 Bent Creek Blvd., Suite 101, Mechanicsburg, PA 17050
On behalf of Walmart, Inc. (Walmart)
TIMOTHY 	SPARKS, 	CARLOS 	MARQUEZ, 	and 	ADRIA 	HARPER,
ESQUIRES, Florida Public Service Commission, 2540 Shumard Oak Blvd.,
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
* Mr. William Garner, Esq. stood in for Mr. Shrinath and Ms. Amiel on behalf of Sierra Club.

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I. 	CASE BACKGROUND
On April 2, 2024, Tampa Electric Company (TECO) filed its Petition for Rate Increase,
minimum filing requirements (MFRs), and testimony. TECO provides service to approximately
844,000 customers in a 2,000 square mile service territory in Hillsborough and portions of Polk,
Pasco, and Pinellas counties, Florida. In compliance with Section 366.06(3), Florida Statutes
(F.S.), an administrative hearing was scheduled for these matters for August 26–30, 2024.
II. 	CONDUCT OF PROCEEDINGS
Pursuant to Rule 28-106.211, F.A.C., this Prehearing Order is issued to prevent delay and
to promote the just, speedy, and inexpensive determination of all aspects of this case.
III. 	JURISDICTION
The Florida Public Service Commission (Commission) is vested with jurisdiction over
the subject matter of this proceeding by the provisions of Chapters 120 and 366, F.S. This
hearing will be governed by said Chapter and Chapters 25-6, 25-22, and 28-106, F.A.C., as well
as any other applicable provisions of law.
IV. 	PROCEDURE FOR HANDLING CONFIDENTIAL INFORMATION
Information for which proprietary confidential business information status is requested
pursuant to Section 366.093, F.S., and Rule 25-22.006, F.A.C., shall be treated by the
Commission as confidential. The information shall be exempt from Section 119.07(1), F.S.,
pending a formal ruling on such request by the Commission or pending return of the information
to the person providing the information. If no determination of confidentiality has been made and
the information has not been made a part of the evidentiary record in this proceeding, it shall be
returned to the person providing the information. If a determination of confidentiality has been
made and the information was not entered into the record of this proceeding, it shall be returned
to the person providing the information within the time period set forth in Section 366.093, F.S.
The Commission may determine that continued possession of the information is necessary for
the Commission to conduct its business.
It is the policy of this Commission that all Commission hearings be open to the public at
all times. The Commission also recognizes its obligation pursuant to Section 366.093, F.S., to
protect proprietary confidential business information from disclosure outside the proceeding.
Therefore, any party wishing to use any proprietary confidential business information, as that
term is defined in Section 366.093, F.S., at the hearing shall adhere to the following:
(1) 	When confidential information is used in the hearing that has not been filed as
prefiled 	testimony 	or 	prefiled 	exhibits, 	parties 	must 	have 	copies 	for 	the

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Commissioners, necessary staff, and the court reporter, in red envelopes clearly
marked with the nature of the contents and with the confidential information
highlighted. Any party wishing to examine the confidential material that is not
subject to an order granting confidentiality shall be provided a copy in the same
fashion as provided to the Commissioners, subject to execution of any appropriate
protective agreement with the owner of the material.
(2) 	Counsel and witnesses are cautioned to avoid verbalizing confidential information
in such a way that would compromise confidentiality. Therefore, confidential
information should be presented by written exhibit when reasonably possible.
At the conclusion of that portion of the hearing that involves confidential information, all
copies of confidential exhibits shall be returned to the proffering party. If a confidential exhibit
has been admitted into evidence, the copy provided to the court reporter shall be retained in the
Office of Commission Clerk’s confidential files. If such material is admitted into the evidentiary
record at hearing and is not otherwise subject to a request for confidential classification filed
with the Commission, the source of the information must file a request for confidential
classification of the information within 21 days of the conclusion of the hearing, as set forth in
Rule 25-22.006(8)(b), F.A.C., if continued confidentiality of the information is to be maintained.
V. 	PREFILED TESTIMONY AND EXHIBITS; WITNESSES
Testimony of all witnesses to be sponsored by the parties and Staff has been prefiled and
will be inserted into the record as though read after the witness has taken the stand and affirmed
the correctness of the testimony and associated exhibits. All testimony remains subject to timely
and appropriate objections. Upon insertion of a witness' testimony, exhibits appended thereto
may be marked for identification. Each witness will have the opportunity to orally summarize his
or her testimony at the time he or she takes the stand. Summaries of testimony shall be limited to
a total of seven minutes for each witness, including any witness presenting direct and rebuttal
testimony together.
Witnesses are reminded that, on cross-examination, responses to questions calling for a
simple “Yes” or “No” answer shall be so answered first, after which the witness may explain his
or her answer. After all parties and Staff have had the opportunity to cross-examine the witness,
the exhibit may be moved into the record. All other exhibits may be similarly identified and
entered into the record at the appropriate time during the hearing.
The Commission frequently administers the testimonial oath to more than one witness at
a time. Therefore, when a witness takes the stand to testify, the attorney calling the witness is
directed to ask the witness to affirm whether he or she has been sworn.
The parties shall avoid duplicative or repetitious cross-examination. Further, friendly
cross-examination will not be allowed. Cross-examination shall be limited to witnesses whose
testimony is adverse to the party desiring to cross-examine. Any party conducting what appears

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to be a friendly cross-examination of a witness should be prepared to indicate why that witness'
direct testimony is adverse to its interests.
VI. 	ORDER OF WITNESSES
Each witness whose name is preceded by a plus sign (+) will present direct and rebuttal
testimony together.
Witness 	Proffered By 	Issues #
Direct
Archie Collins 	TECO 	4, 69
Karen Sparkman 	TECO 	4, 16, 85, 87–89, 92, 115, 119
+ Carlos Aldazabal 	TECO 	4, 21–24, 30, 43–45, 97, 99–102,
116
+ Kris Stryker 	TECO 	14, 15, 18, 20, 43, 44, 95, 98, 116
+ Jose Aponte 	TECO 	18, 20, 22, 24, 95, 97, 98, 101
+ Chip Whitworth 	TECO 	4, 19, 25, 31, 46, 47, 96
+ David Lukcic 	TECO 	19, 96
Christopher Heck 	TECO 	17
+ Marian Cacciatore 	TECO 	3, 53
+ Lori Cifuentes 	TECO 	2, 3, 41, 42, 104
+ Ned Allis 	TECO 	5–9, 60
+ Jeff Kopp 	TECO 	5, 11, 60
+ Dylan D’Ascendis 	TECO 	39
+ John Heisey 	TECO 	18, 95, 113
+ Valerie Strickland 	TECO 	10, 33, 34, 62–66, 106
Jeff Chronister 	TECO 	1, 3, 5, 6, 10–13, 25–38, 40–69,
94–107, 109, 111, 112, 117, 120
Ashley Sizemore 	TECO 	114, 118
Jordan Williams 	TECO 	2, 41, 42, 70–93, 108–110, 115,
117, 119

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Witness 	Proffered By 	Issues #
David E. Dismukes, Ph.D.
Available on 8/29
OPC 	1–3, 41, 119
Kevin J. Mara, P.E. 	OPC 	19, 31, 52, 97
Bion C. Ostrander 	OPC 	55
J. Randall Woolridge, Ph.D. 	OPC 	36–40, 104
Lane Kollen 	OPC 	5, 7–8, 10–11, 18, 20, 26, 33–35,
40, 45, 53–56, 58, 62–65, 68–69,
95–96, 98–103, 105, 108, 112, 115
Karl Rábago
Available on 8/29 and 8/30
Florida Rising &
LULAC
14–25, 39, 53, 71–74, 76, 78–80,
96–103, 119, 120
MacKenzie Marcelin 	Florida Rising &
LULAC
119, 120
Jeff Pollock
Available on 8/29
FIPUG 	39,71–72,83,109–111
Jonathan Ly
Available on 8/29
FIPUG 	18
Christopher C. Walters 	FEA 	37–40
Brian C. Andrews 	FEA 	7
Michael P. Gorman 	FEA 	70–74
Devi Glick 	Sierra Club 	24, 32, 43–45, 59, 97, 102, 116
Steve W. Chriss
Available 8/28, 8/29, and 8/30
FRF &
Walmart
1, 39, 70–74, 79–83, 119
Tomer Kopelovich 	Staff 	49
Angela L. Calhoun 	Staff 	4
Rebuttal
Jeff Chronister 	TECO 	1, 3, 5, 6, 10–13, 25–38, 40–69,
94–107, 109, 111, 112, 117, 120
Jordan Williams 	TECO 	2, 41, 42, 70–93, 108–110, 115,
117, 119

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VII. 	BASIC POSITIONS
TECO: 	These consolidated dockets address three petitions filed by TECO: (1) a petition
for 	approval 	of 	2023 	depreciation 	and 	dismantlement 	study 	[Docket 	No.
20230139-EI]; (2) a petition to implement 2024 generation base rate adjustment
provisions in paragraph 4 of the 2021 stipulation and settlement agreement
[Docket No. 20230090-EI]; and (3) a Petition for Rate Increase [Docket No.
20240026-EI]. 	These 	dockets 	were 	consolidated 	by 	the 	Order 	Establishing
Procedure and Consolidating Dockets (OEP), Order No. PSC-2024-0096-PCO-EI,
issued April 16, 2024.
Introduction
TECO is committed to being a trusted energy partner for its customers now and in
the future. It focuses on carefully and prudently managing its operating expenses
and capital spending to ensure that it meets the growing and changing energy
needs in its service territory. Along the way, the company works diligently and
thoughtfully to continuously improve the safety, reliability, and resilience of its
electric system, improve efficiency in all areas of its operations—especially the
generating efficiency of its existing power plants—and to ensure that it can
continue serving customers at all times regardless of weather conditions.
The impacts of inflation, higher interest rates, increased insurance premiums,
customer growth, and the investments the company is making to improve its
efficiency, 	reliability, 	and 	resilience 	have 	impacted 	the 	operations 	of 	the
company. TECO’s original filing on April 2, 2024 requested a $293,634,910
annual increase in its general base rates and a $2,976,175 annual increase to its
service charges for a total annual increase to its base rates and charges of
$296,611,085 (Issue 69) to be effective with the first billing cycle of January
2025, plus incremental Subsequent Year Adjustments (SYA) of $100,074,841 and
$71,847,925 (Issue 107) to become effective with the first billing cycles in
January 2026 and 2027, respectively. On July 24, 2024, and August 1, 2024, the
company filed updated revenue requirement calculations for its 2025 test year and
2026 and 2027 SYA to reflect changes identified and discussed during discovery
and in the rebuttal testimony of Jeff Chronister (July Filing and August Filing).
Its revised requests for the 2025 test year and 2026 and 2027 SYA are
$295,521965, $95,257,228 and $69,007,620.
Safety, Reliability, and Customer Service
TECO’s solid record of safety, reliability, and customer service is not in dispute.
TECO’s reportable U.S. Occupational Safety and Health Administration (OSHA)
incidents declined from 24 in 2019 to a low of 17 in 2023. Its OSHA incident rate
declined from 1.02 in 2019 to a low of 0.70 in 2023. The company scored better
than industry average for all six J.D. Power measures of customer satisfaction in

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2023, and its Commission complaint record and service hearings do not reveal
systemic service problems. The company improved its system heat rate by 20%
from 2017 to 2023, and during that same time period, reduced outage frequency
and durations by 21% and 22%, respectively. The company’s “flickers” were 30%
less frequent and it provides 99.98% service reliability.
Issues
The Parties have identified over 120 issues in this case and divided them into 10
categories, all of which are important and seven of which are highlighted below.
1. 	Depreciation and Dismantlement (Issues 5 through 12)
Consistent 	with 	its 	2021 	Agreement, 	TECO 	filed 	a 	depreciation 	and
dismantlement study on December 27, 2023. Based on this study and its projected
plant balances, the company seeks recovery of approximately $531.4 million
(revised to $530.9 million in Issue 60) of depreciation and amortization expense
for its projected 2025 test year. The primary issues in this area include the
company’s proposed book depreciation lives for combined cycle generating
assets, solar facilities, and energy storage devices. The company’s proposed lives
for these asset categories (35, 30, and 10 years, respectively) are reasonable and
should not be lengthened as proposed by OPC and FEA. The company’s proposed
net salvage percentages are reasonable and should not be reduced as proposed by
FEA. The company’s proposed annual dismantlement expense accrual was
calculated in accordance with Rule 25-6.04364, F.A.C., and properly considers
escalation of costs, environmental remediation costs, and contingencies.
2. 	2025 Rate Base (Issues 13 through 32)
The primary issues in this area include the company’s proposed addition of 488.7
megawatts (MW) of Future Solar projects (Issue 18), Grid Reliability and
Resilience Projects (GRR Projects) (Issue 19), 115 MW of Energy Storage
Capacity projects (Issue 20), a new corporate headquarters building (Issue 21), the
South Tampa Resilience project (Issue 22), and the Polk 1 Flexibility project
(Issue 24). These projects are cost-effective; are based on analyses of available
options; promote efficiency, reliability, and resilience of the company’s system;
provide other benefits such as fuel savings, fuel diversity, and better customer
service; are prudent; and should be approved.
The 	company’s 	proposed 	Future 	Environmental 	Compliance 	project, 	which
assesses the viability of underground carbon storage at Polk Power Station (Issue
14), is a prudent step to protect the long-term viability of gas-fired generation at
Polk and to evaluate whether the company can and should invest in carbon
capture technology for Polk Unit 2.

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Sierra Club’s proposals to force early retirement of petcoke and coal generation
assets at Polk Unit 1 and Big Bend Unit 4, respectively, are discussed in the
“Other” issues and should be rejected because the assets provide needed operating
flexibility and fuel diversity. These and other reasons are explained in Issues 43,
44, and 116.
3. 	2025 Cost of Capital (Issues 33 through 40)
The two contested issues in this area are equity ratio (Issue 38) and Return on
Equity (ROE) (Issue 39). TECO urges the Commission to approve the company’s
proposed midpoint ROE of 11.5%, an authorized range of allowed ROE of plus or
minus 100 basis points, and its currently approved equity ratio of 54% (investor
sources). The intervenor recommendations for a midpoint ROE of 9.5% are too
low. FEA’s proposed 52% equity ratio is not adequate to preserve TECO’s
financial integrity and a reduction to 52% from the company’s long-standing 54%
equity ratio would be viewed as credit-negative by credit rating agencies.
4. 	2025 Net Operating Income (Issues 41 through 67)
The major issues in this area include the level of generation operations and
maintenance (O&M) expense (Issue 45), the recovery of the company’s short-
term incentive plan (STIP), long-term incentive plan (LTIP), and supplemental
employee retirement plan (SERP) as part of total salaries and benefits expense
(Issue 53), adjustments for affiliate transactions (Issue 55), and the period for
amortizing the regulatory liability associated with 2022 to 2024 solar production
tax credits (PTCs) (Issue 64). Other contested issues include whether to (a) adjust
the company’s projected 2025 operating revenues (Issue 41), (b) disallow O&M
expenses associated with coal assets at Polk Unit 1 and Big Bend Unit 4 (Issues
43 and 44), and (c) disallow a portion of the company’s directors and officers
insurance expense (Issue 56). Issue 65 on the amortization of investment tax
credits (ITCs) includes OPC’s proposal to reject normalization of ITC for energy
storage devices and amortize those ITCs over three years, but otherwise is largely
a fall out issue based on the lives approved for solar facilities and energy storage
devices in Issue 7. The Commission should approve the company’s proposals and
reject the intervenor proposals for the reasons explained under each issue.
5. 	2025 Cost of Service and Rates (Issues 70 through 93)
The major issues in this area revolve around the cost of service methodology to be
used to allocate production (Issue 71), transmission (Issue 72), and distribution
(Issue 73) to rate classes. The company filed cost of service studies for production
and transmission costs using a four Coincident Peak (CP) methodology and
distribution costs using a full Minimum Distribution System (MDS) approach as
required by the 2021 Agreement. The company also presented a 12CP and 1/13th
Average 	Demand 	(AD) 	method 	study 	for 	production 	as 	required 	by 	the

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Commission’s MFR rule. Although the company supports the cost of service
methodologies as required by the 2021 Agreement, how to allocate production,
transmission, and distribution costs to rate classes are issues to be decided by the
Commission. In any event, the Big Bend Unit 4 scrubber and Polk 1 gasifier
should continue to be allocated on an energy basis (not demand as advocated by
FIPUG) (Issue 71). The Commission should approve the company’s proposed
tariff and program changes.
6. 	2026 and 2027 SYA (Issues 94 through 110)
Some of the company’s proposed rate base additions in this case will be placed in
service in 2025 but will not be in service for the entire year, so the company’s
2025 proposed revenue increase (Issue 69) does not reflect the full annual revenue
requirement for those projects.
Other proposed rate base additions will go into service in 2026 and are not
included in the company’s 2025 proposed revenue increase (Issue 69) at all; 2027
will be the first year that these additions will be in service for a full year.
The company’s proposed 2026 SYA is designed to recover the portion of the
annual revenue requirement for the additions going into service in 2025 not
included in the company’s proposed 2025 revenue increase (Issue 69) and the
revenue requirement for additions going into service for the first time (but not a
full year) in 2026.
The company’s proposed 2027 SYA is designed to recover the portion of the
annual revenue requirement for the additions going into service in 2026 for the
first time that is not included in the company’s proposed 2026 SYA.
The projects included in the company’s proposed SYA are major projects, their
costs are reasonable and prudent, placing them in service will have a material
impact on the company’s ability to earn within its authorized range of returns, and
including them in the proposed SYA will mitigate the company’s need for
successive general rate increases; therefore, they should be approved. There is
nothing in Section 366.076, F.S., that limits SYA to cost recovery for generation
projects, thus OPC’s proposal to disallow the GRR Projects (Issue 96) should be
rejected.
The calculation of the company’s proposed 2026 and 2027 SYAs should be
updated to reflect the overall rate of return approved in Issue 40 (Issue 103) and
the deprecation lives and ITC amortization periods approved for the 2025 test
year (Issue 108). The Commission should also approve the company’s positions
on not imputing incremental revenue (Issue 104), including incremental O&M
expenses (Issue 105), rate design and development (Issues 108 and 110), and
effective date (Issue 109).

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7. 	Other (Issues 111 to 121)
The Commission should approve the company’s proposal for a corporate tax
change provision (Issue 111), storm cost recovery provision (Issue 112), asset
optimism mechanism (Issue 113), updated Clean Energy Transition Mechanism
(CETM) 	factors 	(Issue 	114), 	Senior 	Care 	program 	(Issue 	115), 	and 	other
administrative matters (Issues 17, 120, 121). The Commission should reject Sierra
Club’s proposals for future studies and actions for the company’s coal assets at
Polk Unit 1 and Big Bend Unit 4 (Issue 116). The company’s energy conservation
performance under the Florida Energy Efficiency and Conservation Act (FEECA)
is outstanding and should be considered by the Commission when setting rates in
this case (Issue 118).
OPC: 	The burden of proof in a Commission proceeding is always on a utility seeking a
rate change, and upon other parties seeking to change established rates. Fla.
Power Corp. v. Cresse, 413 So.2d 1187, 1191 (Fla. 1982). TECO has the burden
to prove that every aspect of their requested rate increase is justified and
supported by evidence at hearing. Further, pursuant to Section 366.06(1), F.S., the
Commission may only approve the parts of TECO’s rate request which result in
rates that are fair, just, and reasonable for each customer class. TECO’s requested
rate increase would translate to an over 50% increase in base rate. The policy for
energy in the State is now to “ensure an adequate, reliable, and cost-effective
supply of energy for the state in a manner that promotes the health and welfare of
the public . . .” with goals including “[e]nsuring a cost-effective and affordable
energy supply.” See Section 377.601 (1) and (2)(a), F.S. (2024). TECO’s bloated
revenue request is contrary to the State’s goal of providing affordable, reasonable
rates for each customer class.
TECO’s request grossly overstates the revenue requirement needed to provide
safe and reliable service without even considering either SYA for 2026 and 2027.
OPC’s experts will testify in depth about the flawed and excessive nature of
TECO’s requested rate increase. Below are summaries of OPC witnesses’ major
adjustments and areas of concern.
Revenue Forecast Increases
OPC witness Dr. David Dismukes recommends after reviewing TECO’s retail
revenue forecast that 2025 forecasted test year achieved revenues should be
increased by at least $12 million and that the Commission should make the
reasonable 	adjustment 	of 	simply 	excluding 	several 	proposed, 	yet 	poorly
documented out-of-model adjustments. He also demonstrates that the forecasted
achieved retail revenues should be increased of $20 million in 2026 and $26
million in 2027 by application of the same adjustment. He demonstrates that these
adjustments are conservative based on historical under forecasting of TECO’s
retail revenues by 2.1%. These OPC recommendations result in a revenue

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requirement reduction of $12 million in 2025, and an additional reduction of
$7.994 	million 	in 	2026, 	and 	$6.123 	million 	in 	2027. 	Dr. 	Dismukes 	also
recommends 	that 	the 	Commission 	consider 	energy 	affordability 	in 	this
proceeding, and all future utility base rate proceedings, in evaluating rate increase
requests consistent with the trends in other U.S. regulatory jurisdictions.
SYAs—Grid Reliability and Resiliency Projects
OPC witness Kevin Mara reviewed TECO’s proposal for projects in 2026 and
2027 that TECO included under its GRR Projects. He recommends that the total
costs associated with the GRR Projects be excluded from the SYAs since the
SYAs are not the proper funding mechanism for various reasons (i.e., not
completed by end of the SYA period, otherwise routine replacements, and not
Board approved). He also recommends that $7.94 million be excluded for the
excess number of spare power transformers and that all the Distribution Feeder
Hardening cost be included for consideration in the storm protection plan (SPP)
process and its clause recovery for a decrease of $7.97 million. These OPC
recommendations result in a revenue reduction of $0.718 million in the 2025 test
year, and $4.599 million in SYA 2026, and $28.788 million in SYA 2027.
Cost of Capital
OPC witness Dr. Woolridge conducted a review of appropriate cost of equity and
equity ratio for TECO. Based on his acceptance of TECO’s requested high equity
ratio of 54%, he recommends a ROE of 9.50% yielding an overall fair rate of
return (ROR) from investor capital of 7.19%. OPC’s ROE recommendation
results in a revenue reduction of $126.379 million in 2025 and an additional
revenue reduction of $9.273 million in SYA 2026 and $5.022 million in SYA
2027.
Affiliate Transactions
OPC 	witness 	Bion 	Ostrander 	reviewed 	TECO’s 	affiliate 	transactions, 	the
applicable Cost Allocation Manuals (CAMs) and reviewed TECO’s procedures
related 	to 	affiliate 	transactions. 	Based 	on 	deficiencies 	in 	TECO’s 	affiliate
processes, he recommends changing the allocation methodology factors in the
Modified Massachusetts Method (MMM), putting into place a CAM for cost
allocated from Emera to TECO, and disallowing one half of unsupported expense.
He also recommends that the Commission require TECO to discontinue operating
as the central service provider (CSP) or require the nine measures outlined more
fully in his testimony. These are summarized as follows: (1) implement a plan for
achieving recommendations; (2) identify costs saving as CSP and flow back to
customers; (3) document and explain when affiliate takes back share service in-
house; (4) change accounting to track and audit affiliate transactions easily; (5)
reconcile accounting in (4) to FERC Form 1; (6) have an external audit of CSP

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role; (7) monthly invoices for CSP services; (8) Emera and TECO should have
written internal controls; and (9) Emera should perform an internal audit of TECO
as CSP. The overall effect of OPC’s affiliate transactions recommendations
results in a revenue reduction of $6.313 million in the 2025 test year.
Solar and Battery Lives, Investment and Production Tax Credits, and Other
Adjustments
OPC witness Lane Kollen recommends maintaining the status quo for the lives of
the Solar facilities at 35 years and Battery Storage at 20 years based on the utility
planning. He also recommends adjustments for amortizing over three years the
deferred ITCs and deferred PTCs with carrying costs. Mr. Kollen also makes
adjustments to reduce the revenue requirement for expense related to planned
generation maintenance for major outages expense, pensions, portion of active
employee Other Post-retirement Employee Benefit (OPEB), long-term incentive
compensation, SERP, 50% of Directors and Officers (D&O) insurance premiums,
and 50% of Board of Directors expense. These OPC recommendations result in a
revenue reduction of at least $75.734 million in the 2025 test year revenue
requirement. Some of the recommended adjustments result in an additional
revenue requirement reduction of at least $17.952 million in SYA 2026 and at
least $13.699 million in SYA 2027.
OPC will demonstrate deficiencies in the testimony and evidence presented by
TECO’s witnesses. In today’s tough economic climate, TECO’s customers are
already under great financial pressure, so any increase will have a significant
impact 	on 	them. 	Now, 	more 	than 	ever, 	the 	Commission 	must 	consider
affordability of the customer’s bills when evaluating TECO’s rate request.
Ultimately, the Commission must hold TECO to its burden and only approve the
portions of TECO’s rate request which are fair, just, and reasonable.
FL RISING/
LULAC: 	The Commission should deny TECO’s request for increased rates. Last year,
TECO had the third highest residential electricity bills in the nation, out of 149
utilities with more than 100,000 residential customers. Despite its already-high
bills, TECO now requests a $296.6 million revenue increase for 2025 and
recommends it receive an astounding midpoint ROE of 11.5%. Moreover, under
TECO’s 4CP and MDS cost-of-service methodology, it wants to continue shifting
a majority of its additional costs away from large commercial and industrial
customers and onto residential customers.
First, the MDS approach TECO uses is economically regressive, defies cost
causation principles, and forces lower energy usage customers—typically low-
income customers—to subsidize wealthier, higher usage customers. The MDS
approach classifies demand costs as customer-related despite the fact that these
extrapolated costs do not reflect the actual cost of connecting a customer to the

