Florida Public Service Commission native order document 08203-2024

FILED 8/2/2024
DOCUMENT NO. 08203-2024
FPSC - COMMISSION CLERK
BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
In re: Commission review of numeric
conservation goals (Florida Power & Light
Company).
In re: Commi ssion review of numeric
conservation goals (Duke Energy Florida,
LLC).
In re: Commi ssion review of numeric
con servation goals (Tampa Electric Company).
In re: Commission review of numeric
conservation goals (Florida Public Utilities
Company).
In re: Commi ssion review of numeric
con servation goals (JEA).
In re: Commission review of numeric
conservation goals (Orlando Utilities
Commission).
DOCKET NO. 20240012-EG
DOCKET NO. 20240013-EG
DOCKET NO. 20240014-EG
DOCKET NO. 20240015-EG
DOCKET NO. 20240016-EG
DOCKET NO. 20240017-EG
ORDER NO. PSC-2024-0293-PHO-EG
ISSUED: August 2, 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 July 23 , 2024, in Tallahassee, Florida, before
Commissioner Art Graham, as Prehearing Officer.
APPEARANCES:
CHRISTOPHER 	T. 	WRIGHT 	and 	WILLIAM 	P . 	COX , 	ESQUIRES , 	700
Universe Boulevard, Juno Beach, Florida 33408-0420
On behalf of Florida Power & Light Company (FPL).
DIANNE 	M. TRIPLETT, 	MATTHEW R. 	BERNIER and STEPHANIE 	A.
CUELLO , ESQUIRES , 299 First Avenue North, St. Petersburg, Florida 33701
On behalf of Duke Energy Florida, LLC {DEF).

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 2
J. JEFFRY WAHLEN, MALCOLM N. MEANS and VIRGINIA PONDER,
ESQUIRES, Ausley & McMullen, Post Office Box 391, Tallahassee, Florida
32302
On behalf of Tampa Electric Company (TECO).
BETH KEATING, ESQUIRE, Gunster, Yoakley & Stewart, P.A., 215 South
Monroe Street, Suite 601, Tallahassee, Florida 32301
On behalf of Florida Public Utilities Company (FPUC).
GARY V. PERKO, MOHAMMAD O. JAZIL and VALERIE L. CHARTIER-
HOGANCAMP, ESQUIRES, Holtzman, Vogel, Baran, Torchinsky & Josefiak,
PLLC, 119 South Monroe Street, Suite 500, Tallahassee, Florida 32301
On behalf of JEA (JEA).
ROBERT 	SCHEFFEL 	WRIGHT 	and 	JOHN 	T. 	LAVIA, 	III, 	ESQUIRES,
Gardner, Bist, Bowden, Dee, LaVia, Wright, Perry & Harper, P.A., 1300
Thomaswood Drive, Tallahassee, Florida 32308
On behalf of Orlando Utilities Commission (OUC).
SEAN T. GARNER, ERIK SAYLER and KELLY WRIGHT, ESQUIRES,
Florida Department of Agriculture & Consumer Service, Office of General
Counsel, The Mayo Building, 407 S. Calhoun Street, Suite 520, Tallahassee,
Florida 32399-0800
On behalf of Florida Department of Agriculture & Consumer Services (FDACS).
JON C. MOYLE, JR. and KAREN A. PUTNAL, ESQUIRES, Moyle Law Firm,
P.A., 118 North Gadsden Street, Tallahassee, Florida 32301
On behalf of Florida Industrial Power Users Group (FIPUG).
BRADLEY 	MARSHALL 	and 	JORDAN 	LUEBKEMANN, 	ESQUIRES,
Earthjustice, 111 S. Martin Luther King Jr. Blvd., Tallahassee, Florida 32301
On behalf of Florida Rising, Inc. (FL Rising), Environmental Confederation of
Southwest Florida (ECOSWF) and League of United Latin American Citizens
(LULAC).
PETER J. MATTHEIS, MICHAEL K. LAVANGA and JOSEPH R. BRISCAR,
ESQUIRES, Stone, Mattheis, Xenopoulos & Brew, PC, 1025 Thomas Jefferson
Street, NW, Eighth Floor, West Tower, Washington, DC 20007
On behalf of Nucor Steel Florida, Inc. (Nucor).