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grid. TECO’s approach thus uses inflated fixed residential electricity charges,
creating greater impacts on low-income customers given the high correlation
among TECO customers between low usage rates and lower household income.
The 4CP approach used by TECO also unduly burdens residential customers.
4CP 	focuses 	narrowly 	on 	peak 	demand, 	allowing 	residential 	customers 	to
subsidize large commercial and industrial customers with relatively flat loads.
For instance, use of 4CP creates an additional $71 million in costs residential
customers would not otherwise have to pay under a 12CP and 1/13th AD method,
without the use of MDS.
Additionally, TECO’s Future Solar Investments, totaling $786.4 million, reflect
the bulk of its recent generation investments. Under its current cost-of-service
methodology, TECO seeks to allocate all of these investment costs based on
capacity 	demands, 	pushing 	more 	of 	the 	costs 	onto 	residential 	customers
contributing to peak load. This methodology does not promote just and reasonable
rates. TECO readily acknowledges that the value of its solar investments comes
from 	the 	total 	energy 	solar 	produces 	throughout 	the 	day, 	not 	its 	small
contributions to peak demand. For instance, a 74.5 MW solar power plant placed
in service in 2027 will contribute a mere 1.5% of its total nameplate capacity to
meet the summer peak and will contribute nothing to the winter peak. Thus, to
effect just and reasonable rates, TECO should not allocate most of these costs to
residential 	customers 	when 	large 	commercial 	and 	industrial 	customers
consistently use large amounts of energy throughout the day.
In addition to TECO charging residential customers for solar investments that
minimally contribute to peak demand, TECO requests that residential customers
pay for the bulk of other new generating projects they will derive little to no
benefit from and that are unnecessary for maintaining adequate reserve margins.
For example, TECO wants to recover costs for the roughly $200 million fossil-
fueled South Tampa Resilience Project, which essentially acts like a subsidy to
the U.S. government. TECO also wants to spend almost $54 million to increase
TECO’s dependence on oil with its Polk Fuel Diversity Project, and TECO seeks
to recover for its Polk 1 Flexibility Project even though retirement of the unit will
yield savings for customers.
TECO additionally requests rate recovery from mostly residential customers for
other non-generating portions of its recent spending spree. TECO wants to
recover the costs for a new Corporate Headquarters—coming in at a revenue
requirement of over $1 billion—that weighs the importance of employee parking
and nearby amenities above that of grid resilience and reliability. TECO also
wants to charge customers over $33 million annually for short- and long-term
employment 	compensation 	packages 	that 	encourage 	employees 	to 	forego
affordability considerations and promote cost increases. Additionally, in 2025
alone, TECO will spend $716 million on new transmission and distribution
projects. 	These 	projects 	include 	the 	GRR 	Projects, 	expensive 	transmission

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investments destined for quick obsolescence. Among other increased service
charges, TECO also proposes to increase its Initial Service Connection fee to
$168.00, well above Florida’s inflation rate last year and well above the other
Florida investor-owned utilities (IOUs) and public utilities.
The Commission should prohibit TECO from using its out-of-step and regressive
MDS method that yields a $1.07 per customer per day charge, when that charge
should be no higher than $0.43 per customer per day. The Commission should
also approve a midpoint ROE of no higher than 9.50% to provide significant
affordability 	improvements 	without 	sacrificing 	reliability. 	Additionally, 	the
Commission should reject TECO’s use of 4CP and MDS and instead permit a
12CP and 50% AD method, given, among other reasons, that most of TECO’s
new generation is solar and thus contributes only minimally to capacity at peak
load. As it stands, TECO’s current proposals in this rate case will result in unjust
and unreasonable rates in defiance of basic ratemaking principles and Florida law.
FIPUG: 	TECO’s total rate case request is overstated, as the company seeks to increase
customer rates by nearly 30% during the next three years, featuring a significant
20% rate increase in 2025 alone. A host of adjustments are in order that will
meaningfully reduce TECO’s total ask of $296.6 million dollars, adjustments that
will be detailed by evidence adduced at the upcoming rate case hearing. For
example, TECO’s requested ROE of 11.5% is 130 basis points, or approximately
$130 million dollars higher than the 10.2% percent ROE that was unanimously
agreed to by all the parties in the 2021 Settlement Agreement. The nationwide
average for vertically-integrated electric IOUs in rate case decisions during 2023
and through May of 2024 is 9.78%, 172 basis points less or approximately $106
million dollars less than TECO’s ROE request.
FIPUG supports the allocation of production and transmission plant using the 4CP
approach, an approach that was agreed to unanimously in the 2021 Settlement
Agreement and approved by the Commission. Put simply, 4CP measures TECO’s
system peaks once a month during the system peak during the hottest months of
June, July, and August, and once during the coldest month, January. Importantly,
TECO’s cost of service study witness Jordon Williams states that the 4CP method
reflects cost causation in relation to TECO’s peak demands. The 4CP approach is
supported in this case by TECO, FIPUG, and FEA, and was supported in the 2021
rate 	case 	by 	Walmart 	and 	also 	the 	West 	Central 	Florida 	Hospital 	Utility
Association, who has not intervened in the 2024 rate case.
FIPUG also supports the use of the MDS rate design approach, a methodology
that the Commission has previously approved and which more fairly allocates
utility costs to provide distribution service. The MDS approach recognizes that
the distribution network must be ready to serve customers, irrespective of the
amount of power and energy used by customers. Allocating a portion of
distribution network costs on the number of customers recognizes the readiness to

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serve. Accordingly, using MDS to allocate distribution network costs based on the
number of customers, which is consistent with cost causation, is the proper
approach.
FIPUG does not support the drastic changes in the time-of-use rating periods
proposed by TECO. Specifically, the proposed Super Off-Peak period would set
very low energy prices during daytime hours. 	The proposal, which relies solely
on speculative projections of marginal energy prices, lacks foundation. 	It would
also be unprecedented. 	No other utility in Florida (which also have significant
solar capacity) has a similar low-cost rating period during daytime hours. 	This
change would be both disruptive (requiring customers to fundamentally change
their usage patterns), and it would encourage more energy usage during daytime
hours when TECO generally experiences its highest electricity demand, which is
contrary to long-standing practice.
TECO’s cost-effectiveness analysis of its proposed solar projects is lacking and
not robust. The benefits are overstated because it uses inflated natural gas prices
and assumes a value for carbon emissions, a misplaced assumption given that a
tax on fossil fuel emissions has not been enacted in Florida or at the federal level.
Additionally, TECO has not provided any assurance or guarantee that it will not
exceed the projected construction costs and that it will earn production tax credits
as projected. 	Absent such guarantees, customers have no certainty of receiving
the promised benefits.
Should the Commission approve TECO’s Solar Projects, it should impose
consumer protections, including a $1,609/kW cost cap, ensure that TECO credits
at least 100% of the production tax credits projected by TECO in its cost-
effectiveness 	analysis 	(regardless 	of 	actual 	performance), 	and 	establish 	a
minimum 26% annual operating capacity factor to ensure that customers receive
the projected benefits as suggested by FIPUG witness Ly.
FEA: 	FEA recommends TECO be awarded a ROE of 9.60%; a capital structure equity
ratio of 52.0%; and an overall ROR of 6.36% which reduces TECO’s electric
retail revenue requirements by approximately $134.7 million.
FEA also proposes several adjustments to TECO’s proposed depreciation rates.
These adjustments include a recommendation to: (1) increase the life of the Big
Bend and Bayside combined cycle plant from a 35-year life to 40 years; (2) make
adjustments to the interim retirement survivor cure for Production plant accounts
312, 341, 342, and 343; (3) maintain the Average Service Life of Account 367 at
the current 45-year life and TECO’s proposal to shorten it; and (4) make
adjustments to the net salvage rates for Transmission, Distribution and General
Plant (TD&G) accounts 356, 362, 363, 365, 367, 392.02, 392.03, 392.12, and
392.13. These adjustments are captured in FEA Exhibit BCA-6 and result in a
decrease in TECO’s 2024 depreciation expense by $31.38 million.

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Lastly, FEA supports TECO’s class cost of service study and TECO’s proposed
revenue spread. However, FEA recommends an adjustment to the proposed rate
design for the time-of-day rates. Specifically, FEA recommends the GSLDPR
demand charge be increased, and the energy charge be reduced to appropriately
reflect the demand-related cost that should be collected through demand rates.
SIERRA
CLUB: 	TECO customers face some of the highest electricity rates in the country, in part
due to TECO’s continued operation of uneconomic and obsolete fossil-fueled
generating units. In particular, it is no longer reasonable for TECO’s ratepayers to
shoulder 	the 	costs 	of 	maintaining 	outdated 	coal 	and 	petcoke 	combustion
equipment at the Polk Unit 1 and Big Bend Unit 4 generating stations. Both plants
have already been retrofitted such that they can run exclusively on gas, a lower-
cost and less polluting fuel than coal and petcoke, yet TECO seeks to continue
recovering O&M costs to keep coal and petcoke equipment available, in addition
to saddling TECO customers with the additional costs of fuel volatility and
environmental compliance associated with coal production going forward. TECO
should be required to retire all integrated gasification (IG) components at Polk
Unit 1 by 2024 and cease all coal combustion at Big Bend Unit 4 by 2025.
Even once coal combustion is retired at those plants, it is still unreasonable for
TECO customers to shoulder the financial risks of operating Polk Unit 1 and Big
Bend Unit 4 past 2030, due to projected operation costs and the risk of high
environmental compliance costs. TECO should be required to shift the Polk Unit
1 and Big Bend Unit 4 retirement dates to 2030. At the very least, TECO should
be required to study different retirement scenarios for Polk Unit 1 and Big Bend
Unit 4, as compared against the costs of alternative replacement resources, and
TECO should be prevented from recovering capital and O&M costs for these
units until it completes such analysis.
It would be unjust and unreasonable for customers to pay for costs associated with
the proposed Polk Unit 1 Flexibility project. Polk Unit 1 is a 220 MW dual-fuel
plant that is capable of burning coal or petcoke using integrated gasification
combined-cycle (IGCC) technology, but has combusted only gas since 2018.
Through the Polk Unit 1 Flexibility project, TECO seeks to recover $80.5 million
to convert Polk Unit 1 into a simple-cycle combustion turbine (CT), while
retaining IG technology to burn petcoke or coal in the event of a gas crisis. TECO
has not justified incurring the steep costs of converting a relatively small unit with
a low capacity factor from one gas combustion technology to another. Moreover,
it has certainly not justified keeping IG components in long-term standby, with or
without the CT conversion. And it has not justified the costs of keeping the IGCC
steam turbine (ST) and heat recovery steam generators (HRSG) online after the
CT conversion is completed. In fact, if TECO does convert Polk Unit 1 to a CT, it
would only be able to burn petcoke after an additional year-long upgrade. TECO
is unable or unwilling to offer an estimate of the cost of that upgrade. Nor has

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TECO provided analysis demonstrating the reliability needs of a unit as small,
expensive, and rarely utilized as Polk Unit 1. Nonetheless, TECO unreasonably
expects ratepayers to finance the ongoing O&M costs of obsolete coal- and
petcoke-burning equipment, which it has not used since 2018. TECO further
unreasonably expects ratepayers to finance an expensive conversion project
without 	showing 	its 	cost-effectiveness 	compared 	to 	alternative 	replacement
resources. If the Commission approves the Polk Unit 1 Flexibility project, TECO
should nonetheless be required to immediately retire the IG, ST, and HRSG
components at Polk Unit 1.
It would be unjust and unreasonable for TECO to recover the costs of burning
coal at Big Bend Unit 4 past 2025 and to recover the costs of keeping Big Bend
Unit 4 online past 2030. Big Bend Unit 4 is a dual-fuel 486 MW generating unit
that has historically burned both coal and gas, but which TECO plans to primarily
power with gas due to coal’s high fuel costs. For three of the past five years, Big
Bend Unit 4 has been uneconomic for TECO’s ratepayers, with a net negative
value. TECO’s conservative projections illustrate that Big Bend Unit 4 will
continue to be uneconomic, as its costs will exceed its value to ratepayers over the
period from 2024 to 2033, largely because the plant has high costs and a low
utilization factor. These projections do not factor in the very real risk of additional
environmental compliance costs stemming from federal regulations.
Retiring Polk Unit 1 and Big Bend Unit 4 early would enable TECO to avoid the
significant and unaffordable risk of incurring costs to comply with the U.S.
Environmental Protection Agency’s (EPA) Section 111 greenhouse gas, Mercury
and Air Toxics Standards, Effluent Limitation Guidelines (ELG), and Coal
Combustion Residuals rules, each of which were finalized earlier this year. As an
illustration, EPA projects that, to comply with the federal ELG guidelines, which
require zero discharges of coal combustion wastewaters by 2028, TECO could
incur $129 million in capital costs at Big Bend Unit 4 and $9 million in capital
costs at Polk Unit 1. TECO claims it can avoid these costs by utilizing deep
injection wells, but it has not confirmed with EPA that such a plan is legally
compliant, nor has it disclosed the costs of operating those wells or the risks and
associated costs of leakage or other forms of well failure. EPA’s recently finalized
Section 	111 	greenhouse 	gas 	standards 	may 	impose 	additional 	costs 	and
restrictions on the operation and flexibility of Polk Unit 1 and Big Bend Unit 4.
These rules require co-firing with gas at least 40% of the time by 2030 or
installing prohibitively expensive carbon capture and storage technology if plants
operate past 2032.
Last, TECO is not only saddling customers with unjust and unreasonable costs
from uneconomic coal units; it has also has failed to capitalize on billions of
dollars available under the federal Energy Infrastructure Reinvestment (EIR)
program. The EIR, administered by the U.S. Department of Energy’s Loan
Programs 	Office, 	could 	assist 	TECO 	in 	financing 	additional 	clean 	energy

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resources in lieu of Polk Unit 1 and Big Bend Unit 4. EIR funds take the form of
long-duration, low-cost loans for retiring fossil assets—which can assist utilities
in financing the undepreciated capital costs of a plant—coupled with investments
in clean renewable energy resources.
In sum, Sierra Club urges the Commission to reject the recovery of O&M costs
associated with Polk Unit 1’s IG components and to require TECO to retire those
components by 2024. The Commission should further reject recovery of the Polk
Unit 1 Flexibility project unless TECO demonstrates that the $80.5 million price
tag to convert this unit to a simple cycle is lower-cost than replacing it with clean
energy. And even if the Flexibility project is approved, the Commission should
require TECO to immediately retire the IG, ST, and HSRG components at Polk
Unit 1. The Commission should similarly reject recovery of any spending on coal
operations at Big Bend Unit 4 and require TECO to cease coal combustion at Big
Bend Unit 4 by 2025. Finally, the Commission should direct TECO to apply for
EIR funding to retire Polk Unit 1 and Big Bend Unit 4, study clean replacement
resources, and replace their capacity with clean energy resources by 2030.
FRF: 	FRF is a statewide organization with more than 8,000 members in Florida, many
of whom are retail customers of TECO. FRF and its members support utilities’
needs for sufficient revenues to enable them to provide safe, adequate, and
reliable service, and to earn a reasonable return on their prudently incurred
investments in assets used and useful in providing that service. However, as
customers in their own right and recognizing the needs of all Florida citizens for
safe and reliable electric service at fair, just, and reasonable prices, the FRF
opposes rates that are greater than necessary for the utility to provide safe and
reliable service. The Commission’s statutory task is to serve the public interest by
ensuring that utilities provide safe and reliable service at the lowest possible cost.
Thus, the question in this proceeding, as in all general public utility rate cases, is
how much revenue TECO actually needs to provide safe and reliable service and
to earn a reasonable return on its investment. The evidence shows that TECO’s
proposed rates would, if approved by the Commission, produce grossly excessive
revenues to the detriment of TECO’s customers and to the Florida economy
generally, and that TECO’s proposed rates are contrary to the public interest for
these reasons. Specifically, where TECO has requested $296.6 million per year in
2025, TECO can provide safe and reliable service and earn a reasonable return,
consistent with the returns on common equity approved by regulatory bodies for
many other electric utilities in the United States, with a total revenue increase of
only $75.3 million per year in 2025. This is roughly one-fourth, or only 25%, of
TECO’s 	excessive 	request. 	The 	evidence 	also 	demonstrates 	that 	TECO’s
requested SYAs for 2026 and 2027 are also excessive and should be limited to the
minimum amounts necessary for TECO to provide safe and reliable service,
including a reasonable return on its investment.

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TECO’s requested ROE is particularly excessive and accounts for a significant
amount of its overstated and over-reaching rate increase request. TECO has
requested a midpoint ROE of 11.50%, which is 155 basis points greater than its
last authorized midpoint, 130 basis points greater than its current ROE, which was
increased pursuant to a “trigger” provision in its 2021 settlement, and 200 basis
points greater than the ROE recommended by OPC witness Professor J. Randall
Woolridge. Providing a return of TECO’s current “Trigger ROE” instead of its
excessive request would save customers almost $80 million a year; providing a
return based on Professor Woolridge’s recommendation, which is based on
extensive analysis of other regulatory commissions, other utilities, and the risks
that TECO actually faces, would save customers well over $100 million a year as
opposed to TECO’s excessive request. Regarding the risks that TECO faces, the
Commission must recognize that the use of a projected test year reduces TECO’s
risk, and that allowing TECO to recover nearly 40% of its total revenues through
cost 	recovery 	clause 	charges—Fuel, 	Environmental, 	Energy 	Conservation,
Capacity Cost, Storm, and so on—similarly reduces TECO’s risks, and these
factors must be recognized in setting an ROE upon which retail rates are to be
based.
TECO has also overstated its expenses in many areas. The combined evidence
submitted by witnesses for OPC, FRF, and other parties representing customer
interests demonstrates that TECO can fulfill its job, and that the Commission can
fulfill its statutory mandate of serving the public interest by ensuring that TECO
has sufficient revenues but not excessive revenues, by basing TECO’s 2025 rates
on a revenue increase of no more than $43.8 million per year.
FUEL
RETAILERS: The Fuel Retailers sought intervention in this matter for two purposes. First, to
ensure that as electric retail customers of TECO that the rates and charges being
proposed for large customers such as Circle K Stores, Inc., RaceTrac Inc., and
Wawa, Inc. were being fairly and reasonable set. Second, the Fuel Retailers had a
special interest and concern regarding the Electric Vehicle (EV) Charging Pilot
Program of TECO, especially given the actions in the company’s 2021 rate case,
and, specifically, whether in this rate case TECO was proposing any changes that
could be in violation of the requirements of HB 1645, Section 6 (to be codified at
366.94, F.S.) (Chapter 2024-186, Laws of Florida), which would adversely impact
the Fuel Retailers as retail electric customers and as providers of EV charging
services. Just one day before filing its MFRs and other required documents were
filed in this general rate case docket, TECO on April 1, 2024, filed in Docket No.
20240054-EI a request to extend and expand its EV Charging Pilot Program.
Before the Fuel Retailers could file an intervention in this new EV charging
docket, given the Fuel Retailers’ notice to TECO of their intent to intervene and
challenge that extension and expansion, TECO withdrew its request in Docket
20240054-EI. The Fuel Retailers appreciate this action by TECO. Consistent with
the scope of the Order granting the Fuel Retailers intervention into this rate case,

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the Fuel Retailers believe that thus far TECO has not pursued any EV charging
activities in this docket that would be in violation of HB 1645 or the order
granting intervention. Going forward, the Fuel Retailers intend to continue to
participate in these proceedings to ensure that actions are not taken that would
adversely impact or otherwise discriminate against the electric services that the
Fuel Retailers take from TECO.
WALMART: Walmart adopts FRF's Statement of Basic Position except where noted otherwise
in the Issues below.
STAFF: 	Staff's positions are preliminary and based on materials filed by the parties and on
discovery. The preliminary positions are offered to assist the parties in preparing
for the hearing. Staff's final positions will be based upon all the evidence in the
record and may differ from the preliminary positions stated herein.
VIII. 	ISSUES AND POSITIONS
2025 TEST PERIOD AND FORECASTING
ISSUE 1: 	Is TECO's projected test period for the twelve months ending December 31,
2025, appropriate?
TECO: 	Yes. TECO’s proposed test period of the twelve months ending December 31,
2025 is appropriate for use as a test year because (1) 2025 is the first year the
company’s proposed rates are proposed to be in effect and (2) the company’s
financial budget for that period is representative of TECO’s projected revenues
and costs of service, capital structure, and rate base needed to provide safe,
reliable and cost-effective electric service to its customers. (Chronister)
OPC: 	Yes, with adjustments.
FL RISING/
LULAC: 	Yes, with adjustments.
FIPUG: 	Yes. However, adjustments recommended by OPC should be made.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	A projected test year is consistent with Commission practice. The Commission
must recognize that using a projected test year reduces risks faced by the utility,

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TECO in this case, and this reduced risk must be reflected in the ROE used to set
rates.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 2: 	Are TECO’s forecasts of customers, KWH, and KW by revenue and rate
class, appropriate?
TECO: 	Yes. The company’s customer, demand, and energy forecast for 2025 was based
on 	assumptions 	developed 	by 	industry 	experts 	that 	were 	the 	most 	recent
assumptions available at the time the forecasts were prepared. The company used
theoretically and statistically sound forecasting methods previously reviewed and
approved by the Commission. The company’s use of “out of model” adjustments
for changes in energy efficiency, electric vehicle charging, and private rooftop
solar is reasonable and appropriate. OPC’s proposed base revenue adjustments for
2025, 2026, and 2027 rely on a methodology that overlooks key facts, has severe
shortcomings, 	is 	inaccurate, 	and 	therefore 	should 	be 	rejected. 	(Cifuentes,
Williams)
OPC: 	No. TECO’s forecasting fails to conform to historic trends and is biased by
TECO’s usage of out-of-model adjustments. As a result, TECO’s forecasts are
consistently lower than actuals. For example, the average forecast variance in
TECO’s prior two rate cases was 2.1%, which, if applied to this case, would result
in higher forecasted achieved retail revenue of $31 million in 2025, $37 million in
2026, and $39 million in 2027.
FL RISING/
LULAC: 	No.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No. Agrees with OPC as to appropriate corrections to TECO’s forecasts.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 23
FUEL
RETAILERS: No position.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 3: 	What are the inflation, customer growth, and other trend factors that should
be approved for use in forecasting the test year budget?
TECO: 	TECO’s 2025 forecast was prepared using a 2.1% inflation rate, a 1.7% increase
in customer growth, a 3.75% increase for non-union labor, and a 3.5% increase
for union labor. These factors are reasonable and should be approved. (Cifuentes,
Chronister, Cacciatore)
OPC: 	A moderate sales/revenue adjustment which simply excludes several of TECO’s
proposed out-of-model adjustments is reasonable.
FL RISING/
LULAC: 	Assumptions used for forecasting customer growth should include Hillsborough
County 	population 	estimates, 	Hillsborough 	County 	Commercial 	and
Manufacturing employment, building permits, and time-trend variables. Inflation
continues to come down and should be assumed to be approximately 2%. Energy
sales growth assumptions must not rely on 20-year normalized weather patterns,
but should assume that the increasing heat that the Tampa-area is experiencing
from climate change will continue and will continue to get worse. If it is TECO’s
position that this pattern will not continue, then none of the investments TECO is
making for “resiliency” (the vast majority of their investments) should be
allowed. Customer growth should be assumed to continue at approximately at
least 1% per year.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	The inflation, customer growth, sales growth, and other trend factors used in
forecasting for TECO’s test year budget are those recommended by OPC’s
witnesses.
FUEL
RETAILERS: No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 24
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
QUALITY OF SERVICE
ISSUE 4: 	Is the quality of electric service provided by TECO adequate?
TECO: 	Yes. TECO provides excellent customer service. The company scored better than
industry average for all six J.D. Power measures of customer satisfaction in 2023.
Its Commission complaint record and service hearings do not reveal systemic
service problems. The company improved its system heat rate by 20 percent from
2017 to 2023. Since 2017, TECO reduced the frequency of power outages by 21%
and shortened the duration of those outages by 22%. It’s “flickers” were 30% less
frequent 	and 	it 	provides 	99.98% 	service 	reliability. 	(Sparkman, 	Aldazabal,
Whitworth, Collins)
OPC: 	The Commission held several customer service meetings in this matter in which
the 	sworn 	testimony 	provided 	by 	TECO’s 	customers 	was 	overwhelmingly
negative. 	While 	TECO’s 	electric 	service 	may 	be 	adequate 	for 	ratemaking
purposes, the Commission should bear this testimony in mind.
FL RISING/
LULAC: 	No. Per the customer service hearings, there is significant room for improvement.
(Service hearing witnesses).
FIPUG: 	Yes.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 25
DEPRECIATION AND DISMANTLEMENT STUDY
ISSUE 5: 	Should 	currently 	prescribed 	depreciation 	rates 	and 	provision 	for
dismantlement of TECO be revised?
TECO: 	Yes. The 2023 Depreciation Study filed by TECO on December 27, 2023 shows
that the company’s currently prescribed depreciation rates and provision for
dismantlement should be revised. (Allis, Kopp, Chronister)
OPC: 	The present approved service life for solar assets is a 35-year service life and
should be retained.
FL RISING/
LULAC: 	Yes. The depreciation rates should be revised to reflect the presently approved
service lives for solar assets. The provision for dismantlement should be reduced
to remove post-test year escalations of estimated costs, reduce estimated solar site
restoration costs, and reflect longer service lives for solar and battery assets.
(Kollen)
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: The Commission should ensure that Account 370.7 – EV Charging Stations,
should include only EV charging stations and related equipment associated with
TECO’s public offering of EV charging consistent with the intent of HB 1645,
Section 6 (to be codified at 366.94, F.S.) (Chapter 2024-186, Laws of Florida).
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 6: 	What should be the implementation date for new depreciation rates and the
provision for dismantlement?
TECO: 	January 1, 2025. This effective date matches the proposed effective date of the
company’s proposed new 2025 customer rates. (Chronister, Allis)

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 26
OPC: 	The new depreciation and dismantlement rates should be implemented with the
change in base rates upon approval of the Commission.
FL RISING/
LULAC: 	January 1, 2025.
FIPUG: 	The implementation date should be effective on the date that rate adjustments in
this case are effective.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 7: 	What depreciation parameters and resulting depreciation rates for each
depreciable plant account should be approved?
TECO: 	The Commission should approve the parameters and depreciation rates for plant
accounts as specified in Document 4 of Exhibit NA-1. The Commission should
reject intervenor proposals and approve 35, 30, and 10 year lives for combined
cycle, solar, and energy storage, respectively. The Commission should also reject
FEA’s proposed interim survivor curves, its proposed survivor curve for account
367, and its net salvage estimates. As noted in Issues 43 and 44, the Commission
should reject Sierra Club’s proposals to early retire the IGCC components at Polk
Unit 1 and the coal combustion assets at Big Bend Unit 4, so it should also reject
Sierra Club’s proposed adjustments to depreciation parameters. (Allis)
OPC: 	The present approved service life for solar assets is a 35-year service life and
should be retained. While TECO has requested an acceleration of capital recovery
through a reduction in the current depreciation study to a 30-year service life,
TECO has relied on 35-year service life for planning purposes in its 2024 Ten
Year Site Plan filed April 1, 2024. TECO has not provided evidence that solar
assets will not operate 35-years and would not be harmed by continuing the
currently approved service life.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 27
Further, the battery storage assets should reflect a 20-year service life. The 10-
year service life proposed by TECO for battery storage is unduly short and
inconsistent with the industry trend of a 15–20-year service life for planning and
ratemaking. The depreciation expense should be reduced by $5.942 million for
using 20-year service life for Battery Storage assets. Decrease the depreciation
expense by $9.519 million by using the currently approved 35-year service life for
solar assets.
The Commission should also consider reasonable production plant life spans and
other parameters set forth by FEA’s witness.
FL RISING/
LULAC: 	A 20-year service life should be used for Battery Energy Storage System assets.
A 35-year service life should be used for solar assets. For the depreciation rates
for each depreciable plant account, we adopt OPC’s position.
FIPUG: 	Adopts the position of OPC.
FEA: 	The depreciation parameters and depreciation rates presented in Exhibit BCA-6
should be approved.
SIERRA
CLUB: 	Depreciation 	parameters 	and 	rates 	should 	be 	adjusted 	to 	reflect 	the 	2024
retirement of IG technology at Polk Unit 1, along with 2030 retirement dates for
Polk Unit 1 and Big Bend Unit 4.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 8: 	Based on the application of the depreciation parameters and resulting
depreciation rates that the Commission approves, and a comparison of the
theoretical reserves to the book reserves, what are the resulting imbalances?
TECO: 	As of December 31, 2024, the company’s book reserve is approximately $167
million lower than the theoretical reserve shown in the 2023 Depreciation Study,
so the reserve imbalance is approximately negative $167 million. (Allis)
OPC: 	This is a fall out based on the resolution of Issue 7.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 28
FL RISING/
LULAC: 	The Commission has not deemed any specific depreciation rates as appropriate
yet, and therefore we cannot calculate the resulting imbalance. That being said, a
35-year 	depreciation 	life 	for 	solar 	assets 	should 	be 	used, 	and 	a 	20-year
depreciation life for battery assets.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 9: 	What, if any, corrective reserve measures should be taken with respect to the
imbalances identified in Issue 8?
TECO: 	The theoretical reserve balance identified in Issue 8 should be addressed through
remaining life depreciation rates. There is no need for reserve balance transfers.
(Allis)
OPC: 	All imbalances should be corrected using the remaining life technique in this case.
FL RISING/
LULAC: 	Remaining life technique.
FIPUG: 	Imbalances should be via the remaining life approach.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 29
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 10: 	Should the current amortization of investment tax credits (ITCs) and flow
back of excess deferred income taxes (EDITs) be revised to reflect the
approved depreciation rates?
TECO: 	Yes. (Chronister, Strickland)
OPC: 	Yes, the ITCs and EDITs should reflect OPC’s recommendation to retain the
current 35-year service life for solar assets and the 20-year service life for
batteries.
FL RISING/
LULAC: 	Yes, although the flowback of ITCs should be accelerated.
FIPUG: 	Yes.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 11: 	What annual accrual for dismantlement should be approved?
TECO: 	$17,442,392 effective January 1, 2025. This amount was calculated in accordance
with 	Rule 	25-6.04364, 	F.A.C., 	and 	properly 	considers 	escalation 	of 	costs,
environmental remediation costs, and contingencies. (Chronister, Kopp)

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 30
OPC: 	The annual accrual for dismantlement should exclude the cost and expense
escalations after the end of the test year for dismantlement which reduces revenue
requirement by $7.110 million. The dismantlement expense also should be
reduced by $2.614 million to remove the solar site restoration environmental
costs. Further, the dismantlement cost should be reduced by $0.955 million with
the continuation of the currently approved 35-year service life for solar as
recommend by OPC.
FL RISING/
LULAC: 	$10,325,056 (Kollen), adjusted to reflect removal of projects that should be
disallowed as per the other issues.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 12: 	What, 	if 	any, 	corrective 	dismantlement 	reserve 	measures 	should 	be
approved?
TECO: 	None. (Chronister)
OPC: 	All imbalances should be flowed back over the useful lives of the assets in this
case.
FL RISING/
LULAC: 	The Commission should limit the dismantlement expense to costs escalated only
through the test year and exclude all forecast growth in the dismantlement cost
and expense beyond the end of the test year. (Kollen)
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 31
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
2025 RATE BASE
ISSUE 13: 	Has TECO made the appropriate adjustments to remove all non-utility
activities from Plant in Service, Accumulated Depreciation, and Working
Capital in the 2025 projected test year? What, if any, adjustments should be
made?
TECO: 	Yes. (Chronister)
OPC: 	No position.
FL RISING/
LULAC: 	No. Plant in Service, Accumulated Depreciation, and Working Capital should be
adjusted to reflect the removal of at least the following projects from TECO’s
proposed 	rate 	base: 	Future 	Environmental 	Compliance; 	Research 	and
Development; 	Customer 	Experience 	Enhancement; 	Information 	Technology
Capital; Grid Reliability and Resilience; Corporate Headquarters; South Tampa
Resilience; Bearss Operation Center; and Polk 1 Flexibility.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 32
STAFF: 	No position at this time.
ISSUE 14: 	Should TECO’s proposed Future Environmental Compliance Project be
included in the 2025 projected test year? What, if any, adjustments should be
made?
TECO: 	Yes. The company’s Future Environmental Compliance Project at Polk Power
Station involves a detailed geological feasibility assessment of carbon storage at
Polk Power Station. Since the future of environmental regulations for carbon is
uncertain, the project is a prudent step to protect the long-term viability of gas-
fired 	generation 	at 	Polk 	Power 	Station 	at 	a 	significantly 	reduced 	cost 	to
customers. The total cost of the project is estimated to be $126.5 million, of which
$98.4 million will be paid for by a grant from the U.S. Department of Energy,
leaving only $28.1 million to be paid by TECO and $18.2 million of which the
company proposes to be recovered through customer rates in this case. (Stryker)
OPC: 	No position.
FL RISING/
LULAC: 	No, TECO has not met its burden to show this project is in the customer interest
and is reasonable and prudent.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 15: 	Should TECO’s proposed Research and Development Projects be included in
the 2025 projected test year? What, if any, adjustments should be made?
TECO: 	Yes. The company is exploring a long duration energy storage project and a
microgrid 	project, 	both 	of 	which 	will 	likely 	be 	used 	in 	the 	future. 	The

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 33
approximately $7.1 million of costs associated with these projects are prudent
because they will help the company better understand their possibilities and
limitations before it is necessary to implement them on a larger scale; therefore,
they should be included in test year rate base. (Stryker)
OPC: 	No, all costs should be excluded.
FL RISING/
LULAC: 	No, TECO has not met its burden to show that these projects are in the customer
interest and are reasonable and prudent.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 16: 	Should TECO’s proposed Customer Experience Enhancement Projects be
included in the 2025 projected test year? What, if any, adjustments should be
made?
TECO: 	Yes. The company’s proposed Customer Digitization, Operational Efficiency, and
Other Customer Programs are prudent and should be included in test year rate
base. They will improve customer access to services, information, and support;
allow the company to proactively present energy management solutions to
customers; and give customers more choice and flexibility in how they use
electric services. (Sparkman)
OPC: 	No, all costs should be excluded.
FL RISING/
LULAC: 	No, TECO has not met its burden to show that these projects are in the customer
interest and are reasonable and prudent.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 34
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 17: 	Should 	TECO’s 	proposed 	Information 	Technology 	Capital 	Projects 	be
included in the 2025 projected test year? What, if any, adjustments should be
made?
TECO: 	Yes. The company’s proposed expenditures for IT capital projects are prudent and
should be included in test year rate base. They will help create a modern, cloud-
based IT Service platform, replace/upgrade end of life data center hardware and
software, enhance cybersecurity, comply with NERC/CIP requirements, maintain
the company’s Enterprise Resource Planning and Customer Systems platform,
and improve other IT applications. (Heck)
OPC: 	No, all costs should be excluded.
FL RISING/
LULAC: 	No, TECO has not met its burden to show that these projects are in the customer
interest and are reasonable and prudent.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 35
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 18: 	Should TECO’s proposed Solar Projects be included in the 2025 projected
test year? What, if any, adjustments should be made?
TECO: 	Yes. The company’s 488.7 MW of Future Solar Projects are prudent and should
be included in test year rate base. The projects will reduce customer exposure to
volatile fuel prices, provide fuel diversity, and be built at the lowest reasonable
cost. They are cost-effective additions to the company’s generating fleet that will
moderate fuel costs to customers. The company’s cost-effectiveness analyses for
Future 	Solar 	are 	based 	on 	a 	reasonable 	fuel 	forecast, 	include 	reasonable
sensitivities, and show that the proposed solar additions will benefit customers.
FIPUG’s proposed conditions are not reasonable and should not be imposed by
the Commission. (Stryker, Aponte, Heisey)
OPC: 	OPC takes no position at this time on the prudence or cost-effectiveness or need
of the Solar Projects, but to the extent they are included in rates, the depreciable
lives should be increased from 30 to 35 years to maintain the current 35-year
service lives. OPC is still conducting discovery and certain other specific
adjustments may be required.
FL RISING/
LULAC: 	Yes, as long as TECO can show the projects are cost effective. Any costs
associated with these projects that TECO cannot demonstrate are prudent and
reasonable should be removed from rate base thus adjusting rate base downward.
FIPUG: 	No. TECO has not demonstrated that the proposed Solar Projects are cost
effective. Further, TECO’s cost-effectiveness analysis used inflated natural gas
prices and assumed a value for carbon emissions, despite the fact that a tax on
fossil fuel emissions has never been enacted at the state or federal level and there
is no pending legislation to do so. Further, accounting for reduced emissions
while also recognizing production tax credits effectively disadvantages fossil fuel
generation.
In the event that the Commission approves the Solar Projects, it should impose
various consumer protections, including a $1,609/kW cost cap, ensure that TECO
credits at least 100% of the PTCs projected by TECO in its cost-effectiveness
analysis (regardless of actual performance), and establish a minimum 26% annual
operating capacity factor to ensure that customers receive the projected benefits as
suggested by FIPUG witness Ly.
FEA: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 36
SIERRA
CLUB: 	Sierra Club supports the inclusion of TECO’s proposed Solar Projects in the 2025
projected test year.
FRF: 	The FRF supports the addition of solar generating resources into Florida’s power
supply grid, provided that such resources satisfy normal standards of cost-
effectiveness, and reasonableness and prudence of capital and operating costs.
FUEL
RETAILERS: No position.
WALMART: In accordance with Walmart's significant and company-wide renewable energy
goals set forth in the direct testimony of Steve W. Chriss in Docket No.
20240014-EG, Walmart supports solar and other renewable energy projects to the
extent those projects are prudent, cost-effective, and are relevant to Walmart's
renewable energy goals.
STAFF: 	No position at this time.
ISSUE 19: 	Should 	TECO’s 	proposed 	Grid 	Reliability 	and 	Resilience 	Projects 	be
included in the 2025 projected test year? What, if any, adjustments should be
made?
TECO: 	Yes. The proposed GRR Projects are prudent and should be included in test year
rate base. Adding a dedicated grid communication network, intelligent field
devices, and associated back-office control systems will enhance reliability by
reducing the frequency, duration, and impact of outages; improve operational
performance by enabling “self-healing” features to mitigate adverse grid events;
provide more and better data for billing and planning purposes; and facilitate the
addition of more customer-owned, distributed generation on the company’s
system. (Lukcic, Whitworth)
OPC: 	No.
FL RISING/
LULAC: 	No, TECO has not met its burden to show that these projects are in the customer
interest and are reasonable and prudent. (Rábago)
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 37
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 20: 	Should TECO’s proposed Energy Storage projects be included in the 2025
projected test year? What, if any, adjustments should be made?
TECO: 	Yes. The company’s 115 MW of Future Energy Storage Capacity projects are
prudent and should be included in test year rate base. They are cost-effective plant
additions needed to maintain the company’s required winter capacity reserve
margin and to avoid the costs of certain transmission upgrades. (Stryker, Aponte)
OPC: 	OPC takes no position at this time on the prudence or cost-effectiveness or need
of the Energy Storage projects, but to the extent they are included in rates, the
depreciable lives should be increased from 10 to 20 years. OPC is still conducting
discovery and certain other specific adjustments may be required.
FL RISING/
LULAC: 	Yes, as long as TECO can show the projects are cost effective. Any costs
associated with these projects that TECO cannot demonstrate are prudent and
reasonable should be removed from rate base thus adjusting rate base downward.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	Sierra Club supports the inclusion of TECO’s proposed Energy Storage Projects
in the 2025 projected test year.
FRF: 	FRF supports the addition of battery energy storage systems into Florida’s power
supply grid, provided that such resources satisfy normal standards of cost-
effectiveness, and reasonableness and prudence of capital and operating costs.
FRF agrees with OPC that the appropriate depreciation life for battery energy
storage systems is 20 years.
FUEL
RETAILERS: Agrees with OPC.

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 38
WALMART: In accordance with Walmart's significant and company-wide renewable energy
goals set forth in the direct testimony of Steve W. Chriss in Docket No.
20240014-EG, Walmart supports solar and other renewable energy projects to the
extent those projects are prudent, cost-effective and are relevant to Walmart's
renewable energy goals.
STAFF: 	No position at this time.
ISSUE 21: 	Should TECO’s proposed Corporate Headquarters project be included in
the 2025 projected test year? What, if any, adjustments should be made?
TECO: 	Yes. The company’s new corporate headquarters project is supported by a
detailed analysis of the costs and benefits of alternative space options, is prudent,
and should be included in test year rate base. The company is moving from its
current location in downtown Tampa (“TECO Plaza”) to the mid-town Tampa
area because its current lease is expiring and the net present value revenue
requirement of moving to the new building was about the same as other options.
The new building location is not subject to flooding, has better parking, is safer
for employees and the public, and has space to grow that is not available in TECO
Plaza. (Aldazabal)
OPC: 	No position.
FL RISING/
LULAC: 	No, TECO has not met its burden to show that this project is in the customer
interest and is reasonable and prudent.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 39
ISSUE 22: 	Should TECO’s proposed South Tampa Resilience project be included in the
2025 projected test year? What, if any, adjustments should be made?
TECO: 	Yes. The South Tampa Resilience Project (STRP) consists of four reciprocating
internal combustion engines located on land leased at no cost to TECO from
MacDill Air Force Base and is prudent. The STRP will be a system asset that
serves all customers during normal operations, provides quick start capability to
enhance the flexibility and resilience of the company’s generating fleet, supports
the company’s winter reserve margin, is cost-effective, and is expected to
generate fuel savings of $137.9 million for the company’s general body of
ratepayers. The generators will only be isolated to serve MacDill during rare
national emergencies. (Aldazabal, Aponte)
OPC: 	No. The proposal will receive no direct funding support from the U.S. Department
of Defense or federal government despite being sited at McDill Air Force Base
and only has a 33-year cost-free lease for land.
FL RISING/
LULAC: 	No, TECO has not met its burden to show that this project is in the customer
interest and is reasonable and prudent.
FIPUG: 	No, not at this time as the project has materially changed.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 23: 	Should TECO’s proposed Bearss Operations Center project be included in
the 2025 projected test year? What, if any, adjustments should be made?
TECO: 	Yes. The Bearss Operations Center is a modern, storm hardened secure operations
center that will replace the company’s current energy control center (ECC) and IT
functions at the Ybor Data Center, is prudent, and should be included in test year
rate base. The new facility is designed to withstand major tropical storms, protect

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 40
the company’s cyber assets, and operate utility command and control functions
for the next 40 years. The ECC and Ybor Data Center are not storm hardened,
were not built to current standards, are located in flood-prone areas and need to be
replaced to promote reliability and resilience. (Aldazabal)
OPC: 	No position.
FL RISING/
LULAC: 	No, TECO has not met its burden to show that this project is in the customer
interest and is reasonable and prudent.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 24: 	Should TECO’s proposed Polk 1 Flexibility project be included in the 2025
projected test year? What, if any, adjustments should be made?
TECO: 	Yes. The Polk 1 Flexibility Project will convert the existing Polk Unit 1 combined
cycle unit into a highly efficient simple cycle unit, is prudent, and should be
included in test year rate base. The project will increase the unit’s flexibility,
allow faster start times, increase ramp rates, and reduce turndowns; and will
generate an estimated $40 million of fuel cost benefits and a CPVRR benefit of
$166.9 million. Sierra Club’s proposal to early retire the IGCC components at
Polk Unit 1 ignores the importance of the IGCC for present and future customers
and should be rejected. (Aldazabal, Aponte)
OPC: 	No position.
FL RISING/
LULAC: 	No, TECO has not met its burden to show that this project is in the customer
interest and is reasonable and prudent.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 41
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	Sierra Club opposes the inclusion of the costs of the Polk 1 Flexibility project in
the 2025 projected test year. The Commission should disallow recovery unless
TECO provides an analysis demonstrating the CT conversion is lower cost than
retiring the unit and replacing it with alternative resources by 2030 or another
date. If the Commission approves costs associated with converting Polk Unit 1 to
a CT, it should still require that TECO immediately retire its IG, ST, and HRSG
components.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 25: 	What amount of Plant in Service for the 2025 projected test year should be
approved?
TECO: 	The Commission should approve Jurisdictional Adjusted Plant in Service totaling
$13.4 billion as shown on MFR Schedule B-1, adjusted by the company’s July
and August Filings. OPC’s proposed adjustment for spare transformers should be
rejected. (Whitworth, Chronister)
OPC: 	This is largely a fall out issue, but TECO has the burden of proof to demonstrate
the reasonableness or prudence of all costs to be included in rate base. OPC is still
conducting discovery and certain other specific adjustments to Plant in Service
may be required. The Distribution Feeder Hardening costs should be disallowed
and considered in the SPP. This would require a reduction of $0.356 million in
revenue requirement. Plant in Service for the 2025 projected test year should
reflect OPC’s recommended adjustments.
FL RISING/
LULAC: 	$12,774,719.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 42
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 26: 	What amount of Accumulated Depreciation for the 2025 projected test year
should be approved?
TECO: 	The 	Commission 	should 	approve 	Jurisdictional 	Adjusted 	Accumulated
Depreciation and Amortization totaling $4.0 billion as shown on MFR Schedule
B-1, adjusted for the company’s July and August Filings. (Chronister)
OPC: 	Accumulated depreciation should be adjusted to reflect the current 35-year service
life of the solar plants and adjusting the Battery Storage lives from 10 to 20 years.
This requires an adjustment to reduce Accumulated Depreciation of $0.440
million and $0.275 million respectively.
FL RISING/
LULAC: 	TECO’s requested accumulated depreciation amount should be adjusted to reflect
removal of the projects that should be disallowed.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 43
ISSUE 27: 	What amount of Construction Work in Progress for the 2025 projected test
year should be approved?
TECO: 	The Commission should approve Jurisdictional Adjusted Construction Work in
Progress (CWIP) totaling $230.2 million as shown on MFR Schedule B-1.
(Chronister)
OPC: 	CWIP should be adjusted for any disallowance of the GRR Projects.
FL RISING/
LULAC: 	$0.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 28: 	What amount of level of Property Held for Future Use for the 2025 projected
test year should be approved?
TECO: 	The Commission should approve Jurisdictional Adjusted Property Held for Future
Use totaling $68.0 million as shown on MFR Schedule B-1. (Chronister)
OPC: 	No position.
FL RISING/
LULAC: 	$0.
FIPUG: 	No position.
FEA: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 44
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 29: 	What amount of unfunded Other Post-retirement Employee Benefit (OPEB)
liability and any associated expense should be included in rate base?
TECO: 	The amount of unfunded OPEB liability that should be included in rate base is the
13-month average of $70,740,641. This equals the credit amount in account
228.3232, FAS 106 Liability - Retired - Non-Current. The sum of the balances in
accounts 228.3231 and 242.0131 (FAS 158 credits), when added to debit balances
in account 182.3200 (Regulatory Asset) offsetting the FAS 158 balances, equal
zero. There are no associated expenses included in rate base. (Chronister)
OPC: 	Rate base should be adjusted for any under capitalization of OPEB expense.
FL RISING/
LULAC: 	$0, as it should not be included in rate base where a return on equity is earned.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 45
ISSUE 30: 	What level of TECO's fuel inventories should be approved?
TECO: 	The Commission should approve fuel inventory for the projected 2025 test year
totaling $36.6 million as shown on MFR Schedule B-17. Florida Rising’s and
LULAC’s positions that the company should not be using coal or be allowed to
recover fuel inventory ignores the important reliability and other benefits of coal
fired 	generation 	at 	Big 	Bend 	Unit 	4 	and 	should 	be 	rejected. 	(Chronister,
Aldazabal)
OPC: 	No position.
FL RISING/
LULAC: 	$0. TECO should not be using coal or other fuels that require inventory.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 31: 	What amount of Working Capital for the 2025 projected test year should be
approved?
TECO: 	The Commission should approve a Jurisdictional Working Capital Allowance
totaling 	$86.7 	million 	as 	shown 	on 	MFR 	Schedule 	B-1. 	OPC’s 	proposed
adjustment to remove four MVA transformers from inventory should be rejected,
because those transformers are needed for reliability and resilience. (Chronister,
Whitworth)
OPC: 	The Commission should remove four MVA transformers from inventory as they
are excessive. This requires an adjustment to Inventories of $0.362 million. OPC
is still conducting discovery and certain other specific adjustments to rate base
may be required.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 46
FL RISING/
LULAC: 	The Working Capital should be adjusted to remove the Unamortized Rate Case
Expense and should be adjusted to reflect other adjustments that have been made.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 32: 	What amount of rate base for the 2025 projected test year should be
approved?
TECO: 	The Commission should approve projected 13-month average rate base for 2025
of $9.8 billion as shown on MFR Schedule B-1, less $5,918,042 per the
company’s July and August Filings for a total of $9,792,232,298. (Chronister)
OPC: 	This is largely a fall out issue, but TECO has the burden of proof to demonstrate
the reasonableness or prudence of all costs to be included in rate base. OPC is still
conducting discovery and certain other specific adjustments to rate base may be
required. Rate base for the 2025 projected test year should reflect OPC’s
recommended adjustments and should be no more than $9,800.670 million.
FL RISING/
LULAC: 	Approximately $8 billion. The rate base should be reduced to reflect the removal
of the following projects from 2025 rate base: Future Environmental Compliance;
Research and Development; Customer Experience Enhancement; Information
Technology Capital; Grid Reliability and Resilience; Corporate Headquarters;
South Tampa Resilience; Bearss Operation Center; and Polk 1 Flexibility.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 47
SIERRA
CLUB: 	TECO’s customers experience higher energy burdens than the national average,
and 	their 	electricity 	rates 	can 	be 	reduced 	by 	removing 	spending 	on 	coal
combustion at Polk Unit 1 and Big Bend Unit 4 from the rate base. Moreover, the
Polk 1 Flexibility project should not be included in the rate base for the 2025
projected test year unless TECO can provide an analysis showing that its cost is
lower than the costs of retiring Polk Unit 1 and replacing its capacity with
alternative sources of clean generation. Last, Sierra Club supports corporate cost,
ROE, and reserve margin oversight arguments put forth by intervenors that would
reduce the 2025 test year rate base and provide relief for energy burdened
customers.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No new investments in EV charging associated with new projects should be
included pursuant to the requirements of HB 1645, Section 6 (to be codified at
366.94, F.S.) (Chapter 2024-186, Laws of Florida).
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
2025 COST OF CAPITAL
ISSUE 33: 	What 	amount 	of 	accumulated 	deferred 	taxes 	should 	be 	approved 	for
inclusion in the capital structure for the 2025 projected test year?
TECO: 	The Commission should approve Jurisdictional Adjusted Accumulated Deferred
Income Taxes of $980.9 million as shown on MFR Schedule D-1a. (Chronister,
Strickland)
OPC: 	The amount of accumulated deferred taxes that should be included in the capital
structure for the 2025 projected test year is $980.855 million.
FL RISING/
LULAC: 	Adopts the position of OPC.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 48
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 34: 	What amount and cost rate of the unamortized investment tax credits should
be approved for inclusion in the capital structure for the 2025 projected test
year?
TECO: 	The Commission should approve Jurisdictional Adjusted Tax Credits in the
amount of $211.7 million and a cost rate of 8.26 percent as shown on MFR
Schedule D-1a. The company acknowledges the fact that the unamortized ITC
would have been adjusted as result of the July and August Filings. However, this
change would not materially impact the overall weighted average cost of capital
rate and thus the ITC cost rate. (Chronister, Strickland)
OPC: 	The amount and cost rate of the unamortized investment tax credits that should be
included in the capital structure for the 2025 projected test year is $178.098
million at a cost rate of 7.18%.
FL RISING/
LULAC: 	The ITCs should be flowed back to customers over a ten-year period. The
appropriate cost rate is zero, as TECO already receives a return on investment for
the capital expenditures associated with the battery assets.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 49
ISSUE 35: 	What amount and cost rate for customer deposits should be approved for
inclusion in the capital structure for the 2025 projected test year?
TECO: 	The Commission should approve Jurisdictional Adjusted Customer Deposits of
$99.2 million and a cost rate of 2.41% as shown on MFR Schedule D-1a.
(Chronister)
OPC: 	The amount and cost rate for customer deposits that should be included in the
capital structure for the 2025 projected test year is $99.195 million at a cost rate
of 2.41%.
FL RISING/
LULAC: 	$99.195 million.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 36: 	What amount and cost rate for short-term debt should be approved for
inclusion in the capital structure for the 2025 projected test year?
TECO: 	The Commission should approve Jurisdictional Adjusted Short-Term Debt of
$376.6 million and a cost rate of 3.90% as shown on MFR Schedule D-1a.
(Chronister)
OPC: 	The appropriate amount of short-term debt is $376.625 million with a cost rate of
3.90%.
FL RISING/
LULAC: 	The Commission should approve a short-term debt amount adjusted downwards
to account for a reduced rate base and adjusted upwards for the adjusted 50-50
equity-to-debt ratio. A cost rate of 3.90% should be approved.

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PAGE 50
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 37: 	What amount and cost rate for long-term debt should be approved for
inclusion in the capital structure for the 2025 projected test year?
TECO: 	The Commission should approve Jurisdictional Adjusted Long-Term Debt of
$3.536 billion and a cost rate of 4.53% as shown on MFR Schedule D-1a.
(Chronister)
OPC: 	The appropriate amount of long-term debt is $3,536.333 million with a cost rate
of 4.53%.
FL RISING/
LULAC: 	The Commission should approve a long-term debt amount adjusted downwards to
account for a reduced rate base and adjusted upwards to account for a 50-50
equity-to-debt ratio. A cost rate of 4.53% should be approved.
FIPUG: 	Adopts the position of OPC.
FEA: 	The appropriate long-term debt balance that should be approved for inclusion in
the capital structure should be $3,706,461.830, or 37.83%, for the 2025 projected
test year.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.

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PAGE 51
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 38: 	What equity ratio should be approved for use in the capital structure for
ratemaking purposes for the 2025 projected test year?
TECO: 	The Commission should approve the company’s proposed 54% equity ratio
(investor sources). This proposed equity ratio is reasonable and prudent, will
allow the company to maintain its financial integrity, attract capital on reasonable
terms and conditions, and ensure uninterrupted access to capital markets to
finance infrastructure improvements and manage unforeseen events. The lower
equity ratio advocated by FEA, Florida Rising, and LULAC are too low, would be
perceived by credit-rating agencies as credit-negative, and should be rejected.
(Chronister)
OPC: 	TECO’s requested equity ratio of 54% should only be accepted if the ROE is
accordingly established taking into consideration the high level of the equity ratio;
otherwise the proposed equity ratio is excessive.
FL RISING/
LULAC: 	43.41% to reflect a 50-50 equity-to-debt ratio.
FIPUG: 	Adopts the position of OPC.
FEA: 	The appropriate equity ratio that should be approved for use in the capital
structure for ratemaking purposes for the 2025 projected test year is 45.15%, or
52.0% on an investor-supplied basis.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 52
ISSUE 39: 	What authorized return on equity (ROE) should be approved for use in
establishing TECO’s revenue requirement for the 2025 projected test year?
TECO: 	The Commission should approve a mid-point ROE of 11.5% with an allowed
range of earnings of plus or minus 100 basis points. The ROEs proposed by the
intervenors are too low, do not reflect a reasonable return, are not prudent, and
should be rejected. (D’Ascendis)
OPC: 	The Commission should approve a 9.50% ROE.
FL RISING/
LULAC: 	9.50%. (Rábago)
FIPUG: 	The authorized ROE should be no higher than the average ROE authorized by
state regulators in rate cases decided in 2023 and 2024 involving vertically
integrated electric utilities, 9.78%, as testified to by FIPUG witness Pollock.
FEA: 	The authorized ROE of 9.60% should be approved for use in establishing TECO’s
revenue requirement for the 2025 projected test year.
SIERRA
CLUB: 	No position.
FRF: 	9.50%.
FUEL
RETAILERS: No position.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 40: 	What capital structure and weighted average cost of capital should be
approved for use in establishing TECO’s revenue requirement for the 2025
projected test year?
TECO: 	The Commission should approve the Jurisdictional Capital Structure totaling
$9.798 billion and a weighted average cost of capital (WACC) of 7.37% as shown
on MFR Schedule D-1a and shown below:

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PAGE 53
The company acknowledges the fact that the capital structure should be reduced
by $5,918,042 as a result of the July Filing. However, this change would not
materially impact the weighted average cost of capital rate. (Chronister)
OPC: 	The Commission should approve a WACC and capital structure shown in the
testimony of OPC’s experts.
FL RISING/
LULAC: 	The Commission should approve a 50-50 equity-to-debt ratio. The weighted
average cost of capital should be adjusted to account for downward rate base
adjustments and the adjusted equity-to-debt ratio.
FIPUG: 	Adopts the position of OPC.
FEA: 	The capital structure and weighted average cost of capital that should be approve
is demonstrated in the chart below:
Jurisdictional
Capital 	Cost 	Weighted
Class of Capital 	Structure 	Ratio 	Rate 	Cost Rate
Long Term Debt 	3,706,462	$ 	37.83% 	4.53% 	1.71%
Short Term Debt 	376,625 	3.84% 	3.90% 	0.15%
Customer Deposits 	99,195 	1.01% 	2.41% 	0.02%
Preferred Stock 	- 	0.00% 	- 	0.00%
Common Equity 	4,423,344 	45.15% 	9.60% 	4.33%
Deferred Income Taxes 	980,855 	10.01% 	- 	0.00%
Tax Credits - Zero Cost 	- 	0.00% 	- 	0.00%
Tax Credits - Weighted Cos 	211,669 	2.16% 	7.14% 	0.15%
9,798,150	$ 	100.00% 	6.36%

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PAGE 54
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
2025 NET OPERATING INCOME (Is
ISSUE 41: 	Has TECO correctly calculated the revenues at current rates for the 2025
projected test year?
TECO: 	Yes. The correct amount of revenues from sales at current rates for the 2025
projected test year is $1.481 billion as shown on MFR Schedule C-1, page 1 of 3.
This amount was determined by applying the company’s current tariff rates to the
electricity sales reflected in its Customer, Demand, and Energy forecasts by
customer rate classes, is reasonable, and should be approved by the Commission.
OPC’s proposed base revenue adjustments for 2025, 2026, and 2027 rely on a
methodology that overlooks key facts, has severe shortcomings, and is inaccurate,
and therefore should be rejected. (Chronister, Cifuentes, Williams)
OPC: 	No. The Commission should reject TECO’s energy sales forecast because it bears
no resemblance to historic trends and is biased due to the introduction of a
number of subjective out-of-model adjustments. Over the past several years, the
company has consistently prepared sales forecasts that were lower than actuals.
The Commission should instead accept a conservative, modified version of
TECO’s forecast that removes subjective out-of-model adjustments. The removal
of out-of-model adjustments will increase TECO’s test year sales forecast
resulting in a 2025 sales projection of 20,635,457 MW-hours. This will result in
an increase of 2025 test year projected retail revenues by $12.3 million.
FL RISING/
LULAC: 	No.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 55
SIERRA
CLUB: 	No position.
FRF: 	No. TECO’s sales forecast is significantly understated. The Commission should
increase 2025 test year retail revenue by at least $12.3 million.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 42: 	What amount of Total Operating Revenues should be approved for the 2025
projected test year?
TECO: 	The correct amount of total operating revenues for the 2025 projected test year is
$1.518 billion as shown on MFR Schedule C-1, page 1 of 3. This amount reflects
the amount of revenue from sales in Issue No. 41 plus a reasonable estimate of
Other 	Operating 	Revenues 	for 	the 	2025 	test 	year. 	(Chronister, 	Cifuentes,
Williams)
OPC: 	This is a largely a fall out issue, but TECO has the burden of proof to demonstrate
the reasonableness of its forecast of test year revenues. OPC is still conducting
discovery and certain other specific adjustments to rate base may be required. The
Total Operating Revenues for the 2025 projected test year should reflect all of
OPC’s recommended adjustments, the adjustments for Issue 7 and should be no
more than $43.8 million.
FL RISING/
LULAC: 	Adopts the position of OPC.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 56
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 43: 	What amount of O&M expense associated with Polk Unit 1 has TECO
included in the 2025 projected test year? Should this amount be approved
and what, if any, adjustments should be made?
TECO: 	As noted in the company’s answer to Sierra Club’s First Set of Interrogatories No.
6, the company included $9,685,047 of Polk Unit 1 non-fuel O&M costs in the
2025 projected test year. Most of this amount is associated with the operation of
Polk Unit 1 on natural gas. Polk Unit 1 provides important fuel diversity,
reliability, and flexibility benefits to customers and could return to IGCC
operation within a year to help protect customers from high gas prices if the
forward curve for petcoke is favorable. The existing well system at Polk Station is
adequate and necessary to handle the wastewater from Polk 1 and 2. The
associated environmental costs are justified in light of the significant fuel
diversity, 	reliability, 	and 	flexibility 	benefits 	that 	Polk 	Unit 	1 	provides 	to
customers. For these reasons, Sierra Club’s recommendations to disallow the
O&M expenses associated with wastewater injection and the IGCC components at
Polk Unit 1 should be rejected and the company’s forecasted amount should be
approved. (Aldazabal, Stryker, Chronister)
OPC: 	No position at this time. OPC is still conducting discovery and certain other
specific adjustments may be required.
FL RISING/
LULAC: 	Adopts the position of Sierra Club.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	Sierra Club does not support the inclusion of any O&M expenses at Polk Unit 1
that cover the procurement or combustion of coal or petcoke. This includes the
O&M expenses of keeping Polk Unit 1’s IGCC equipment—including its IG, ST,
and HRSG technologies—in service.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 57
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 44: 	What amount of O&M expense associated with Big Bend Unit 4 has TECO
included in the 2025 projected test year? Should this amount be approved
and what, if any, adjustments should be made?
TECO: 	As noted in the company’s answer to Sierra Club’s First Set Interrogatory, No. 6,
the company included $12,472,909 in Big Bend Unit 4 non-fuel O&M costs in the
2025 projected test year. Big Bend Unit 4 provides important fuel diversity,
reliability, and flexibility benefits to customers. Although it does not frequently
run on coal, Big Bend 4 is available to run and has recently run on coal during
extreme winter weather, when gas prices spiked, and during pipeline alert periods
when gas deliveries to Florida were limited. The company has already achieved
compliance with the ELG rule through its deep injection well system and the
discharge of FGD and other storm and wastewater is now permitted through the
FDEP Underground Injection Control Program. The associated coal combustion
costs are justified in light of the significant fuel diversity, reliability, and
flexibility benefits that Big Bend Unit 4 provides to customers. For these reasons,
the Sierra Club’s recommendations to disallow the O&M expenses associated
with coal combustion operation of the unit should be rejected and the company’s
forecasted amount should be approved. (Aldazabal, Stryker, Chronister)
OPC: 	No position at this time. OPC is still conducting discovery and certain other
specific adjustments may be required.
FL RISING/
LULAC: 	Adopts the position of Sierra Club.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	Sierra Club urges the Commission to reject the inclusion of any and all O&M
expenses associated with coal combustion at Big Bend Unit 4 for the 2025
projected test year, including fuel costs, maintenance costs, operating costs, and
environmental compliance costs, among others.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 58
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 45: 	What amount of generation O&M expense should be approved for the 2025
projected test year?
TECO: 	The Commission should approve Jurisdictional Adjusted Production (generation)
O&M Expense for the 2025 test year of 	$125.0 million, less $285,000 per the
company’s July and August Filings for a total of $124.7 million. The company
has 	not 	“bunched” 	planned 	major 	outages 	in 	the 	test 	year 	and 	OPC’s
“normalization” proposal improperly focuses on historical costs which are not
indicative of the costs expected to be incurred in the test year. If the Commission
adjusts planned outage expenses for the test year, it should allow the company to
defer costs above an annual allowed amount for recovery in future years.
(Aldazabal, Chronister)
OPC: 	The 	Commission 	should 	“normalize” 	the 	planned 	generation 	maintenance
expense in the test year by averaging the actual expense incurred in the years
2019 through 2023 and the budget and forecast expenses in the years 2024 and
2025. This results in an adjustment to retail revenue requirement of $12.430
million.
FL RISING/
LULAC: 	The generation O&M expense for the 2025 test year should be normalized by
averaging the actual expense incurred from 2019 through 2023 and the budget and
forecast expenses in for 2024 and 2025. This results in a $12.392 million
reduction 	in 	2025 	planned 	generation 	maintenance 	expense 	from 	TECO’s
proposed expense. (Kollen). The generation O&M expense should also be
reduced by about $2.6 million to account for the removal of the following projects
from rate base: South Tampa Resilience; Polk 1 Flexibility.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	Sierra Club has no position on this issue, except that generation O&M expenses
approved for Polk Unit 1 and Big Bend Unit 4 should be modified to reflect no
coal or petcoke-related costs.
FRF: 	Agrees with OPC that the Commission should normalize TECO’s planned
generation maintenance expense in the 2025 test year and reduce TECO’s 2025
revenue requirement by $12.430 million.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 59
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 46: 	What amount of transmission O&M expense should be approved for the
2025 projected test year?
TECO: 	The Commission should approve Jurisdictional Adjusted Transmission O&M
Expense for the 2025 test year of 	$11,491,000. This amount is below the
Commission’s 	benchmark 	amount, 	is 	reasonable, 	and 	should 	be 	approved.
(Whitworth, Chronister)
OPC: 	No position.
FL RISING/
LULAC: 	TECO’s requested transmission O&M for 2025 should be reduced to reflect
disallowance of GRR Projects.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 47: 	What amount of distribution O&M expense should be approved for the 2025
projected test year?
TECO: 	The Commission should approve Jurisdictional Adjusted Distribution O&M
Expense for the 2025 test year of 	$54,243,000. This amount is below the

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 60
Commission’s 	benchmark 	amount, 	is 	reasonable, 	and 	should 	be 	approved.
(Whitworth, Chronister)
OPC: 	No position.
FL RISING/
LULAC: 	TECO’s requested transmission O&M for 2025 should be reduced to reflect
disallowance of GRR Projects.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 48: 	Has TECO made the appropriate test year adjustments to remove fuel
revenues 	and 	fuel 	expenses 	recoverable 	through 	the 	Fuel 	Adjustment
Clause?
TECO: 	Yes. The appropriate adjustments are shown on MFR Schedules C-2 and C-3 and
should be approved. (Chronister)
OPC: 	No position.
FL RISING/
LULAC: 	No, it remains TECO’s burden to show it has appropriately removed fuel
revenues and fuel expenses.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 61
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 49: 	Has 	TECO 	made 	the 	appropriate 	test 	year 	adjustments 	to 	remove
conservation revenues and conservation expenses recoverable through the
Conservation Cost Recovery Clause?
TECO: 	Yes. The appropriate adjustments are shown on MFR Schedules C-2 and C-3 and
should be approved. (Chronister)
OPC: 	No position.
FL RISING/
LULAC: 	No, it remains TECO’s burden to show it has appropriately removed conservation
revenues and conservation expenses.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 62
ISSUE 50: 	Has TECO made the appropriate test year adjustments to remove capacity
revenues and capacity expenses recoverable through the Capacity Cost
Recovery Clause?
TECO: 	Yes. The appropriate adjustments are shown on MFR Schedules C-2 and C-3 and
should be approved. (Chronister)
OPC: 	No position.
FL RISING/
LULAC: 	No, it remains TECO’s burden to show it has appropriately removed capacity
revenues and capacity expenses recoverable through the Capacity Cost Recovery
Clause.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 51: 	Has 	TECO 	made 	the 	appropriate 	test 	year 	adjustments 	to 	remove
environmental revenues and environmental expenses recoverable through
the Environmental Cost Recovery Clause?
TECO: 	Yes. The appropriate adjustments are shown on MFR Schedules C-2 and C-3 and
should be approved. (Chronister)
OPC: 	No position.
FL RISING/
LULAC: 	No, 	it 	remains 	TECO’s 	burden 	to 	show 	it 	has 	appropriately 	removed
environmental revenues and environmental expenses recoverable through the
Environmental Cost Recovery Clause.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 63
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 52: 	Has TECO made the appropriate test year adjustments to remove all storm
hardening revenues and expenses recoverable through the Storm Protection
Plan Cost Recovery Clause?
TECO: 	Yes. The appropriate adjustments are shown on MFR Schedules C-2 and C-3 and
should be approved. (Chronister)
OPC: 	No. The Distribution Feeder Hardening costs should be disallowed and included
in the SPP. This would require a reduction of $0.356 million in retail revenue
requirement.
FL RISING/
LULAC: 	No. TECO has not removed all the costs for feeder hardening activities or lateral
undergrounding from its rate base. (Mara)
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 64
STAFF: 	No position at this time.
ISSUE 53: 	What amount of salaries and benefits, including incentive compensation,
should be approved for the 2025 projected test year?
TECO: 	The 	Commission 	should 	approve 	salaries 	and 	benefits 	expense, 	including
incentive compensation, for the 2025 test year in the amount of $376.9 million as
shown on MFR Schedule C-35. The Commission should reject OPC’s, Florida
Rising’s, and LULAC’s proposals to disallow recovery of expenses associated
with the company’s STIP, LTIP, and SERP, because these plans are: (1)
reasonable and prudent parts of the company’s total compensation expense, which
is targeted at the market-median, 	(2) enable the company to compete for
employee talent, and (3) provide reasonable and balanced incentives that benefit
customers. (Cacciatore, Chronister)
OPC: 	The Commission should disallow the LTIP incentive compensation expense tied
to Emera’s financial performance. The effect of this adjustment is a reduction of
$7.170 million in the retail revenue requirement. The Commission should also
disallow the SERP expense as it is considered to be a non-qualified plan which
the Company has discontinued. The effect of this adjustment is a reduction of
$0.107 million in the retail revenue requirement.
FL RISING/
LULAC: 	The amount of salaries and benefits should be reduced to reflect shareholder
payment of 50% of incentive compensation for 2025. This results in a $17.13
million 	reduction 	from 	TECO’s 	$376.9 	million 	proposed 	total. 	(Rábago).
Additionally, TECO’s proposed total should be reduced by $0.107 million to
remove the SERP expense (Kollen).
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 65
ISSUE 54: 	Does TECO’s pension and OPEB expense properly reflect capitalization
credits in the 2025 projected test year? If not, what adjustments, if any,
should be made?
TECO: 	Yes. 	The 	Commission 	should 	approve 	the 	company’s 	pension 	and 	OPEB
expenses for the test year as shown on MFR Schedule C-17. A portion of active
employee pension and OPEB expenses are capitalized through the company’s
fringe rate like other labor costs and reflected as a credit to Account 926. OPC’s
proposed adjustment to reduce O&M expense is inappropriate because the amount
of pension and OPEB costs to be capitalized has already been deducted from the
company’s forecasted benefits expense. The company’s 2025 test year reflects
capitalization of $424,000 and $697,000 of pension and OPEB costs, respectively.
(Chronister)
OPC: 	The Commission should reduce the pension and OPEB cost to reflect the credit
for the portions of the costs that will be capitalized. The effect is a reduction of
$0.489 million in the revenue requirement for the reduction in pension expense
and a reduction of $0.806 million in the revenue requirement for the reduction in
OPEB expense to reduce the requested amounts for the capitalized portions.
FL RISING/
LULAC: 	No. The Commission should reduce the pension and OPEB expense to reflect
capitalization credits, resulting in a reduction of $0.489 million in revenue
requirement in pension expense and a reduction of $0.806 million in the revenue
requirement for the reduction in OPEB expense. (Kollen)
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 66
ISSUE 55: 	What cost allocation methodologies and what amount of allocated costs and
charges with TECO’s affiliated companies should be approved for the 2025
projected test year and what, if any, other measures should be taken?
TECO: 	The company accounts for affiliated transactions in accordance with Rule 25-
6.1351, F.A.C. Most of the company’s affiliate transactions are reflected in the
Administrative and General functional expense group, which is $56 million below
the Commission’s benchmark. The Commission should approve ($28,650,000) of
allocated costs and charges from TECO to its affiliates for the 2025 projected test
year as reflected in OPC's 5th Set of Interrogatories No. 98. This amount is
designated with an "S" for Sale, "A&G Expense Credit" as its general ledger
treatment, is included on line No. 62, and reduces test year O&M expenses. The
Commission 	should 	approve 	the 	total 	of 	$15,653,000 	of 	allocated 	costs
($11,075,000) and direct charges ($4,578,000) incurred by TECO from affiliated
companies for the 2025 projected test year as reflected in OPC's 5th Set
Interrogatory No. 98. This amount is designated with a "P" for Purchase and
included on line No. 60. These “S” and “P” amounts were developed using the
cost allocation methodologies described in the pre-filed direct testimony of
Chronister II, which have been in place for many years, are fair and reasonable,
and should be approved. The Commission should reject OPC’s two proposed
affiliate transaction adjustments because they subtract amounts not included in the
company’s test year budget, are based on incorrect information and assumptions,
rely on historical not test year data, and are founded on inappropriate modification
of 	allocation 	factors. 	The 	company’s 	operations 	as 	a 	so-called 	“de 	facto
centralized service provider” complies with Rule 25-6.1351, F.A.C. OPC’s
recommendations 	for 	other 	actions 	and 	future 	regulation 	should 	only 	be
considered in a rulemaking or other proceeding applicable to all public utilities
operating under the Commission’s jurisdiction and are either overly burdensome
or redundant. (Chronister)
OPC: 	The Commission should reduce the Corporate Support Allocations from Emera to
TECO by $0.858 million related to expenses of a dissolved affiliate that was
proposed to be transferred to TECO. The Commission should also reduce the
shared service allocation from Tampa Electric to TECO by $5.457 million to
reflect Witness Ostrander’s revising of the allocation factors for various shared
services and the disallowing of one half of significant unsupported corporate
overhead. In addition, the Commission should require TECO to change its MMM
allocation factor by substituting a Headcount allocation factor in place of the Net
Income allocation factor. The Commission should consider requiring TECO to
discontinue its central service provider responsibilities or in the alternative require
TECO to implement the nine steps outlined in Witness Ostrander’s testimony.
The Commission should require TECO to discontinue its role as the CSP or
require the nine measures outlined more fully in OPC witness Ostrander’s
testimony. These are summarized as follows: (1) implement a plan for achieving

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 67
recommendations; (2) identify costs saving as CSP and flow back to customers;
(3) document and explain when affiliate takes back share service in-house; (4)
change accounting to track and audit affiliate transactions easily; (5) reconcile
accounting in (4) to FERC Form 1; (6) have external audit of CSP role; (7)
monthly invoices for CSP services; (8) Emera and TECO should have written
internal controls; and (9) Emera should perform an internal audit of TECO as
CSP.
FL RISING/
LULAC: 	A Revised MMM should be used to allocate affiliate costs and charges using the
following inputs: (1) Operating Assets factor; (2) Revenue factor; and (3)
Headcount factor. The Revised MMM Rate for TECO should be 67.62%, a 4.96%
reduction from TECO’s proposed rate. In total, TECO’s Shared Service expense
should be reduced by $5.50 million from TECO’s 2025 Budget amounts.
(Ostrander)
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 56: 	What amount of Directors and Officers Liability Insurance and Board of
Director expense for the 2025 projected test year should be approved?
TECO: 	The Commission should approve $303,000 of D&O Liability Insurance expense
and $752,000 of Board of Director expense for the 2025 projected test year. The
Commission 	should 	reject 	OPC’s 	proposed 	50% 	adjustment 	because 	D&O
Liability 	Insurance 	and 	Board 	of 	Directors 	expenses 	are 	an 	ordinary 	and
necessary cost of doing business, is necessary to recruit and retain qualified
directors and officers, and the amounts are reasonable. (Chronister)

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PAGE 68
OPC: 	The Commission should require an equal sharing of the TECO’s D&O insurance
premium and Board of Directors expenses between customers and shareholders to
allocate these expenses equally based on an assumption the expenses benefit both
ratepayers and shareholders, as recognized in previous Commission orders. The
effects are a 50% reduction in D&O insurance expense or $0.151 million in
revenue requirement and a 50% reduction of Board of Directors expenses or
$0.376 million in revenue requirement.
FL RISING/
LULAC: 	The 	D&O 	Liability 	Insurance 	expense 	should 	be 	shared 	equally 	between
customers and shareholders, resulting in a $0.151 million reduction in the D&O
Liability Insurance expense. (Kollen)
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 57: 	What amount of Economic Development expense for the 2025 projected test
year should be approved?
TECO: 	The Commission should approve economic development expenses for the 2025
projected test year of $446,502. This amount was calculated in accordance with
Rule 25-6.0426, F.A.C., and is reasonable. (Chronister)
OPC: 	No position.
FL RISING/
LULAC: 	$0.
FIPUG: 	No position.
FEA: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 69
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 58: 	What amount and amortization period for TECO's rate case expense for the
2025 projected test year should be approved?
TECO: 	The Commission should approve total rate case expense of $2,048,000, an
amortization period of three years, and $683,000 of rate case expense for the
projected 2025 test year as shown on MFR Schedule C-10. (Chronister)
OPC: 	Rate case expense should be amortized over at least a three-year period.
FL RISING/
LULAC: 	$0, as this rate case was not for customers.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 70
ISSUE 59: 	What amount of O&M Expense for the 2025 projected test year should be
approved?
TECO: 	The Commission should approve Jurisdictional Adjusted Other O&M Expenses
of $391.8 million for the 2025 projected test year as shown on MFR Schedule C-
1, less $285,000 per the company’s July and August Filings for a total of $391.5
million. This amount is well below the Commission’s O&M Benchmark, reflects
the costs necessary to support the operations of the company during the test year,
and is reasonable. (Chronister)
OPC: 	This is largely a fall out issue, but TECO has the burden of proof to demonstrate
the 	reasonableness 	or 	prudence 	of 	all 	costs 	to 	be 	included 	in 	revenue
requirements. 	OPC 	is 	still 	conducting 	discovery 	and 	certain 	other 	specific
adjustments to in rate base may be required. The O&M expense for the projected
2025 test year should reflect all of OPC’s recommended adjustments.
FL RISING/
LULAC: 	O&M expense should be adjusted to reflect the removal of O&M expenses as
specified in Issues 43–58.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	Sierra Club supports modifying O&M Expense for the 2025 projected test year to
reflect no coal combustion at Polk Unit 1 and Big Bend Unit 4.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 60: 	What amount of depreciation and dismantlement expense for the 2025
projected test year should be approved?
TECO: 	Based 	on 	the 	depreciation 	parameters 	and 	rates 	proposed 	in 	Issue 	7, 	the
Commission 	should 	approve 	Jurisdictional 	Adjusted 	Depreciation 	and
Amortization expense in the amount of $531.4 million for the projected 2025 test

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 71
year as shown on MFR Schedule C-1, less $504,154 per the company’s July and
August Filings for a total of $530.9 million. (Chronister, Allis, Kopp)
OPC: 	This is largely a fall out issue, but TECO has the burden of proof to demonstrate
the 	reasonableness 	or 	prudence 	of 	all 	costs 	to 	be 	included 	in 	revenue
requirements. 	OPC 	is 	still 	conducting 	discovery 	and 	certain 	other 	specific
adjustments to in rate base may be required. The depreciation and dismantlement
expense for the projected 2025 test year should reflect all of OPC’s recommended
adjustments and the adjustments from Issue 7.
FL RISING/
LULAC: 	Adopts the position of OPC, and then adjusted to reflect the disallowance of
projects that do not belong in rate base as reflected in other Issue positions.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 61: 	What amount of Taxes Other Than Income Taxes for the 2025 projected test
year should be approved?
TECO: 	The Commission should approve Jurisdictional Adjusted Taxes Other Than
Income expense of $101.6 million for the projected 2025 test year as shown on
MFR Schedule C-1, plus $923 per the company’s July and August Filings, for a
total of $101.6 million. (Chronister)
OPC: 	No position.
FL RISING/
LULAC: 	No position.
FIPUG: 	No position.

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FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 62: 	What amount of Parent Debt Adjustment is required by Rule 25-14.004,
Florida Administrative Code, for the 2025 projected test year?
TECO: 	The 	Commission 	should 	approve 	a 	Parent 	Debt 	Adjustment 	calculated 	in
accordance with Rule 25-14.004, F.A.C., of $12.9 million for the projected 2025
test year. The adjustment decreased the company’s 2025 revenue requirement by
$17.4 million. (Strickland, Chronister)
OPC: 	A $12.936 million revenue requirement reduction is required as shown in the
utility’s MFRs.
FL RISING/
LULAC: 	Adopts the position of OPC.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 73
ISSUE 63: 	What amount of Production Tax Credits should be approved and what is the
proper accounting treatment for the 2025 projected test year?
TECO: 	The 	company 	reduced 	projected 	2025 	test 	year 	income 	tax 	expense 	by
approximately $35.4 million to reflect the “flow through” of the estimated amount
of PTC to be generated in 2025 by its solar plants placed in service in 2022 and
thereafter, which amount should be approved by the Commission. (Strickland,
Chronister)
OPC: 	No changes to the as-filed TECO amounts for PTCs are recommended. TECO
included $35.388 million in PTCs as a reduction to income tax expense for the
2025 projected test year. Grossed-up, the PTCs reduced the revenue requirement
by $47.549 million.
FL RISING/
LULAC: 	For 2025, TECO should immediately flow PTCs to its customers. (Kollen)
The costs should also be flowed back to customers on a capacity basis. If the
Commission adopts 50% AD, then costs should flow back as 50% energy and
50% capacity.
FIPUG: 	The Commission should adopt a consumer protection by requiring TECO to flow-
through the higher of the actual PTCs earned or 100% of the projected PTCs
associated with the proposed solar projects. Also see Issue 18.
FEA: 	No position.
SIERRA
CLUB: 	Sierra Club takes no position on this issue, beyond supporting TECO maximizing
its eligibility for PTCs and passing on the savings from those tax credits to
residential customers, who face the highest energy burdens from TECO’s high
bills.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 74
ISSUE 64: 	What treatment, amounts, and amortization period for the Production Tax
Credits that were deferred in 2022-2024 should be approved for the 2025
projected test year?
TECO: 	As of December 31, 2024, the regulatory liability for “deferred” PTCs from 2022
to 2024 is expected to be approximately $55.3 million. The Commission should
approve this amount, a ten-year amortization period, and a resulting $5.5 million
Net Operating Income (NOI) reduction for the projected 2025 test year. The
three-year amortization period for deferred PTCs proposed by OPC is too short,
would create intergenerational inequities and an abnormal ratemaking earnings
profile, and should be rejected. The regulatory liability recorded by the company
should not be increased by a carrying charge, because the meaning of the
“normalization” requirement for new tax credits in the 2021 was in dispute and is
similar to a gain on the sale of assets, which does not accrue a carrying charge. If
a carrying charge for the regulatory liability is implemented, then the 13-month
average of the regulatory liability should be removed from Jurisdictional Adjusted
Rate 	Base 	so 	that 	the 	revenue 	requirement 	reduction 	is 	not 	done 	twice.
(Strickland, Chronister)
OPC: 	TECO deferred $41.150 million in PTCs in excess of ITCs applicable to the years
2022–2024. The Commission should compensate customers for carrying costs on
the deferred PTCs by adding the deferred carrying costs calculated at the allowed
return from the prior rate case to the regulatory liability. Carrying charges of
$3.437 million should be added to deferral balance making it sum to $44.587
million. After gross-up for income taxes, the balance returned to customers should
be $59.844 million (total TECO) and $59.634 million (jurisdictional). The effects
of the carrying charges addition are a reduction of at least $0.887 million in the
revenue requirement, assuming an amortization period of 10 years as filed by
TECO. The Commission should refund the regulatory liability, including the
deferred return on the regulatory liability for the years 2022 through 2024, over a
three-year amortization period. The effects are an additional reduction of at least
$13.182 million in the claimed revenue requirement. The revenue requirement
effects include the changes in amortization expense and the return effects of the
changes of the deferred balances in rate base.
FL RISING/
LULAC: 	The PTCs that were deferred in 2022–2024 totaling $0.460 million should go to
customers by adding the deferred carrying costs calculated at the allowed return
from the prior case to the regulatory liability. The amortization period should be
three years. (Kollen)
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
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SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 65: 	What treatment and amount of the Investment Tax Credits pursuant to the
Inflation Reduction Act should be approved for the 2025 projected test year?
TECO: 	The 	Commission 	should 	approve 	normalization 	(amortization 	over 	book
depreciation life) of deferred ITCs for solar and energy storage devices, because it
is required under U.S. Internal Revenue Service (IRS) requirements for solar and
for energy storage because it avoids intergenerational inequities by allowing the
customers who will pay for the assets to enjoy the benefit of the tax credits over
the life of the assets. For solar generating facilities placed in service before 2022,
the Commission should approve ITC amortization based on a 30-year proposed
book depreciation life that reduces income tax expense by $9.9 million for the
projected 2025 test year. For the ITC associated with energy storage facilities, the
Commission should approve ITC amortization based on a 10-year proposed book
depreciation life that reduces test year income tax expense by $3 million ($2.8
million based on the July and August Filings) for the projected 2025 test year.
The amortization periods for solar and storage should be adjusted to reflect the
book 	depreciation 	lives 	approved 	by 	the 	Commission 	in 	this 	case. 	If 	the
Commission requires TECO to opt-out of normalization for energy storage ITC,
the three-year amortization period for battery storage proposed by OPC is too
short, would create intergenerational inequities and an abnormal ratemaking
earnings profile, and should be rejected. (Strickland, Chronister)
OPC: 	The Commission should reflect the ITCs as if TECO elected and will continue to
elect out of the normalization requirements. If TECO is unwilling to elect out of
the normalization requirements each year, then the Commission should reduce the
company’s authorized ROE or some other form of penalty commensurate with the
offense for taking this path of self-interest and self-dealing at the expense of, and
harm to, its customers. The effects of the first recommendation are a reduction of
$3.493 million in the revenue requirement and a reduction of $0.100 million in
the CETM revenue requirement due to the reduction in the cost of capital by
including the new ITCs since 2022 as cost-free capital in the capital structure
instead of including the new ITCs at the weighted average cost of capital. The

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 76
Commission should also direct TECO to defer the ITCs pursuant to the Inflation
Reduction Act earned each year, but to amortize the deferred ITCs over a three-
year amortization period.
FL RISING/
LULAC: 	The ITCs should be treated as if TECO elected and will continue to elect out of
normalization requirements. The Commission should also direct TECO to defer
the ITCs each year and amortize the deferred ITCs over a ten-year amortization
period.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 66: 	What amount of Income Tax expense should be approved for the 2025
projected test year?
TECO: 	The Commission should approve Jurisdictional Adjusted Income Tax Expense
(Benefit) totaling ($8.3 million) for the projected 2025 test year as shown on MFR
Schedule C-1, plus $412,001 per the company’s July and August Filings, for a
total of ($7.9 million). The July and August Filings provided revenue requirement
impacts, 	the 	$412,001 	of 	Income 	Tax 	expense 	adjustments 	includes 	the
appropriate tax impacts to NOI. (Strickland, Chronister)
OPC: 	This is largely a fall out issue, but TECO has the burden of proof to demonstrate
the 	reasonableness 	or 	prudence 	of 	all 	costs 	to 	be 	included 	in 	revenue
requirements. 	OPC 	is 	still 	conducting 	discovery 	and 	certain 	other 	specific
adjustments to in rate base may be required. The Income Tax expense for the
projected 2025 test year should reflect all of OPC’s recommended adjustments.
FL RISING/
LULAC: 	Adopts the position of OPC.

ORDER NO. PSC-2024-0351-PHO-EI
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FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 67: 	What amount of Net Operating Income should be approved for the 2025
projected test year?
TECO: 	The Commission should approve Jurisdictional Adjusted Net Operating Income
for the projected 2025 test year of $501.4 million as shown on MFR Schedule C-
1, plus $376,230 of NOI adjustments per the company’s July and August Filings,
for a total of $501.7 million. The July and August Filings provided revenue
requirement impacts, the $376,230 of NOI adjustments includes the appropriate
tax impacts to NOI. (Chronister)
OPC: 	This is largely a fall out issue, but TECO has the burden of proof to demonstrate
the 	reasonableness 	or 	prudence 	of 	all 	costs 	to 	be 	included 	in 	revenue
requirements. 	OPC 	is 	still 	conducting 	discovery 	and 	certain 	other 	specific
adjustments to in rate base may be required. The Net Operating Income for the
projected 2025 test year should reflect all of OPC’s recommended adjustments.
FL RISING/
LULAC: 	Adopts the position of OPC, as modified to reflect positions on Issues 41–66.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agree with OPC.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 78
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
2025 REVENUE REQUIREMENTS
ISSUE 68: 	What 	revenue 	expansion 	factor 	and 	net 	operating 	income 	multiplier,
including the appropriate elements and rates, should be approved for the
2025 projected test year?
TECO: 	The Commission should approve a revenue expansion factor and NOI multiplier
of 0.74424 and 1.34364, respectively, for the projected 2025 test year based on
the following elements and rates: regulatory assessment fee (0.085%), bad debt
rate (0.224%), state income tax rate (5.5%) and federal income tax rate (21.0%).
(Chronister)
OPC:
Assume pre-tax income of 	1.0000%
Regulatory Assessment 	0.00085%
Bad Debt Rate 	0.00224%
Net Pretax Subtotal 	0.99691%
State income tax 	5.50% 	0.054830%
Taxable income for Federal income tax 	0.94208%
Federal income tax at 21% 	21.0% 	0.19784%
Revenue Expansion Factor 	0.74424%
Gross-Up 	1.34364
FL RISING/
LULAC: 	The revenue expansion factor and NOI multiplier should be adjusted to reflect a
50-50 equity-to-debt ratio.
FIPUG: 	Adopts the position of OPC.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 79
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	The appropriate revenue expansion factor is 1.34364.
FUEL
RETAILERS: No position.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 69: 	What amount of annual operating revenue increase for the 2025 projected
test year should be approved?
TECO: 	The Commission should approve a $295.5 million annual operating revenue
increase for the 2025 projected test year as shown on the company’s August
Filing. (Chronister, Collins)
OPC: 	The Commission should approve a revenue increase of no more than $43.8
million for 2025.
FL RISING/
LULAC: 	$0. The Commission should deny TECO’s requested rate increase.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No more than $43.8 million.
FUEL
RETAILERS: No position.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 80
2025 COST OF SERVICE AND RATES
ISSUE 70: 	Is TECO’s proposed separation of costs and revenues between the wholesale
and retail jurisdictions appropriate?
TECO: 	Yes. TECO’s proposed Jurisdictional Separation Study is appropriate and should
be approved. (Williams)
OPC: 	No position.
FL RISING/
LULAC: 	No position.
FIPUG: 	No position.
FEA: 	FEA supports TECO’s jurisdiction allocation study.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	The FRF does not oppose TECO’s jurisdictional separation cost of service study.
FUEL
RETAILERS: No position.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 71: 	What is the appropriate methodology to allocate production costs to the rate
classes?
TECO: 	The terms of the 2021 Stipulation and Settlement Agreement approved by Order
No. PSC-2021-0423-S-EI issued November 10, 2021, in Docket No. 20210034-EI
(“2021 Agreement”) require TECO to propose to allocate production costs using
the 4 Coincident Peak methodology. The Big Bend Unit 4 scrubber and Polk 1
gasifier should continue to be allocated on an energy basis, which is consistent
with TECO’s last four approved Cost of Service Studies. (Williams)
OPC: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
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FL RISING/
LULAC: 	The 12CP and 50% AD cost allocation methodology. (Rábago)
FIPUG: 	FIPUG agrees with TECO that the 4CP method should be used to allocate
production plant and related costs to the rate classes. The 4CP method best
reflects cost causation for TECO because it recognizes that (1) TECO must have
sufficient capacity to meet its peak demand and (2) TECO’s peak demands
regularly occur during daytime hours in the summer months and it is projecting to
become a winter peaking utility. Thus, the peak demands for the months June,
July, August, and January should be used to derive the 4CP allocation factors.
PTCs should be allocated on energy usage because PTCs are directly related to
the MW-hours generated from solar projects.
FEA: 	FEA supports the use of 4CP methodology as proposed by TECO.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	FRF does not oppose TECO’s proposed cost of service study.
FUEL
RETAILERS: No position.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 72: 	What is the appropriate methodology to allocate transmission costs to the
rate classes?
TECO: 	The terms of the 2021 Agreement require Tampa Electric to propose to allocate
transmission costs using the 4CP methodology. (Williams)
OPC: 	No position.
FL RISING/
LULAC: 	The 12CP cost allocation methodology. (Rábago)
FIPUG: 	FIPUG agrees with TECO that the 4CP method should be used to allocate
production plant and related costs to the rate classes. The 4CP method best
reflects cost causation for TECO because it recognizes that (1) TECO must have

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sufficient capacity to meet its peak demand and (2) TECO’s peak demands
regularly occur during daytime hours in the summer months and it is projecting to
become a winter peaking utility. Thus, the peak demands for the months June,
July, August, and January should be used to derive the 4CP allocation factors.
FEA: 	FEA supports the use of 4CP methodology as proposed by TECO.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	The FRF does not oppose TECO’s proposed cost of service study.
FUEL
RETAILERS: No position.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 73: 	What is the appropriate methodology to allocate distribution costs to the rate
classes?
TECO: 	The 	terms 	of 	the 	2021 	Agreement 	require 	TECO 	to 	propose 	to 	classify
distribution costs using a full MDS approach. Distribution costs should be
allocated the same way in which they were derived and provided in MFR
Schedule E-10. The allocation methodology relies on a mixture of rate class non-
coincident peaks and customer maximum demands. It is consistent with how
TECO has previously allocated distribution costs and consistent with NARUC’s
Electric Utility Cost Allocation Manual. (Williams)
OPC: 	No position.
FL RISING/
LULAC: 	The 12CP cost allocation methodology. (Rábago)
FIPUG: 	The MDS rate design approach should be used. This methodology, previously
approved by the Commission more fairly allocates utility costs to provide
distribution service. The MDS approach recognizes that the distribution network
must be ready to serve customers, irrespective of the amount of power and energy
used by customers. Allocating a portion of distribution network costs on the
number of customers recognizes the readiness to serve. Accordingly, using MDS

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to allocate distribution network costs based on the number of customers, which is
consistent with cost causation, is the proper approach.
FEA: 	FEA supports TECO’s proposed use of the MDS to classify primary distribution
cost as customer and demand. FEA supports the primary distribution cost
classified as customer to be allocated across rate classes on class customer
numbers. FEA supports allocating primary distribution costs classified as demand
on a non-coincident class demand allocator.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	The FRF does not oppose TECO’s proposed cost of service study.
FUEL
RETAILERS: No position.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 74: 	How should any change in the revenue requirement approved by the
Commission be allocated among the customer classes?
TECO: 	Any changes in the revenue requirement should be allocated among customers
based on the Commission’s approved cost allocation methodology. (Williams)
OPC: 	No position.
FL RISING/
LULAC: 	Changes in the revenue requirement should be allocated among customer classes
using a 12CP and 50% AD methodology. (Rábago)
FIPUG: 	The approved revenue requirement should be determined using an accepted class
cost of service study, except when it would result in a class receiving an increase
higher than 1.5 times the system average base revenue increase, and no class
should receive a rate decrease.
FEA: 	The revenue change should be allocated across rate classes based on the results of
TECO’s class cost of service study.

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SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	The FRF does not oppose TECO’s proposed revenue allocation methodology for
allocating any increase or decrease in revenue requirements to rate classes.
FUEL
RETAILERS: No position.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 75: 	Should 	the 	proposed 	modifications 	to 	the 	delivery 	voltage 	credit 	be
approved?
TECO: 	Yes. 	The 	proposed 	modifications 	are 	reasonable 	and 	should 	be 	approved.
(Williams)
OPC: 	No position.
FL RISING/
LULAC: 	No.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
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ISSUE 76: 	What are the appropriate service charges (initial connection, reconnect for
nonpayment, connection of existing account, field visit, temporary overhead
and underground, meter tampering)?
TECO: 	The appropriate service charges are the proposed charges provided in MFR
Schedule E-13b. (Williams)
OPC: 	No position.
FL RISING/
LULAC: 	TECO’s proposed initial connection charge and all proposed reconnection service
charges for residential customers should be reduced by 80%. (Rábago)
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 77: 	Should the modifications to the emergency relay power supply charge be
approved?
TECO: 	Yes. 	The 	proposed 	modifications 	are 	reasonable 	and 	should 	be 	approved.
(Williams)
OPC: 	No position.
FL RISING/
LULAC: 	Yes.
FIPUG: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 86
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 78: 	What are the appropriate basic service charges?
TECO: 	The appropriate basic service charges are shown in MFR Schedule E-13c.
(Williams)
OPC: 	The basic service charges should reflect all the adjustments recommended by
OPC.
FL RISING/
LULAC: 	TECO’s basic service charge for residential customers should be no more than
$0.43 per customer per day or no more than $13.08 per customer per month.
(Rábago)
FIPUG: 	The adjustments recommended by OPC should be adopted.
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	The FRF does not oppose TECO’s proposed cost of service study or its proposed
revenue allocation methodology.
FUEL
RETAILERS: No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 87
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 79: 	What are the appropriate demand charges?
TECO: 	The appropriate demand charges are shown in MFR Schedule E-13c. (Williams)
OPC: 	The demand charges should reflect all the adjustments recommended by OPC as
approved by the Commission.
FL RISING/
LULAC: 	The appropriate residential energy and demand charge should be no more than
8.59 cents/kWh for the first 1,000 kWh and no more than 9.52 cents/kWh for all
additional kWh of usage and reduced to reflect the reduced rate base from the
disallowance of TECO’s proposed investments as reflected in other issues.
(Rábago)
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	The FRF does not oppose TECO’s proposed cost of service study or its proposed
revenue allocation methodology.
FUEL
RETAILERS: In general, no objection to the proposed charges. However, TECO should
propose a reasonable demand charge that would facilitate the deployment of EV
fast charging stations by third parties such as the Fuel Retailers such as Duke is
considering.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 80: 	What are the appropriate energy charges?
TECO: 	The appropriate energy charges are shown in MFR Schedule E-13c. (Williams)

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 88
OPC: 	The energy charges should reflect all the adjustments recommended by OPC as
approved by the Commission.
FL RISING/
LULAC: 	The appropriate residential energy and demand charge should be no more than
8.59 cents/kWh for the first 1,000 kWh and no more than 9.52 cents/kWh for all
additional kWh of usage and reduced to reflect the reduced rate base from the
disallowance of TECO’s proposed investments as reflected in other issues.
(Rábago)
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	The FRF does not oppose TECO’s proposed cost of service study or its proposed
revenue allocation methodology.
FUEL
RETAILERS: No position.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 81: 	What are the appropriate Lighting Service rate schedule charges?
TECO: 	The appropriate Lighting Service charges are shown in MFR Schedule E-13c and
E-13d. (Williams)
OPC: 	No position.
FL RISING/
LULAC: 	No position.
FIPUG: 	No position.
FEA: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 89
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	The FRF does not oppose TECO’s proposed cost of service study or its proposed
revenue allocation methodology.
FUEL
RETAILERS: No position.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 82: 	What are the appropriate Standby Services (SS-1, SS-2, SS-3) rate schedule
charges?
TECO: 	The appropriate Standby Services rate schedule charges are shown in MFR
Schedule E-13c. (Williams)
OPC: 	No position.
FL RISING/
LULAC: 	Even though the rate increase should be denied, these rates should be increased to
reflect a 12CP and 50% AD cost of service.
FIPUG: 	4 CP.
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	The FRF does not oppose TECO’s proposed cost of service study or its proposed
revenue allocation methodology.
FUEL
RETAILERS: No position.
WALMART: Adopts the position of FRF.

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 90
STAFF: 	No position at this time.
ISSUE 83: 	Should the proposed modifications to the time-of-day periods be approved?
TECO: 	Yes. The proposed modifications to the time-of-day periods should be approved.
TECO’s proposed modifications to the time-of-day periods are reasonable and
more accurately reflect a change in the company’s marginal energy costs profile.
(Williams)
OPC: 	No position.
FL RISING/
LULAC: 	Yes.
FIPUG: 	No. TECO’s proposed time-of-day periods, which include very low “Super Off-
Peak” energy charges, would be unique in Florida. No other investor-owned
utility 	in 	Florida 	similarly 	offer 	a 	Super 	Off-Peak 	period 	that 	encourages
electricity usage during hot summer afternoons when TECO (and Florida utilities
generally) regularly experiences its system peaks. This would create a perverse
inventive to use more electricity during high load hours. Marginal energy costs
are not the only consideration in determining time-of-day periods. Other factors,
such as system loads, loss of load expectation, and the need to maintain
dispatchable generation to support the integration of renewable resources must
also be considered. Further, TECO’s projected marginal energy costs are not
consistently 	low 	during 	TECO’s 	proposed 	Super 	Off-Peak 	period. 	Finally,
TECO’s proposal would represent a drastic change from current practice, which
could be very disruptive to customers.
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	The FRF does not oppose TECO’s proposed cost of service study or its proposed
revenue allocation methodology.
FUEL
RETAILERS: No position.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.

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DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 91
ISSUE 84: 	Should the proposed modifications to the Non-Standard Meter Rider tariff
(Tariff Sheet No. 3.280) be approved?
TECO: 	No. TECO did not propose any modifications to the Non-Standard Meter Rider
tariff. (Williams)
OPC: 	No position.
FL RISING/
LULAC: 	Yes.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 85: 	Should the proposed tariff modifications to the Budget Billing Program
(Fifth Revised Tariff Sheet No. 3.020) be approved?
TECO: 	Yes. 	The 	proposed 	modifications 	are 	reasonable 	and 	should 	be 	approved.
(Williams, Sparkman)
OPC: 	No position.
FL RISING/
LULAC: 	No, although other modifications should be made.
FIPUG: 	No position.
FEA: 	No position.

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PAGE 92
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 86: 	Should the proposed tariff modifications regarding general liability and
customer responsibilities (Fifth Revised Tariff Sheet No. 5.070 and Original
Tariff Sheet No. 5.081) be approved?
TECO: 	Yes. 	The 	proposed 	modifications 	are 	reasonable 	and 	should 	be 	approved.
(Williams)
OPC: 	No position.
FL RISING/
LULAC: 	No.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.

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DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 93
ISSUE 87: 	Should 	the 	proposed 	tariff 	modifications 	to 	Contribution 	in 	Aid 	of
Construction (Fifth Revised Tariff Sheet No. 5.105) be approved?
TECO: 	Yes. 	The 	proposed 	modifications 	are 	reasonable 	and 	should 	be 	approved.
(Williams, Sparkman)
OPC: 	No, the proposed tariff modification to CIAC should not be approved unless all
installment payments of CIAC are fully credited to the benefit of the customer
before the plant is placed in service.
FL RISING/
LULAC: 	No.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 88: 	Should the proposed tariff modifications to the Economic Development Rider
(Third Revised Tariff Sheet Nos. 6.720, 6.725, 6.730) be approved?
TECO: 	Yes. 	The 	proposed 	modifications 	are 	reasonable 	and 	should 	be 	approved.
(Williams, Sparkman)
OPC: 	No position.
FL RISING/
LULAC: 	No, the entire Rider should be stricken.
FIPUG: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 94
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 89: 	Should the proposed modifications to LS-1 (Eleventh Revised Tariff Sheet
No. 6.809) regarding lighting wattage variance be approved?
TECO: 	Yes. 	The 	proposed 	modifications 	are 	reasonable 	and 	should 	be 	approved.
(Williams, Sparkman)
OPC: 	No position.
FL RISING/
LULAC: 	Yes.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.

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PAGE 95
ISSUE 90: 	Should the proposed LS-2 Monthly Rental Factors (Original Tariff Sheet No.
6.845) be approved?
TECO: 	Yes. The proposed LS-2 Monthly Rental Factors offers optionality to customers,
are reasonable, and should be approved. (Williams)
OPC: 	No position.
FL RISING/
LULAC: 	No position.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 91: 	Should 	the 	proposed 	termination 	factors 	for 	long-term 	facilities 	(Fifth
Revised Tariff Sheet No. 7.765) be approved?
TECO: 	Yes. The proposed termination factors for long-term facilities are reasonable and
should be approved. (Williams)
OPC: 	No position.
FL RISING/
LULAC: 	No position.
FIPUG: 	No position.
FEA: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
DOCKET NOS. 20240026-EI, 20230139-EI, 20230090-EI
PAGE 96
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 92: 	Should the non-rate related tariff modifications be approved?
TECO: 	Yes. The proposed revisions are reasonable and should be approved. (Williams,
Sparkman)
OPC: 	No position.
FL RISING/
LULAC: 	No.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 97
ISSUE 93: 	Should the Commission give staff administrative authority to approve tariffs
reflecting Commission approved rates and charges?
TECO: 	Yes. (Williams)
OPC: 	No position.
FL RISING/
LULAC: 	No.
FIPUG: 	Yes.
FEA: 	No position.
SIERRA
CLUB: 	For each of the Issues in this category, Sierra Club has no position beyond
generally supporting intervenor proposals to reduce energy burdens for residential
customers.
FRF: 	No position.
FUEL
RETAILERS: Yes.
WALMART: No position.
STAFF: 	No position at this time.
2026 AND 2027 SUBSEQUENT YEAR ADJUSTMENTS
ISSUE 94: 	What are the considerations or factors that the Commission should evaluate
in determining whether an SYA should be approved?
TECO: 	The Commission should consider the projects proposed to be included for cost
recovery via an SYA, the projected costs of those projects, the impact those plant
additions will have on the company’s ability to earn within its authorized range of
return on equity, and the extent to which the proposed SYA can mitigate the
company’s need for successive general rate increases. There is nothing in Section
366.076, F.S., that limits SYA to cost recovery for generation projects. The
projects included in the company’s proposed 2026 and 2027 SYA are major
projects, their costs are reasonable and prudent, placing them in service will have
a material impact on the company’s ability to earn within its authorized range of
returns, and including them in the proposed SYA will mitigate the company’s

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PAGE 98
need for successive general rate increases; therefore, they should be approved.
(Chronister)
OPC: 	A SYA should not be necessary nor is it good policy to approve one without
significant limitations. If the test year is chosen appropriately, it should be
representative of rates on a going-forward basis, negating the need for another
rate adjustment so shortly after the original test year, absent any extraordinary
circumstances. 	Moreover, 	any 	rate 	adjustments 	due 	the 	subsequent 	year
information is inherently more unreliable the further out in time the request is
made. While Section 366.076 (2), F.S., allows the Commission to adopt rules “for
incremental adjustments in rates for subsequent periods,” Rule 25-6.0425, Rate
Adjustment Application and Procedures, adopted to implement this provision
merely states “[t]he Commission may in a full revenue requirements proceeding
approve incremental adjustments in rates for periods subsequent to the initial
period in which new rate will be in effect.” No factors or other specific directions
are provided in the statute or in the rule. The Commission’s limited, past practice
has been to limit subsequent year rate adjustments to the placement of large,
discrete revenue impacting generation facilities into service such as the generation
base rate adjustments (GBRAs) or solar base rate adjustments (SoBRAs). Even
when the generation facilities and/or major capital projects are placed in service,
TECO still must demonstrate that it would cause TECO to earn below the
approved equity range due to the material revenue requirement impact in the
year(s) immediately after a rate case. Further, TECO must demonstrate the need
for generation and/or facilities in the subsequent year. Given the lack of other
directives in either the statute or rule, the Commission should not expand its use
of a SYA beyond large revenue impacting generation or equivalent type facilities.
All historically and traditional “business as normal” distribution “electric delivery
infrastructure” investment costs should NOT be allowed in a subsequent year
adjustment.
FL RISING/
LULAC: 	SYAs, if ever authorized, should be based on very specific, large, usually
singular, generation investments. These SYAs should not be approved. If the
Commission does approve an SYA, the Commission should apply the factors
proposed by OPC to establish a framework, limitations, guidance, and customer
protections when assessing which projects and costs, if any, should be included in
an SYA.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.

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PAGE 99
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 95: 	Should the Commission approve the inclusion of TECO’s proposed Solar
Projects in the 2026 and 2027 SYA? What, if any, adjustments should be
made?
TECO: 	Yes. The Future Solar Projects proposed for recovery through SYA are prudent or
the reasons explained under Issue 18 and should be included in the 2026 and 2027
SYA. (Stryker, Aponte, Heisey, Chronister)
OPC: 	The TECO proposed Solar Projects inclusion in the 2026 SYA and 2027 SYA
should not be allowed unless the Solar Projects meet the following criteria: (1)
they are specific new and material generation-type capital investment costs and
operation expenses (i.e. a discrete, material capital project); (2) the associated
revenue requirement would cause TECO to earn below the earnings range
approved in this docket in the subsequent year; and (3) TECO can demonstrate a
need for the generation and that they are cost-effective.
FL RISING/
LULAC: 	If the SYA is approved, then yes, with the following solar-specific adjustments: a
35-year service life of the assets; use of a 9.50% ROE. (Kollen)
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.

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ISSUE 96: 	Should the Commission approve the inclusion of TECO’s proposed Grid
Reliability and Resilience Projects in the 2026 and 2027 SYA? What, if any,
adjustments should be made?
TECO: 	Yes. The proposed GRR Projects are prudent for the reasons explained under
Issue 19 and should be included in the 2026 and 2027 SYA. There is nothing in
Section 366.076, Florida Statutes, that limits SYA to cost recovery for generation
projects, thus OPC’s proposal to disallow the GRR Projects should be rejected.
(Lukcic, Whitworth, Chronister)
OPC: 	No, the Commission should deny the inclusion of TECO’s proposed GRR
Projects for the following reasons: (1) these projects are historically, traditional
“business and normal” activities; (2) these projects are NOT for specific new and
material generation capital investment costs and operation expenses (i.e. a
discrete, material capital project); (3) “delivery infrastructure” investments have
not previously been allowed recovery in an SYA.
FL RISING/
LULAC: 	No.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPCl.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 97: 	Should the Commission approve the inclusion of TECO’s proposed Polk 1
Flexibility Project in the 2026 SYA? What, if any, adjustments should be
made?
TECO: 	Yes. The Polk 1 Flexibility Project is prudent for the reasons explained under
Issue 	24 	and 	should 	be 	included 	in 	the 	2026 	SYA. 	(Aldazabal, 	Aponte,
Chronister)

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OPC: 	The proposed Polk 1 Flexibility Project is being placed into service in 2025
during the test year without a full year revenue requirement. The TECO Polk 1
Flexibility Project inclusion in the 2026 SYA should not be allowed unless it
meets the following criteria: (1) it is a specific new and material generation
capital investment costs and operation expenses (i.e. a discrete, material capital
project); (2) the associate revenue requirement would cause TECO to earn below
the earnings range approved in this docket in the subsequent year; and (3) TECO
can demonstrate a need for the generation.
FL RISING/
LULAC: 	No.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	For the reasons outlined in the Statement of Basic Position above, the Polk 1
Flexibility Project should not be included in the 2026 SYA.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPCl.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 98: 	Should the Commission approve the inclusion of TECO’s proposed Energy
Storage Projects in the 2026 SYA? What, if any, adjustments should be
made?
TECO: 	Yes. The company’s 115 MW of Future Energy Storage Capacity projects are
prudent for the reasons explained under Issue 20 and should be included in the
2026 and 2027 SYA. As shown in the July Filing, the calculation of the
company’s proposed 2026 SYA should be adjusted to reflect an additional
$3,790,454 of energy storage rate base (13-month average), additional O&M and
depreciation expense of $285,000 and $321,545, respectively, a reduction of
property taxes $41,723, and an increase to the ITC amortization benefit of
$994,805, for a net revenue requirement decrease of $78,509 for the 2026 SYA.
As shown in the July Filing, the calculation of the company’s proposed 2027 SYA
should be adjusted to reflect an additional $1,686,310 of energy storage rate base
(13-month average), additional O&M expense, depreciation expense and property

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taxes 	of 	$42,408, $182,609 	and 	$40,800, 	respectively, 	for 	a 	net 	revenue
requirement 	increase 	of 	$422,181 	for 	the 	2027 	SYA. 	(Stryker, 	Aponte,
Chronister)
OPC: 	The TECO proposed Energy Storage Projects inclusion in the 2026 SYA should
not be allowed unless they met the following criteria: (1) they are specific new
and material generation-type capital investment costs and operation expenses (i.e.
a discrete, material capital project); (2) the associate revenue requirement would
cause TECO to earn below the earnings range approved in this docket in the
subsequent year; and (3) TECO can demonstrate a need for the energy supply
projects and that they are cost-effective.
FL RISING/
LULAC: 	If the SYA is approved, yes, with the following battery-specific adjustments: a
20-year service life of the assets; reflection of the assets as cost-free capital in the
cost of capital applied to rate base; use of a 9.50% ROE. (Kollen). A ten-year ITC
amortization period should also be used.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 99: 	Should the Commission approve the inclusion of TECO’s proposed Bearss
Operations Center Project in the 2026 SYA? What, if any, adjustments
should be made?
TECO: 	Yes. The Bearss Operations Center is prudent for the reasons explained under
Issue 23 and should be included in the 2026 SYA. (Aldazabal, Chronister)
OPC: 	The proposed Bearss Operation Center is being placed into service in 2025 during
the test year without a full year revenue requirement. The TECO proposed Bearss
Operations Center Project inclusion in the 2026 SYA should not be allowed

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unless it meets the following criteria: (1) it is a specific new and material capital
investment costs and operation expenses (i.e. a discrete, material capital project);
(2) the associate revenue requirement would cause TECO to earn below the
earnings range approved in this docket in the subsequent year; and (3) TECO can
demonstrate a need for the facility.
FL RISING/
LULAC: 	No.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 100: 	Should 	the 	Commission 	approve 	the 	inclusion 	of 	TECO’s 	proposed
Corporate Headquarters Project in the 2026 SYA? What, if any, adjustments
should be made?
TECO: 	Yes. The company’s new corporate headquarters project is prudent for the reasons
explained under Issue 21 and should be included in the 2026 SYA. (Aldazabal,
Chronister)
OPC: 	The proposed Corporate Headquarters Project is being placed into service in 2025
during the test year without a full year revenue requirement. The TECO proposed
Corporate Headquarters Project inclusion in the 2026 SYA should not be allowed
unless it meets the following criteria: (1) it is a specific new and material capital
investment costs and operation expenses (i.e. a discrete, material capital project);
(2) the associate revenue requirement would cause TECO to earn below the
earnings range approved in this docket in the subsequent year; and (3) TECO can
demonstrate a need for the facility.
FL RISING/
LULAC: 	No.

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FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 101: 	Should the Commission approve the inclusion of TECO’s proposed South
Tampa 	Resilience 	Project 	in 	the 	2026 	and 	2027 	SYA? 	What, 	if 	any,
adjustments should be made?
TECO: 	Yes. South Tampa Resilience Project is prudent for the reasons explained under
Issue 22 and should be included in the 2026 and 2027 SYA. (Aldazabal, Aponte,
Chronister)
OPC: 	The proposed South Tampa Resilience Project is being placed into service in 2025
during the test year without a full year revenue requirement. The TECO proposed
South Tampa Resilience Project inclusion in the 2026 SYA should not be allowed
unless it meets the following criteria: (1) it is a specific new and material capital
investment costs and operation expenses (i.e. a discrete, material capital project);
(2) the associate revenue requirement would cause TECO to earn below the
earnings range approved in this docket in the subsequent year; and (3) TECO can
demonstrate a need for the facility.
FL RISING/
LULAC: 	No.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.

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FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 102: 	Should the Commission approve the inclusion of TECO’s proposed Polk Fuel
Diversity Project in the 2026 and 2027 SYA? What, if any, adjustments
should be made?
TECO: 	Yes. The Polk Fuel Diversity project is prudent and should be included in the
2027 SYA. The Project will mitigate customer exposure to natural gas price
spikes and supply disruptions and is not proposed to be recovered in the 2026
SYA. (Aldazabal, Chronister)
OPC: 	The proposed Polk Fuel Diversity Project is being placed into service in 2025
during the test year without a full year revenue requirement. The TECO proposed
Polk Fuel Diversity Project inclusion in the 2026 SYA and 2027 SYA should not
be allowed unless it meets the following criteria: (1) it is a specific new and
material capital investment costs and operation expenses (i.e. a discrete, material
capital project); (2) the associate revenue requirement would cause TECO to earn
below the earnings range approved in this docket in the subsequent year; and (3)
TECO can demonstrate a need for the facility.
FL RISING/
LULAC: 	No.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	The Polk Fuel Diversity Project should not be included in the 2026 SYA.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 106
ISSUE 103: 	What overall rate of return should be used to calculate the 2026 and 2027
SYA?
TECO: 	The Commission should use the overall return approved in Issue 40, which the
company believes should be 7.37%. (Chronister)
OPC: 	The overall rate of return should be the OPC proposed ROR for 2025 of 7.19%
using OPC proposed ROE of 9.50%.
FL RISING/
LULAC: 	If the Commission approves the SYAs, the rate of return should be adjusted to
reflect the reduced rate base and adjusted capital structure.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	Sierra Club supports Florida Rising’s and LULAC’s proposed rate of return in
order to provide rate relief to energy burdened residential customers.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 104: 	Should the SYA for 2026 and 2027 reflect additional revenues due to
customer growth? What, if any, adjustments should be made?
TECO: 	No. OPC’s proposed revenue adjustments for 2026 and 2027 should be rejected
for the reasons discussed in Issue 2 and because additional revenue from customer
growth will be needed to recover costs associated with general rate base growth.
Imputing incremental into the calculation of the 2026 and 2026 SYA would be
inconsistent with the method used to calculate the company’s previous SoBRA
and GBRA, would moderate the benefits of SYA and increase the likelihood that
the company will need additional rate relief in those years. (Chronister, Cifuentes)
OPC: 	Yes. Should the Commission allow a 2026 SYA, the additional forecasted
revenues reflected due to customer growth should be increased by at least $7.994
million. Should the Commission allow a 2027 SYA, additional forecasted

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revenues reflected due to customer growth should be increased by at least $6.123
million.
FL RISING/
LULAC: 	If the Commission approves the SYAs, then yes. The 2026 SYA should be
reduced by $7.994 million, and the 2027 SYA should be reduced by $6.123
million to reflect additional revenues due to customer growth. (Kollen)
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Yes. Agrees with OPC as to appropriate adjustments.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 105: 	Should 	the 	Commission 	approve 	the 	inclusion 	of 	TECO’s 	proposed
incremental O&M expense associated with the SYA projects in the 2026 and
2027 SYA?
TECO: 	Yes. The O&M expenses for 2026 and 2027 for the SYA projects are project
specific and incremental to the O&M expenses included in the calculation of the
company’s projected 2025 test year NOI (see Issue 59). (Chronister)
OPC: 	No, the Commission should subtract the variable O&M expense savings that
TECO estimated in its cost effectiveness determinations. Otherwise, the requested
SYA revenue requirement for these costs is overstated.
FL RISING/
LULAC: 	No.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
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SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 106: 	Should the depreciation expense and Investment Tax Credits amortization
used to calculate the proposed 2026 and 2027 SYA be adjusted to reflect the
Commission’s decisions on depreciation rates and ITC amortization for the
2025 projected test year?
TECO: 	Yes. (Strickland, Chronister)
OPC: 	Yes, any 2026 SYA and 2027 SYA should reflect OPC’s proposed adjustments in
for ITCs to correct for errors and modify the Company’s calculation. The effect of
correcting TECO’s error and modifying the calculation is a reduction of $4.529
million in 2026 SYA revenue requirements and a reduction of $2.453 million in
the 2027 SYA revenue requirements.
FL RISING/
LULAC: 	Yes.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
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ISSUE 107: 	What annual amount of incremental revenues should be approved for
recovery through the 2026 and 2027 SYA?
TECO: 	The Commission should approve SYA for 2026 and 2027 to recover incremental
revenues of $100,074,841 and $71,847,925, respectively. These amounts have
been updated to reflect the impact of the adjustments shown in the July and
August Filings and Issue 98 and no income tax gross up on non-equity return
capital structure components. (Chronister)
OPC: 	If the Commission allows the GRR Projects, the Commission should reduce the
revenue requirement for the GRR Projects by at least $4.599 million in the 2026
SYA and by at least $28.788 million in the 2027 SYA.
FL RISING/
LULAC: 	$0.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC that the Commission should approve an increase of $60.257
million per year for 2026 and an increase of $20.286 million per year for 2027.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 108: 	What rate design approach should be used to develop customer rates for the
2026 and 2027 SYA?
TECO: 	The Commission should apply the incremental 2026 and 2027 SYA revenues
approved in Issue 107 on a pro rata basis to the customer, energy, and demand
charges for the non-lighting classes approved in Issues 75 through 85. (Williams)
OPC: 	The incremental revenues should include all of OPC’s adjustments which would
allow a maximum revenue increase of $60.257 million in 2026 and $20.286
million in 2027.

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FL RISING/
LULAC: 	If the Commission approves the SYA, then 12CP + 50% AD should be used to
allocate the increased revenue requirement.
FIPUG: 	The rate design approach as proposed by FIPUG above, 4 CP.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	The FRF does not oppose TECO’s proposed cost of service study or its proposed
revenue allocation methodology.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 109: 	When should the 2026 and 2027 SYA become effective?
TECO: 	The 2026 and 2027 SYA should be effective with the first billing cycle in January
2026 and 2027, respectively. (Chronister, Williams)
OPC: 	The 2026 SYA, if allowed over the objection of OPC, should not become
effective any sooner than the first billing cycle in 2026. The 2027 SYA, if allowed
over the objection of the OPC, should not become effective any sooner than the
first billing cycle in 2027.
FL RISING/
LULAC: 	Never. If the Commission approves the SYAs, then January 1, 2026, and January
1, 2027.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	If approved, any 2026 SYA should become effective for service rendered on the
first day of the first billing cycle of January 2026, and any 2027 SYA should

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 111
become effective for service rendered on the first day of the first billing cycle of
January 2027.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 110: 	Should TECO be required to file its proposed 2026 and 2027 SYA rates for
Commission approval in September 2026 and 2027, respectively, reflecting
then current billing determinants?
TECO: 	Yes. This approach ensures that SYA rates will be based on the most recent
available billing determinants. (Williams)
OPC: 	Yes.
FL RISING/
LULAC: 	Yes, if the Commission approves the 2026 and 2027 SYAs.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Yes.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
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OTHER
ISSUE 111: 	Should TECO’s proposed Corporate Income Tax Change Provision be
approved?
TECO: 	Yes. The proposed Corporate Income Tax Change Provision, like others that have
been in effect by agreement since 2013, will provide an efficient regulatory
mechanism for addressing corporate income tax changes that occur after this rate
proceeding is over. (Chronister)
OPC: 	No. It is premature as there is no pending federal or state tax law changes and
may inappropriately affect the agency’s future actions that otherwise would be
applicable to all utilities statewide. Based on Commission precedent, this issue
should not be included in this docket.
FL RISING/
LULAC: 	No.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 112: 	Should TECO’s proposed Storm Cost Recovery Provision be approved?
TECO: 	Yes. The proposed Storm Cost Recovery Provision, like others that have been in
effect by agreement since 2013, will provide an efficient regulatory mechanism
for review and recovery of prudent storm damage restoration and recovery costs.
(Chronister)
OPC: 	Yes, to the extent the storm cost recovery provision is consistent with the Wilson
case which allows for a tariff filed by a company to become effective subject to a
hearing.

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FL RISING/
LULAC: 	No.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No. FRF does not object to prompt recovery by TECO of significant storm
restoration costs without a rate-case type inquiry, but the FRF agrees with
Walmart that decisions regarding the cost allocation and rate design for recovery
of storm restoration costs should be decided in specific proceedings for each
storm event.
FUEL
RETAILERS: No position.
WALMART: Walmart opposes the resolution of this issue in this Docket as to the procedure by
which TECO collects future storm costs from customers, though Walmart agrees
that such collection of future storm costs would not be subject to a rate case type
inquiry.
STAFF: 	No position at this time.
ISSUE 113: 	Should TECO’s proposed Asset Optimization Mechanism be approved, and
what, if any, modifications should be made?
TECO: 	Yes. The company’s existing Asset Optimization Mechanism (“AOM”) has
provided over $45 million of customer benefits since 2018. Adding capacity
release of gas pipeline transportation and renewable energy credit (“REC”) sale
revenues to the AOM will reasonably incent the company to engage in beneficial
transactions that will lower fuel expenses for customers; therefore, the company’s
proposed AOM should be approved. (Heisey)
OPC: 	No. This is not the proper subject of a base rate case.
FL RISING/
LULAC: 	No.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.

ORDER NO. PSC-2024-0351-PHO-EI
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SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.
ISSUE 114: 	What are the appropriate updated Clean Energy Transition Mechanism
factors and when should they become effective?
TECO: 	The Commission should approve the proposed CETM factors shown on pages 10
and 11 of the prepared direct testimony of Ashley Sizemore as updated to reflect
the overall rate of return approved by the Commission in Issue 40 to be effective
with the first billing cycle in January 2025. (Sizemore)
OPC: 	The CETM should be reduced by $1.828 million in 2025 to reflect OPC’s
positions on ROE of 9.5% and inclusion of the battery storage related ITCs as
zero cost of capital.
FL RISING/
LULAC: 	CETM should be discontinued.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Agrees with OPC.
FUEL
RETAILERS: No position.
WALMART: Agrees with OPC.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 115
ISSUE 115: 	Should the proposed Senior Care Program (Original Tariff Sheet No. 3.310)
and associated cost recovery be approved?
TECO: 	Yes. The proposed new Senior Care Program assists a small population of
financially challenged customers and should be approved. (Williams, Sparkman)
OPC: 	No position.
FL RISING/
LULAC: 	No, the Program should not be approved as-is with its associated cost recovery
mechanism.
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 116: 	Should TECO be required to perform any studies or analysis relating to the
retirement of Polk Unit 1 and/or Big Bend Unit 4, including early retirement
dates, environmental compliance costs, and/or procurement of alternative
resources?
TECO: 	No. The company’s testimony and exhibits demonstrate that (1) Polk Unit 1
provides important fuel diversity, reliability, and flexibility benefits to customers
and could return to IGCC operation within a year to help protect customers from
high gas prices if the forward price curve for petcoke is favorable and (2) Big
Bend Unit 4 provides important fuel diversity, reliability, and flexibility benefits
to customers, and while it does not frequently run on coal, Big Bend 4 is available
to run and has recently run on coal during extreme winter weather, when gas
prices spiked, and during pipeline alert periods when gas deliveries to Florida
were limited. The company evaluates the roles these units play in its generating
portfolio every year as part of the 10-Year Site Planning process, so no further

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studies or actions like early retirement and loan applications are needed or should
be ordered at this time. (Aldazabal, Stryker)
OPC: 	No position.
FL RISING/
LULAC: 	Adopts the position of Sierra Club.
FIPUG: 	Not unless ordered to do by the Commission.
FEA: 	No position.
SIERRA
CLUB: 	As outlined in the Statement of Basic Position above, TECO should, at a
minimum, provide its energy burdened customers with rate relief by ceasing coal
operations at Polk Unit 1 and Big Bend Unit 4 as soon as possible. Polk Unit 1
and Big Bend Unit 4’s coal combustion equipment should be retired in 2024 and
2025, respectively.
In addition, Sierra Club recommends completely retiring both plants by 2030. If
the Commission does not require these 2030 retirements, TECO should be
required to study earlier retirement dates for Polk Unit 1 and Big Bend Unit 4,
including retirements by 2030 and 2032, by measuring the cost-effectiveness of
retiring each unit early against the cost of acquiring replacement resources. TECO
should additionally be required to study the economic impacts of complying with
EPA’s 2024 rules affecting fossil-fueled power plants, which are listed in the
Statement of Basic Position above, and TECO should include those projected
costs in its retirement scenarios. In the event that the Commission calls for a
retirement study rather than retirement commitments, these scenarios and studies
should be published in a formal report to the Commission no later than the end of
2025. In that event, the Commission should also require TECO to apply for EIR
funding to fund clean replacement resources for Polk 1 and Big Bend 4 by the end
of 2025. TECO should be required to submit to the Commission a plan to take
advantage of such funding based on the results of the retirement studies.
FRF: 	Regardless whether the Commission requires TECO to perform any studies or
analyses relating to potential early retirements of Polk Unit 1 or Big Bend Unit 4,
in the current regulatory environment, it would be imprudent for TECO not to be
conducting such studies and analyses on a regular basis far enough in advance to
enable it to make prudent retirement decisions based on regulatory and market
developments.
FUEL
RETAILERS: No position.

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WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 117: 	What is the appropriate effective date for TECO's revised 2025 rates and
charges?
TECO: 	The company’s revised 2025 rates and charges should be approved effective with
the first billing cycle in January 2025. (Chronister, Williams)
OPC: 	The 2025 rates and charges should not become effective any sooner than the first
billing cycle in 2026.
FL RISING/
LULAC: 	No effective date should be applicable because the Commission should deny
TECO’s petition for rate increase. If the Commission does not outright deny the
petition, then January 1, 2025.
FIPUG: 	Adopts the position of OPC.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Any change in rates for the 2025 test year should be effective for service rendered
on the first day of the first billing cycle of January 2025.
FUEL
RETAILERS: No position.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 118: 	Has the Commission considered TECO’s performance pursuant to Sections
366.80–366.83 and 403.519, Florida Statutes, when establishing rates?
TECO: 	Yes. The company’s FEECA performance is summarized in the prepared direct
testimony of Ashley Sizemore. From inception through the end of 2023, the
company’s energy conservation programs have reduced summer and winter peak
demand by 835.4 MW and 1,349.8 MW, respectively, and have saved 1,950.1

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GWh of annual energy, which is the equivalent of avoiding the need for over
seven 180 MW power plants. (Sizemore)
OPC: 	No position.
FL RISING/
LULAC: 	No, not at this time. However, the Commission has a duty to consider these
statutes. The Commission should consider TECO’s performance adequate, but
since TECO does minimal energy efficiency as compared to national standards,
no adjustments are warranted. (Marcelin)
FIPUG: 	No position.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	No position.
FUEL
RETAILERS: No position.
WALMART: No position.
STAFF: 	No position at this time.
ISSUE 119: 	What 	considerations 	should 	the 	Commission 	give 	the 	affordability 	of
customer bills and how does TECO’s rate increase impact ratepayers in this
proceeding?
TECO: 	Affordability is a term that’s difficult to describe because its meaning varies from
person-to-person. What may be “affordable” varies from household-to-household.
It 	depends 	on 	individual 	perceptions, 	income 	levels, 	financial 	obligations,
spending priorities, and spending decisions. Two families with the same income
and utility bills may view affordability of electricity differently based on their
different circumstances. The term “affordable” is not used or defined in Chapter
366, Florida Statutes. To the extent the U.S. Department of Energy’s high energy
burden six percent guideline is relevant, the company’s historical and proposed
residential bills for a two person household would be about 4.5 percent, well
below the guideline.
Electricity is steadily becoming a more important and valuable part of daily
living. The company 	is 	committed to providing safe, reliable, and resilient

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PAGE 119
electric service to all of its customers – now and in the future. The Commission
should consider affordability in this case by recognizing that the company
promotes overall affordability by operating in an efficient and cost-effective
manner, and by making investments that provide long-term value to moderate fuel
and operating costs and increase reliability and resilience. Tampa Electric’s
proposed rates and charges in this case reflect these efforts; are fair, just, and
reasonable; and will allow the company to continue meeting the ever increasing
service and reliability expectations of its customers.
The actual impact of the proposed rate increase in this case is difficult to predict
because they will be reflected on customer bills that are influenced by the weather
and 	customer usage, which cannot be estimated with certainty on an individual
customer basis, and on recovery clause factors that have not been set. Moderate
weather and low fuel costs can offset the impact of base rate increases on
customers; extreme weather and high fuel costs can have the opposite effect.
As filed, the company’s proposed 2025 base rate increases for a typical 1,000
kWh RS bill and a typical 1,200 kWh GS bill are 21.9 and 2.5 percent,
respectively. Using the company’s recovery clause factors in effect on January 1,
2024, which have since declined, the company estimates that a typical 1,000 kWh
residential bill will increase about 12 percent over 2024 but would be lower than
in 2023. Similarly, a typical small commercial bill of 1,200 kWh would increase
0.1 	percent 	over 	2024 	and 	would 	be 	about 	10 	percent 	lower 	than 	2023.
(Williams, Sparkman)
OPC: 	Pursuant to Section 366.06(1), F.S., the Commission may only approve the parts
of TECO’s rate request which results in rates that are fair, just, and reasonable for
each customer class. TECO’s requested rate increase would translate to an over
50% increase in base rate. The policy for energy in the State is now to “ensure an
adequate, reliable, and cost-effective supply of energy for the state in a manner
that promotes the health and welfare of the public . . .” with goals including
“[e]nsuring a cost-effective and affordable energy supply.” 	See Section 377.601
(1) and (2)(a), F.S. (2024). TECO’s bloated revenue request is contrary to the
State’s goal of providing affordable, reasonable rates for each customer class.
The Commission should consider energy affordability in this proceeding, and all
future utility base rate proceedings, in evaluating rate increase requests consistent
with the trends in other U.S. regulatory jurisdictions.
TECO’s excessive rate increase request will have a negative impact on ratepayers.
In today’s tough economic climate, TECO’s customers are already under great
financial pressure, so any increase will have a significant impact on them. Now,
more than ever, the Commission must consider affordability of the customer’s
bills when evaluating TECO’s rate request. Ultimately, the Commission must
hold TECO to its burden and only approve the portions of TECO’s rate request
which are fair, just, and reasonable.

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PAGE 120
FL RISING/
LULAC: 	In order to set fair and reasonable rates, the Commission would be remiss not to
consider the affordability of customer bills, which involves, in part, assessing the
energy burdens of TECO’s customers. In other words, the Commission should
consider the extent to which energy bills constitute a share of customers’
household incomes—the higher the share, the greater the energy burden. Because
customers 	with 	high 	energy 	burdens, 	primarily 	low-income 	customers, 	are
vulnerable to rate and bill volatility, unaffordable electric bills can create a
cascade of household economic problems. Further, TECO’s customers living at or
below the poverty level experiencing high energy burdens cannot simply reduce
their energy consumption or invest in energy efficiency measures to cut back on
bills, and customers living in rental properties have even less control over the
heating and cooling arrangements in their homes. Beyond economic problems,
unaffordable electricity bills implicate social and public health issues. Thus, the
Commission should also consider affordability in the context of the broader
affordability 	crisis 	TECO 	customers 	are 	facing—from 	housing 	to 	food 	to
insurance costs—and in the context of changing weather patterns, such as an
increased number of extreme heat days each year. Consideration of energy burden
and affordability in this rate case, and denial of increased rates, means more
TECO customers may not have to choose between electricity and no electricity or
choose electricity over medication, food, rent, and other necessities. (Rábago)
(Marcelin)
Additionally, state and local governments and public utilities commissions are
increasingly considering energy affordability in regulation and public policy.
New York recently adopted a statewide goal of achieving a six percent energy
burden, the common threshold at which energy bills are deemed unaffordable.
Additionally, 	the 	California 	Public 	Utilities 	Commission 	developed 	an
affordability metric for essential services, and the Pennsylvania Public Utility
Commission 	has 	examined 	and 	established 	maximum 	energy 	burdens 	for
customers. (Dismukes)
If the Commission approves TECO’s rate increases, TECO’s lowest users of
electricity, primarily low-income customers, will experience shocking base rate
and bill increases compared to wealthier customers using significantly more
energy. Additionally, TECO plans to increase the daily per-customer fixed charge
by 51% from $0.71 to $1.07. 	In 2023, TECO’s residential customers averaged
1,157 kWh of usage, resulting in an average 2023 bill of $191.95. 	Due to
decreased 	fuel 	prices 	and 	reduced 	storm 	recovery 	charges, 	under 	TECO’s
proposed rates, its 2025 bill would cost $184.25 with the same 1,157 kWh usage,
rising to $196.96 in 2027 with the proposed SYAs. However, this number could
be dramatically higher when fuel prices rise and if a storm (or storms) hit TECO’s
service area from now through the end of 2027. (Rábago) (Marcelin)

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FIPUG: 	TECO’s proposed rate increase results in a base rate increase of 20% in the first
year for large commercial and industrial users and over 30% when the subsequent
year rate increase adjustments are included. The Commission should consider the
affordability of bills for all customers, and consider the key roles that large
commercial and industrial customers play in the social fabric of TECO’s service
area. Collectively, large commercial and industrial customers provide good jobs
to countless Floridians, pay millions of dollars in taxes to federal, state, and local
governments, and contribute to the communities in which they operate. Large
commercial and industrial customers must often compete regionally, nationally
and in some cases, internationally, in their respective marketplaces. Energy is a
significant variable cost for large commercial and industrial customers and the
energy costs must be affordable for these businesses to be successful.
The Commission is charged with balancing competing interests when considering
TECO’s rate case. One issue of significant importance to large commercial and
industrial customers, FIPUG, and FEA, which represents MacDill Airforce Base
in Tampa, is to fairly apply a rate design which best assigns costs to those rate
classes which cause the costs. TECO has proposed and supports the 4CP
approach, which the Commission approved previously in the most recent TECO
rate case settlement. This approach is a fair way to assign costs and is an
important and meaningful affordability issue in this case for FIPUG and other
parties.
FEA: 	Adopts the position of FIPUG.
SIERRA
CLUB: 	Sierra Club is deeply concerned that TECO customers face the third-highest
electricity bills in the nation. Accordingly, the Commission should favor measures
to reduce ratepayers’ bills when facing policy choices in weighing the recovery of
TECO’s proposed expenses. Wherever the Commission can reduce costs to
ratepayers, the Commission should favor such proposals. Finally, the Commission
should scrutinize TECO’s reserve margin and reliability planning assumptions
with an eye toward reducing overbuild and costs to ratepayers.
Sierra Club is concerned that this rate increase will have a substantial harmful
impact on already-overburdened electricity customers. TECO’s rate increase
could lead to customers facing unacceptable choices regarding basic necessities.
Customers may have to choose whether to pay for food or pay TECO to run their
air conditioning. With such high bills, more customers will be vulnerable to going
into debt or arrearage.
FRF: 	Pursuant to the over-arching mandate of Section 366.01, F.S., to regulate public
utilities in the public interest, the Commission must always consider, among all
relevant factors, the affordability of customer bills and the impacts of rate
increases on electric customers and on the Florida economy. In this case involving
TECO’s request for increased rates, the correct balance is simple and obvious: the

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 122
Commission should approve rates that will produce revenues that are sufficient to
enable TECO to recover all of its necessary costs incurred to provide safe and
reliable service and to earn a reasonable—but not excessive—return on its used
and useful investment.
TECO’s requested rate increases will, if approved, harm all of its customers
(ratepayers) by charging customers more than is necessary for TECO to provide
safe and reliable service while providing TECO with a reasonable return on its
investment. At the same time, TECO’s requested rate increases will, if approved,
harm Florida’s economy by forcing TECO’s customers, many of whom are
already economically distressed by TECO’s high rates, to pay more than is
necessary for electric service, thereby diminishing customers’ ability to purchase
more Florida-produced goods and services while transferring excessive profits
from TECO’s customers to its Canadian owners.
FUEL
RETAILERS: Agrees with OPC.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 120: 	Should TECO be required to file, within 90 days after the date of the final
order in this docket, a description of all entries or adjustments to its annual
report, rate of return reports, and books and records which will be required
as a result of the Commission’s findings in this rate case?
TECO: 	Yes. (Chronister)
OPC: 	No position.
FL RISING/
LULAC: 	No, 	because 	TECO’s 	petition 	for 	rate 	increase 	should 	be 	denied. 	If 	the
Commission does not outright deny the petition, then yes.
FIPUG: 	Yes.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	Yes.

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 123
FUEL
RETAILERS: Yes.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.
ISSUE 121: 	Should this docket be closed?
TECO: 	Yes.
OPC: 	No position.
FL RISING/
LULAC: 	Yes, after the Commission denies TECO’s petition for rate increase.
FIPUG: 	Yes, after the Commission takes final agency action.
FEA: 	No position.
SIERRA
CLUB: 	No position.
FRF: 	When a final Commission order has been issued and either (a) all appeals of such
order or orders have been finally resolved, or (b) the time for filing any further
appeal has passed, this docket should be closed.
FUEL
RETAILERS: Not until all actions are concluded, including any appeals.
WALMART: Adopts the position of FRF.
STAFF: 	No position at this time.

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 124
IX. 	EXHIBIT LIST
Witness 	Proffered
By
Description
Direct
Archie Collins 	TECO 	AC-1 	1. List of Tampa Electric Witnesses
and Purpose of their Direct
Testimony
2. List of Minimum Filing
Requirement Schedules Sponsored
by Archie Collins
3. List of Minimum Filing
Requirement Schedules Witness
Assignments
Karen Sparkman 	TECO 	KKS-1 	1. List of Minimum Filing
Requirement Schedules Sponsored or
Co-Sponsored By Karen Sparkman
2. Tampa Electric JDP Study
Highlights – Residential
3. Tampa Electric JDP Study
Highlights – Business
4. Customer Contact Center Metrics
5. Statistics on Commission
Escalated Calls
6. Customer Experience Capital
Expense Summary 2022 – 2025
Carlos Aldazaba 	TECO 	CA-1 	1. List of Minimum Filing
Requirement Schedules Sponsored or
Co-Sponsored by Carlos Aldazabal
2. Generation Mix
3. Total System Heat Rate (2013-
2023)
4. Total CO2 Emissions (2013-2023)
5. System Heat Rate and Fuel
Savings
6. Total System Net EAF Percentage
7. Solar Projects 2021-2023
8. Headquarters Evaluation
Scorecard
9. Headquarters Evaluation
10. Energy Supply Capital Expense
Summary 2022-2025

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Witness 	Proffered
By
Description
Kris Stryker 	TECO 	KS-1 	1. List of Minimum Filing
Requirement Schedules Sponsored or
Co-Sponsored by Kris Stryker
2. English Creek Solar Project
Specifications and Projected Costs
3. Bullfrog Creek Solar Project
Specifications and Projected Costs
4. Duette Solar Project Specifications
and Projected Costs
5. Cottonmouth Solar Project
Specifications and Projected Costs
6. Big Four Solar Project
Specifications and Projected Costs
7. Farmland Solar Project
Specifications and Projected Costs
8. Brewster Solar Project
Specifications and Projected Costs
9. Wimauma 3 Solar Project
Specifications and Projected Costs
10. Dover Energy Storage Capacity
Project Specifications and Projected
Costs
11. Lake Mabel Energy Storage
Capacity Project Specifications and
Projected Costs
12. Wimauma Energy Storage
Capacity Project Specifications and
Projected Costs
13. South Tampa Energy Storage
Capacity Project Specifications and
Projected Costs
14. Clean Energy Capital Expense
Summary 2022-2025
Jose Aponte 	TECO 	JA-1 	1. Demand and Energy Forecast
2. Fuel Price Forecast
3. Future Project Costs Per kWac
4. Polk 1 Flexibility Project Cost-
Effectiveness Test
5. South Tampa Resilience Project
Cost-Effectiveness Test
6. Total Energy Storage Capacity

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Witness 	Proffered
By
Description
Cost-Effectiveness Test
7. Dover Energy Storage Capacity
Cost-Effectiveness Test
8. Lake Mabel Energy Storage
Capacity Cost-Effectiveness Test
9. Wimauma Energy Storage
Capacity Cost-Effectiveness Test
10. South Tampa Energy Storage
Capacity Cost-Effectiveness Test
11. Total Future Solar Cost-
Effectiveness Test
12. Future Solar (2024 Projects)
Cost-Effectiveness Test
13. Future Solar (2025 Projects)
Cost-Effectiveness Test
14. Future Solar (2026 Projects)
Cost-Effectiveness Test
15. English Creek Solar Cost-
Effectiveness Test
16. Bullfrog Creek Solar Cost-
Effectiveness Test
17. Duette Solar Cost-Effectiveness
Test
18. Cottonmouth Solar Cost-
Effectiveness Test
19. Big Four Solar Cost-
Effectiveness Test
20. Farmland Solar Cost-
Effectiveness Test
21. Brewster Solar Cost-
Effectiveness Test
22. Wimauma 3 Solar Cost-
Effectiveness Test

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Witness 	Proffered
By
Description
Chip Whitworth 	TECO 	CW-1 	1. List of Minimum Filing
Requirement Schedules Sponsored or
Co-Sponsored by Chip Whitworth
2. FPSC Adjusted Reliability Trends
3. Service Area Customer Demand –
Growth
4. Electric Delivery Capital Expense
Summary 2022-2025
5. DOE ICE Calculator Results
6. Line Loss Reduction
7. Grid Reliability and Resilience
Project Schedule
8. Service Territory Map
David Lukcic 	TECO 	DL-1 	1. List of Minimum Filing
Requirement Schedules Sponsored or
Co-Sponsored by David Lukcic
2. Operation Technology Capital
Expense Summary 2022-2025
Christopher Heck 	TECO 	CH-1 	1. List of Minimum Filing
Requirement Schedules Sponsored or
Co-Sponsored by Chris Heck
2. Information Technology Capital
Expense Summary 2022-2025
Marian Cacciatore 	TECO 	MC-1 	1. List of Minimum Filing
Requirement Schedules Sponsored or
Co-Sponsored by Marian Cacciatore
2. Employee Count Total by
Function
(2021-2025)
3. IBEW and OPEIU Historical Base
Wage Adjustments (2021-2023)
4. Total Annual Compensation
Analysis for Exempt and Non-
Covered/Non-Exempt Benchmarked
Positions (2022-2023)
5. Merit Budget History – Exempt
(2021-2023)
6. Merit Budget History – Non-
Covered/Non-Exempt (2021-2023)
7. Utility Comparison – Total

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Witness 	Proffered
By
Description
Salaries and Wages as a Percent of
Operations and Maintenance
Expense (2023)
8. Tampa Electric Benefits Package
Description
9. 2023 Benefits Valuation Analysis
(“BVA”)
10. Mercer – Average Annual Health
Benefits Cost Per Employee (2021-
2023)
Lori Cifuentes 	TECO 	LC-1 	1. List of Minimum Filing
Requirement Schedules Sponsored or
Co-Sponsored by Lori Cifuentes
2. Comparison of 2021 Forecast
Versus Current Forecasts of
Customer Growth and Energy Sales
3. Economic Assumptions Average
Annual Growth Rate
4. Billing Cycle Based Degree Days
5. Customer Forecast
6. Per-Customer Energy
Consumption
7. Retail Energy Sales
8. Per-Customer Peak Demand
9. Peak Demand
10. Firm Peak Demand
11. Firm Peak Load Factor
Ned Allis 	TECO 	NA-1 	1. List of Minimum Filing
Requirement Schedules sponsored or
co-sponsored by Ned Allis on behalf
of Tampa Electric Company
2. 2023 Depreciation Study
3. List of Cases in which Ned Allis
Submitted Testimony
4. Summaries of Depreciation
Accruals Using Existing and
Proposed Depreciation Rates

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Witness 	Proffered
By
Description
Jeff Kopp 	TECO 	JK-1 	1. Decommissioning Cost Estimate
Study
2. Resume of Jeffrey Kopp
3. List of Proceedings in which Mr.
Kopp has Submitted Testimony
Dylan D’Ascendis 	TECO 	DWD-1 	1. Resume and Testimony Listing of
Dylan W. D’Ascendis
2. Summary of Common Equity Cost
Rate
3. Financial Profile of Tampa
Electric Company and the Utility
Proxy Group
4. Application of the Discounted
Cash Flow Model
5. Application of the Risk Premium
Model
6. Application of the Capital Asset
Pricing Model
7. Basis of Selection for the Non-
Price Regulated Companies
Comparable in Total Risk to the
Utility Proxy Group
8. Application of Cost of Common
Equity Models to the Non-Price
Regulated Proxy Group
9. Derivation of the Flotation Cost
Adjustment to the Cost of Common
Equity
10. Derivation of the Indicated Size
Premium for Tampa Electric
Company Relative to the Utility
Proxy Group
11. Service Area Maps for Tampa
Electric and the Utility Proxy Group
12. National Risk Index of Utility
Proxy Group and Tampa Electric
Company
13. Comparison of Projected Capital
Expenditures Relative to Net Plant
14. Fama and French – Figure 2
15. Referenced Endnotes for the

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Witness 	Proffered
By
Description
Prepared Direct Testimony of Dylan
W. D’Ascendis
John Heisey 	TECO 	JH-1 	1. Asset Optimization Mechanism
Results 2018-2023
Valerie Strickland 	TECO 	VS-1 	1. List of Minimum Filing
Requirement Schedules Sponsored or
Co-Sponsored by Valerie Strickland
2. Calculation of 2025 PTC Revenue
Requirement Impact and Proposed
Amortization of Deferred PTC
Benefit
3. Calculation of IRC Required
Deferred Income Tax Adjustment
Jeff Chronister 	TECO 	JC-1 	1. List of Minimum Filing
Requirement Schedules Sponsored or
Co-Sponsored by Jeff Chronister
2. Final Order No. PSC-2021-0423-
S-EI Approving 2021 Stipulation
Settlement Agreement (without
Attachment C – Tariffs)
Jeff Chronister
Vol. II
TECO 	JC-2 	1. List of Minimum Filing
Requirement Schedules Sponsored or
Co-Sponsored by Richard Latta (now
Chronister II)
2. 2019 – 2025 Budgeted Versus
Actual Jurisdictional Adjusted Rate
Base
3. 2022-2025 Total Company Capital
Investments
4. 2022-2025 O&M Expense
5. 2026 and 2027 Subsequent Year
Adjustment (SYA) Details
Ashley Sizemore 	TECO 	AS-1 	1. CETM Schedules for the period
2022 through 2024
2. CETM True Up for 2025
3. CETM Factors for 2025

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Witness 	Proffered
By
Description
Jordan Williams 	TECO 	JW-1 	1. List of Minimum Filing
Requirement Schedules Sponsored or
Co-Sponsored By Jordan Williams
David Dismukes, Ph.D. 	OPC 	DED-1 	Base Revenue Impact
David Dismukes, Ph.D. 	OPC 	DED-2 	Out-Of-Model Adjustments
David Dismukes, Ph.D. 	OPC 	DED-3 	Company Energy Sales and
Customer Forecasts
David Dismukes, Ph.D. 	OPC 	DED-4 	Revised Sales Forecast Based on a
Ten-Year Trend
David Dismukes, Ph.D. 	OPC 	DED-5 	Usage Per Customer Utility Survey
David Dismukes, Ph.D. 	OPC 	DED-6 	Forecast Variance Analysis
David Dismukes, Ph.D. 	OPC 	DED-7 	Energy Affordability Index
Lane Kollen 	OPC 	LK-1 	Resume of Lane Kollen
Lane Kollen 	OPC 	LK-2 	Response to OPC ROG 1, No. 37
Lane Kollen 	OPC 	LK-3 	Response to OPC ROG 1, No. 22,
OPC POD 10, No. 125
Lane Kollen 	OPC 	LK-4 	Response to OPC ROG 9, No. 167
Lane Kollen 	OPC 	LK-5 	Response to OPC ROG 1, Nos. 15 &
16
Lane Kollen 	OPC 	LK-6 	Response to OPC ROG 1, No. 17
Lane Kollen 	OPC 	LK-7 	Response to OPC ROG 1, No. 34
Lane Kollen 	OPC 	LK-8 	Response to OPC ROG 2, No. 56
Lane Kollen 	OPC 	LK-9 	Santee Cooper IRP
Lane Kollen 	OPC 	LK-10 	Lazard Report
Lane Kollen 	OPC 	LK-11 	Response to OPC ROG 4, No. 90
Lane Kollen 	OPC 	LK-12 	Response to OPC ROG 4, No. 89

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Witness 	Proffered
By
Description
Lane Kollen 	OPC 	LK-13 	2.19.24 Letter to Commission
Lane Kollen 	OPC 	LK-14 	Response to OPC ROG 4. No. 91
Lane Kollen 	OPC 	LK-15 	Response to OPC ROG 4, No. 83
Lane Kollen 	OPC 	LK-16 	SPP Gross-Up Calculation
Kevin J. Mara, P.E. 	OPC 	KJM-1 	Curriculum Vitae
Kevin J. Mara, P.E. 	OPC 	KJM-2 	Grip Reliability and Resiliency
Budgets 2024-2030
Bion C. Ostrander 	OPC 	BCO-1 	Regulatory Cases
Bion C. Ostrander 	OPC 	BCO-2 	OPC Adjustment to Affiliate
Expenses
Bion C. Ostrander 	OPC 	BCO-3 	TECO Discovery Responses
J. Randall Woolridge, Ph.D. 	OPC 	JRW-1 	Cost of Capital Recommendation
J. Randall Woolridge, Ph.D. 	OPC 	JRW-2 	Public Utility Capital Cost Indicators
J. Randall Woolridge, Ph.D. 	OPC 	JRW-3 	Summary Financial Statistics for
Proxy Groups, Value Line Risk
Metrics for Proxy Groups
J. Randall Woolridge, Ph.D. 	OPC 	JRW-4 	Capital Structure and Debt Cost
Rates
J. Randall Woolridge, Ph.D. 	OPC 	JRW-5 	DCF Study
J. Randall Woolridge, Ph.D. 	OPC 	JRW-6 	CAPM Study
J. Randall Woolridge, Ph.D. 	OPC 	JRW-7 	Tampa Electric Company’s Rate of
Return Recommendation
J. Randall Woolridge, Ph.D. 	OPC 	JRW-8 	Investment Firms’ Expected U.S.
Large Cap Equity Market Annual
Returns
J. Randall Woolridge, Ph.D. 	OPC 	JRW-9 	GDP and S&P 500 Growth Rates

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Witness 	Proffered
By
Description
Karl Rábago 	FL Rising/
LULAC
KRR-1 	Karl R. Rábago Resume
Karl Rábago 	FL Rising/
LULAC
KRR-2 	Rábago List of Prior Testimony
Karl Rábago 	FL Rising/
LULAC
KRR-3 	12 CP & 50% AD COS w/o Rev Def
Karl Rábago 	FL Rising/
LULAC
KRR-4 	12 CP & 50% AD COS w Rev Def
Karl Rábago 	FL Rising/
LULAC
KRR-5 	Residential Proposed Rates
MacKenzie Marcelin 	FL Rising/
LULAC
MM-1 	2023 Utility Average Monthly Bill
MacKenzie Marcelin 	FL Rising/
LULAC
MM-2 	TECO Answers to 1 st RFAs
MacKenzie Marcelin 	FL Rising/
LULAC
MM-3 	SACE EE in the SE
MacKenzie Marcelin 	FL Rising/
LULAC
MM-4 	Utility Energy Efficiency
Performance
MacKenzie Marcelin 	FL Rising/
LULAC
MM-5 	TECO EE Spending
Jeff Pollock 	FIPUG 	JP-1 	Authorized Return on Equity for
Vertically Integrated Electric
Utilities In Rate Cases Decided in
2023 and 2024
Jeff Pollock 	FIPUG 	JP-2 	Monthly System Peaks as a Percent
of the Annual System Peak
Jeff Pollock 	FIPUG 	JP-3 	TECO’s Response to Staff’s Sixth
Set of Data Requests in Docket No.
20210034-EI
Jeff Pollock 	FIPUG 	JP-4 	FIPUG’s Revised Class Cost-of-
Service Study

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Witness 	Proffered
By
Description
Jeff Pollock 	FIPUG 	JP-5 	Class Revenue Allocation Based on
FIPUG’s Revised Class Cost-of-
Service Study
Jeff Pollock 	FIPUG 	JP-6 	2025 Marginal Energy Costs by Hour
by Month
Jonathan Ly 	FIPUG 	JL-1 	Summary of TECO’s Future Solar
Projects Cost-Effectiveness Analysis
Jonathan Ly 	FIPUG 	JL-2 	Comparison of Natural Gas Forecasts
Jonathan Ly 	FIPUG 	JL-3 	Comparison of EIA Reference Case
Henry Hub Natural Gas Price
Forecasts
Christopher C. Walters 	FEA 	CCW-1 	Valuation Metrics
Christopher C. Walters 	FEA 	CCW-2 	Proxy Group
Christopher C. Walters 	FEA 	CCW-3 	Consensus Analysts’ Growth Rates
Christopher C. Walters 	FEA 	CCW-4 	Constant Growth DCF Model –
Consensus Analysts Growth Rates
Christopher C. Walters 	FEA 	CCW-5 	Payout Ratios
Christopher C. Walters 	FEA 	CCW-6 	Sustainable Growth Rate
Christopher C. Walters 	FEA 	CCW-7 	Constant Growth DCF Model –
Sustainable Growth Rate
Christopher C. Walters 	FEA 	CCW-8 	Multi-Stage Growth DCF Model
Christopher C. Walters 	FEA 	CCW-9 	Common Stock Market/Book Ratio
Christopher C. Walters 	FEA 	CCW-10 	Equity Risk Premium – Treasury
Bond
Christopher C. Walters 	FEA 	CCW-11 	Equity Risk Premium – Utility Bond
Christopher C. Walters 	FEA 	CCW-12 	Bond Yield Spreads
Christopher C. Walters 	FEA 	CCW-13 	Treasury and Utility Bond Yields

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Witness 	Proffered
By
Description
Christopher C. Walters 	FEA 	CCW-14 	Beta Analysis
Christopher C. Walters 	FEA 	CCW-15 	CAPM Return
Brian C. Andrews 	FEA 	BCA-1 	Account 312 Life Analysis
Brian C. Andrews 	FEA 	BCA-2 	Account 341 Life Analysis
Brian C. Andrews 	FEA 	BCA-3 	Account 342 Life Analysis
Brian C. Andrews 	FEA 	BCA-4 	Account 343 Life Analysis
Brian C. Andrews 	FEA 	BCA-5 	Select TD&G Account Net Salvage
Analyses
Brian C. Andrews 	FEA 	BCA-6 	FEA Proposed Depreciation Rates
Brian C. Andrews 	FEA 	BCA-7 	Comparison of TECO and FEA
Depreciation Rates and Expense
Devi Glick 	Sierra Club 	DG-1 	Resume of Devi Glick
Devi Glick 	Sierra Club 	DG-2 	TECO response to Sierra Club 1st
IRRs
Devi Glick 	Sierra Club 	DG-3 	TECO response to Sierra Club 2nd
IRRs
Devi Glick 	Sierra Club 	DG-4 	TECO response to Sierra Club 3rd
IRRs
Devi Glick 	Sierra Club 	DG-5 	TECO Ten-Year Site Plan, January
2024 – December 2033
Devi Glick 	Sierra Club 	DG-6 	U.S. Department of Energy and
Tampa Electric Company. 2000. The
Tampa Electric Integrated
Gasification Combined-Cycle
Project: An Update. Topical Report
Number 19
Devi Glick 	Sierra Club 	DG-7 	TECO response to SC IRR 1-8,
Attachment (BS 28921) 2018 – 2023
GFP.xlsx

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Witness 	Proffered
By
Description
Devi Glick 	Sierra Club 	DG-8 	TECO response to SC IRR 31,
Attachment (BS 28967) Sierra Club
1st Set 2024 - 2033 Firm Generators
and RM IRR Q31
Devi Glick 	Sierra Club 	DG-9 	EPA Memorandum, Steam Electric
Rulemaking Record – EPA-HQ-OW-
2009-0819. Unit-Level Costs and
Loadings Estimates for the 2024
Final Rule (DCN SE11756A1), April
22, 2024
Devi Glick 	Sierra Club 	DG-10 	EPA Memorandum, Steam Electric
Rulemaking Record – EPA-HQ-OW-
2009-0819. Generating Unit-Level
Costs and Loadings Estimates by
Regulatory Option for the 2024 Final
Rule (DCN SE11756), April 22,
2024
Devi Glick 	Sierra Club 	DG-11 	NERC, 2023 State of Reliability
Technical Assessment, June 2023
Devi Glick 	Sierra Club 	DG-12 	TECO response to SC IRR 8,
Attachment (BS 28923) 2019 - 2023
Factor and Rates
Devi Glick 	Sierra Club 	DG-13 	Schlissel, D. 2017. Using Coal
Gasification to Generate Electricity:
A Multibillion-Dollar Failure.
Institute for Energy Economics and
Financial Analysis
Devi Glick 	Sierra Club 	DG-14 	U.S. EPA. 2024 Update to the 2023
Proposed Technology Review for the
Coal- and Oil-Fired EGU Source
Category (2024 Technical Memo),
Attachment 1
Devi Glick 	Sierra Club 	DG-15 	Duke Energy, “Appendix F: Coal
Retirement Analysis,” 2023
Carolinas Resources Plan

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 137
Witness 	Proffered
By
Description
Devi Glick 	Sierra Club 	DG-16 	Institute for Energy Economics and
Financial Analysis, “Coal Use at U.S.
Power Plants Continues Downward
Spiral; Full Impact on Mines to be
Felt in 2024,” Nov. 2, 2023
Devi Glick 	Sierra Club 	DG-17 	Earthjustice, “Toxic Coal Ash in
Florida: Addressing Coal Plants’
Hazardous Legacy,” May 3, 2023
Devi Glick 	Sierra Club 	DG-18 	U.S. Department of Energy, Loan
Programs Office, Program Guidance
for Title 17 Clean Energy Financing
Program, May 19, 2023
Devi Glick 	Sierra Club 	DG-19 	C. Fong, D. Posner, and U.
Veradarajan, “The Energy
Infrastructure Reinvestment
Program: Federal financing for an
equitable, clean economy,” RMI,
February 16, 2024
Devi Glick 	Sierra Club 	DG-20 	C. Fong, D. Posner, and U.
Varadarajan, “Maximizing the value
of the energy infrastructure
reinvestment program for utility
customers,” RMI, May 24, 2024
Steve W. Chriss 	FRF
Walmart
SWC-1 	Qualifications of Steve W. Chriss
Steve W. Chriss 	FRF
Walmart
SWC-2 	Impact of TECO’s Proposed Increase
in Return on Equity ($000) vs.
Originally Approved
Steve W. Chriss 	FRF
Walmart
SWC-3 	Impact of TECO’s Proposed Increase
in Return on Equity ($000) vs. ROE
Trigger
Steve W. Chriss 	FRF
Walmart
SWC-4 	Reported Authorized Returns on
Equity, Electric Utility Rate Cases
Completed, 2021 to Present

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 138
Witness 	Proffered
By
Description
Steve W. Chriss 	FRF
Walmart
SWC-5 	Impact of TECO’s Proposed Increase
in Return on Equity ($000) vs.
National Average, Vertically
Integrated.
Tomer Kopelovich 	Staff 	TK-1 	Revised Auditor’s Report
Angela L. Calhoun 	Staff 	ALC-1 	List of Service Complaints
Angela L. Calhoun 	Staff 	ALC-2 	List of Billing Complaints (amended
pages)
Angela L. Calhoun 	Staff 	ALC-3 	List of Warm Transfers
Rebuttal
Carlos Aldazabal 	TECO 	CA-2 	1. Tampa Electric’s Answer to
OPC’s First Set of Interrogatories,
No. 37
2. 2022 Fuel Savings Associated with
Using Coal
Kris Stryker 	TECO 	KS-2 	1. NREL: Best Practices Handbook
for the Collection and Use of Solar
Resource Data for Solar Energy
Applications: Second Edition
Jose Aponte 	TECO 	JA-2 	1. Low Fuel Forecast Solar Cost-
Effectiveness Test
2. High Fuel Forecast Solar Cost-
Effectiveness Test
3. Solar Cost-Effectiveness Test
Capacity Factor Sensitivity
Chip Whitworth 	TECO 	CW-2 	1. Historical Transformer Failures
2. Historical Transformer Purchases
3. Order No. PSC-2020-0224-AS-EI

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Witness 	Proffered
By
Description
Lori Cifuentes 	TECO 	LC-2 	1. Detailed Calculations of Energy
Efficiency Out-of-Model
Adjustments
2. Detailed Calculations of Electric
Vehicle Charging Out-of-Model
Adjustments
3. Detailed Calculations of Private
Rooftop Solar Out-of-Model
Adjustments
4. Florida Utilities 2010-2027
Residential Usage Per-Customer
Growth Trends
5. Florida Utilities – Usage Per-
Customer Utility Survey
6. Historical Forecast Accuracy
7. Total Retail Energy Sale (June
2023 - May 2024)
Ned Allis 	TECO 	NA-2 	1. Document No. 1
2. Document No. 2
3. Document No. 3
Dylan D’Ascendis 	TECO 	DWD-2 	1. Updated ROE Analysis
2. D’Ascendis Indicated Return
Histogram
3. Retention Ratio Regression
Analysis
4. Growth Rate Regression Analysis
5. Dr. Woolridge Corrected DCF
Results
6. Comparison of Market Return
Measures
7. Hypothetical Example: Flotation
Cost Recovery
8. Observed Market Returns and
Frequency Distributions of Observed
Market Returns (1926-2023)
9. Historical Market Returns (2014-
2023)
10. Safety Ranking Analysis for
Utility Proxy Group and Non-
Regulated Proxy Group
11. Walters Indicated Return

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Witness 	Proffered
By
Description
Histogram
12. Electric Rate Case Common
Equity Ratios (2016-2024)
13. Gross Domestic Product by
Industry
14. Market-to-Book Ratios, Earnings
to Book Ratios and Inflation for S&P
Industrial Index and the S&P 500
Composite Index (1947-2023)
15. Walters Corrected Risk Premium
Model
16. Walters’ Market DCF Exclusions
Summary
17, Walters Corrected CAPM
18. Rate Adjustment Clauses
Allowed For Electric Proxy Group
Companies
19. Referenced Endnotes for the
Prepared Direct Testimony of Dylan
W. D’Ascendis
John Heisey 	TECO 	JH-2 	1. Average Natural Gas Forecast at
Henry Hub
2. LNG Export Growth
3. Data Center Growth
Valerie Strickland 	TECO 	VS-2 	1. 3-year life – Battery Storage ITC –
2025 Test Year
2. 3-year life – Battery Storage ITC –
SYA 2026 and 2027
Jeff Chronister 	TECO 	JC-3 	1. Notice of Substitution of Witness
2. Dismantlement Calculations
3. Audit Finding Responses

ORDER NO. PSC-2024-0351-PHO-EI
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Witness 	Proffered
By
Description
Jordan Williams 	TECO 	JW-2 	1. TECO_TOD_Workpapers
Marginal Energy Costs
2. 2024 Ten Year Site Plan Marginal
Energy Costs
3. GSLDTPR Demand Percentage
4. EIA Home Heating Source
5. EIA Whole Home Energy Costs
6. EIA State Data
7. Energy Burden Chart
8. Composite Notice
X. 	PROPOSED STIPULATIONS
There are no proposed stipulations at this time.
XI. 	PENDING MOTIONS
During 	this 	Prehearing 	Conference, 	OPC 	made 	an 	ore 	tenus 	Motion 	Requesting
Extension of Time to Provide Exhibits. OPC argues that it lost a few days time to prepare cross-
examination exhibits due to Hurricane Debby. OPC states that providing additional time to
comply will allow it to focus more and will translate into a reduction of extraneous documents
marked as exhibits.
In light of the delay caused by Hurricane Debby and the benefits articulated by OPC, I
find there is good cause to modify the OEP, Order No. PSC-2024-0096-PCO-EI, and set a new
Provision 	of 	Exhibits 	deadline. 	With 	the 	exception 	of 	deposition 	transcripts 	used 	for
impeachment 	exhibits, 	which 	will 	be 	discussed 	further 	below, 	all 	cross-examination,
demonstrative, and impeachment exhibits, except for deposition transcripts, shall be exchanged
between the parties and Staff by the close of business on Thursday, August 15, 2024, using the
process set out in the OEP.
Deposition transcripts used for impeachment purposes only are no longer required to be
exchanged between the parties and Staff. Deposition transcripts that are used for impeachment
purposes will not be loaded into Case Center. Section VII, Part I, of the OEP, still applies to
those deposition transcripts that parties seek to admit into the record.
In 	addition, 	it 	appears 	questions 	remain 	concerning 	the 	Provision 	of 	Exhibits
requirements of the OEP. By Section VII, Part G, of the OEP, the Commission intended to
require all parties and Staff to exchange exhibits prior to the hearing so that all hearing
participants are on notice of all exhibits to be used during the hearing. Notice prior to the hearing

ORDER NO. PSC-2024-0351-PHO-EI
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PAGE 142
remains the intent and is the reason for the Exhibit List required by Section VII, Part G, of the
OEP.
The following clarifications are offered to assist the parties in preparing for the final
hearing:
 	Parties may use the exhibits identified by Staff on the Comprehensive Exhibit List
(CEL) for cross-examination purposes without listing them on the party’s exhibit list
or exchanging the exhibit with the other parties. Thus, for example, a Staff Exhibit on
the CEL may be used by any party, and should not be duplicated on another party’s
exhibit list or provided in the exchange if the party intends to use that previously
identified exhibit.
 	All hearing participants are already on notice of all prefiled testimony and exhibits.
Thus, no prefiled testimony or prefiled exhibits should be listed on any party’s exhibit
list or exchanged.
 	Parties are not required to submit an exhibit in Excel format if you are satisfied that a
witness can view the PDF conversion of the spreadsheet; please check the PDF
version to ensure legibility. However, if an Excel spreadsheet is submitted in native
format, the party must also submit a PDF conversion of the exhibit using the same
exhibit name. (i.e., OPC-1 Short Title.pdf and OPC-1 Short Title.xls).
 	Parties are not required to create a separate PDF file or exhibit for each Interrogatory
response. 	Several 	responses 	and 	attachments 	can 	be 	combined 	into 	one 	PDF
document and submit it as one composite exhibit. If a party submits an attachment
separately, the attachment must be numbered as a separate exhibit.
 	The exchange of cross-examination exhibits prior to hearing is consistent with Florida
law and is to afford due process to all parties by avoiding “trial by surprise.” The
Commission expects all parties to respect the process by being judicious about the
cross-examination exhibits provided. Parties should have a reasonable, good faith
expectation of using the exhibit during the hearing.
After the Prehearing Conference, on August 9, 2024, OPC filed a Motion and Notice of
Intent to Seek Official Recognition.
XII. 	PENDING CONFIDENTIALITY MATTERS
TECO
Date Filed 	Type 	Subject Matter
April 11, 2024 	MTPO 	OPC’s 1st IRR & 1st POD
April 17, 2024 	MTPO 	OPC’s 2nd IRR & 2nd POD
April 19, 2024 	MTPO 	OPC’s 2nd IRR & 2nd POD
April 22, 2024 	RCC & MTPO 	OPC’s 2nd POD
April 22, 2024 	MTPO 	OPC’s 1st POD
April 26, 2024 	RCC & MTPO 	OPC’s 1st IRR & 1st POD

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April 30, 2024 	RCC & MTPO 	OPC’s 1st POD
May 2, 2024
Amended August 2, 2024 RCC & MTPO 	LULAC’s 1st POD
May 8, 2024 	RCC & MTPO 	OPC’s 6th POD
May 13, 2024 	MTPO 	OPC’s 4th POD
May 13, 2024 	RCC 	OPC’s 4th POD
May 20, 2024 	RCC & MTPO 	OPC’s 10th POD
July 1, 2024 	Amended RCC & MTPO 	OPC’s 1st POD
July 1, 2024 	Amended RCC & MTPO 	OPC’s 10th IRR & 11th POD
July 12, 2024 	RCC & MTPO 	LULAC’s 9th POD
July 22, 2024 	RCC & MTPO
John C. Heisey's Exhibit JCH-1,
page 3 of 3, for the period January
2023 – December 2023, filed on
April 3, 2024, in Docket No.
20240001-EI
July 26, 2024 	MTPO July 22, 2024, Deposition
Transcript of Carlos Aldazabal
July 29, 2024 	MTPO July 26, 2024, Deposition
Transcript of Archie Collins
July 30, 2024 	RCC & MTPO
Late Filed Exhibit No. 2 to the
Deposition Transcript of Archie
Collins
July 31, 2024 	RCC & MTPO
Late Filed Exhibit No. 2 to the
Deposition Transcript of David
Lukcic
August 1, 2024 	RCC July 22, 2024, Deposition
Transcript of Carlos Aldazabal
August 2, 2024 	RCC & MTPO LULAC’s 1st POD
Amended Exhibit A
August 8, 2024 	RCC & MTPO Exhibits 1 & 2 to the Report on
Customer Services Hearings
XIII. 	POST-HEARING PROCEDURES
If no bench decision is made, each party shall file a post-hearing statement of issues and
positions. A summary of each position, set off with asterisks, shall be included in that statement.
If a party's position has not changed since the issuance of this Prehearing Order, the post-hearing
statement may simply restate the prehearing position; however, if the prehearing position is
longer than 75 words, it must be reduced to no more than 75 words. If a party fails to file a post-
hearing statement, that party shall have waived all issues and may be dismissed from the
proceeding.

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Pursuant to Rule 28-106.215, F.A.C., a party's proposed findings of fact and conclusions
of law, if any, statement of issues and positions, and brief, shall together total no more than 75
pages and shall be filed at the same time.
XIV. 	RULINGS
Opening statements, if any, shall not exceed five minutes per party.
Witness summary testimonies shall not exceed seven minutes total, for both direct and
rebuttal combined.
The Provision of Exhibits deadline contained in Section X of the Order Establishing
Procedure and Consolidating Dockets, Order No. PSC-2024-0096-PCO-EI, is extended to
August 15, 2024, by close-of-business.
It is therefore,
ORDERED by Commissioner Gary F. Clark, as Prehearing Officer, that this Prehearing
Order shall govern the conduct of these proceedings as set forth above unless modified by the
Commission.
By ORDER of Commissioner Gary F. Clark, as Prehearing Officer, this 14th day of
August, 2024.
GARY F. CLARK
Commissioner and Prehearing Officer
Florida Public Service Commission
2540 Shumard Oak Boulevard
Tallahassee, Florida 32399
(850) 413-6770
www.floridapsc.com
Copies furnished: A copy of this document is
provided to the parties of record at the time of
issuance and, if applicable, interested persons.
CMM

ORDER NO. PSC-2024-0351-PHO-EI
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NOTICE OF FURTHER PROCEEDINGS OR JUDICIAL REVIEW
The Florida Public Service Commission is required by Section 120.569(1), Florida
Statutes, to notify parties of any administrative hearing or judicial review of Commission orders
that is available under Sections 120.57 or 120.68, Florida Statutes, as well as the procedures and
time limits that apply. This notice should not be construed to mean all requests for an
administrative hearing or judicial review will be granted or result in the relief sought.
Mediation may be available on a case-by-case basis. 	If mediation is conducted, it does
not affect a substantially interested person's right to a hearing.
Any party adversely affected by this order, which is preliminary, procedural, or
intermediate in nature, may request: (1) reconsideration within 10 days pursuant to Rule 25-
22.0376, Florida Administrative Code; or (2) judicial review by the Florida Supreme Court, in
the case of an electric, gas, or telephone utility. A motion for reconsideration shall be filed with
the 	Office 	of 	Commission 	Clerk, 	in 	the 	form 	prescribed 	by 	Rule 	25-22.0376, 	Florida
Administrative Code. Judicial review of a preliminary, procedural, or intermediate ruling or
order is available if review of the final action will not provide an adequate remedy. Such review
may be requested from the appropriate court, as described above, pursuant to Rule 9.100, Florida
Rules of Appellate Procedure.