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 3
JAMES W. BREW, LAURA WYNN BAKER and SARAH B. NEWMAN,
ESQUIRES, Stone, Mattheis, Xenopoulos & Brew, PC, 1025 Thomas Jefferson
Street, NW, Eighth Floor, West Tower, Washington, DC 20007
On behalf of White Springs Agricultural Chemicals, Inc. d/b/a PCS Phosphate –
White Springs (PCS Phosphate).
WILLIAM C. GARNER, ESQUIRE, Law Office of William C. Garner, PLLC,
3425 Bannerman Road, Unit 105, No. 414, Tallahassee, Florida 32312
On behalf of Southern Alliance for Clean Energy (SACE).
STEPHANIE U. EATON, ESQUIRE, Spilman, Thomas & Battle, PLLC, 110
Oakwood Drive, Suite 500, Winston-Salem, North Carolina 27103
STEVEN W. LEE, ESQUIRE, Qualified Representative, Spilman, Thomas &
Battle, PLLC, 1100 Bent Creek Blvd., Suite 101, Mechanicsburg, Pennsylvania
17050
On behalf of Walmart, Inc. (Walmart).
JACOB IMIG and JON RUBOTTOM, ESQUIRES, Florida Public Service
Commission, 2540 Shumard Oak Boulevard, Tallahassee, Florida 32399-0850
On behalf of the Florida Public Service Commission (Staff).
MARY ANNE HELTON, ESQUIRE, Deputy General Counsel, Florida Public
Service Commission, 2540 Shumard Oak Boulevard, Tallahassee, Florida 32399-
0850
Advisor to the Florida Public Service Commission.
KEITH C. HETRICK, ESQUIRE, General Counsel, Florida Public Service
Commission, 2540 Shumard Oak Boulevard, Tallahassee, Florida 32399-0850
Florida Public Service Commission General Counsel
I. 	CASE BACKGROUND
On 	January 	5, 	2024, 	Docket 	Nos. 	20240012-EG, 	20240013-EG, 	20240014-EG,
20240015-EG, 20240016-EG, and 20240017-EG were established to review and adopt the
corresponding utility’s conservation goals pursuant to Sections 366.80-366.83 and 403.519,
Florida Statutes. (F.S.), known collectively as the Florida Energy Efficiency and Conservation
Act (FEECA). By the Order Consolidating Dockets and Establishing Procedure, Order No. PSC-
2024-0022-PCO-EG, issued January 23, 2024 (OEP), the dockets were consolidated for purposes
of hearing, and controlling dates were established. The OEP was subsequently modified by the
First Order Modifying Order Establishing Procedure, Order No. PSC-2024-0159-PCO-EG,
issued May 17, 2024. The matter has been scheduled for a formal hearing from August 6, 2024,
through August 9, 2024.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 4
II. 	CONDUCT OF PROCEEDINGS
Pursuant to Rule 28-106.211, F.A.C., this Prehearing Order is issued to prevent delay and
to promote the just, speedy, and inexpensive determination of all aspects of this case.
III. 	JURISDICTION
This Commission is vested with jurisdiction over the subject matter by the provisions of
Chapter 366, Florida Statutes (F.S.). 	This hearing will be governed by said Chapter and
Chapters 25-17, 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
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.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 5
(2) 	Counsel and witnesses are cautioned to avoid verbalizing confidential information
in such a way that would compromise confidentiality. 	Therefore, confidential
information should be presented by written exhibit when reasonably possible.
At the conclusion of that portion of the hearing that involves confidential information, all
copies of confidential exhibits shall be returned to the proffering party. If a confidential exhibit
has been admitted into evidence, the copy provided to the court reporter shall be retained in the
Office of Commission Clerk’s confidential files. If such material is admitted into the evidentiary
record at hearing and is not otherwise subject to a request for confidential classification filed
with the Commission, the source of the information must file a request for confidential
classification of the information within 21 days of the conclusion of the hearing, as set forth in
Rule 25-22.006(8)(b), F.A.C., if continued confidentiality of the information is to be maintained.
V. 	PREFILED TESTIMONY AND EXHIBITS; WITNESSES
Testimony of all witnesses to be sponsored by the parties (and Staff) has been prefiled
and will be inserted into the record as though read after the witness has taken the stand and
affirmed the correctness of the testimony and associated exhibits. All testimony remains subject
to timely and appropriate objections. Upon insertion of a witness' testimony, exhibits appended
thereto may be marked for identification. 	Each witness will have the opportunity to orally
summarize his or her testimony at the time he or she takes the stand. 	Summaries of testimony
shall be limited to three minutes.
Witnesses are reminded that, on cross-examination, responses to questions calling for a
simple yes or no answer shall be so answered first, after which the witness may explain his or her
answer. 	After all parties and Staff have had the opportunity to cross-examine the witness, the
exhibit may be moved into the record. All other exhibits may be similarly identified and entered
into the record at the appropriate time during the hearing.
The Commission frequently administers the testimonial oath to more than one witness at
a time. 	Therefore, when a witness takes the stand to testify, the attorney calling the witness is
directed to ask the witness to affirm whether he or she has been sworn.
The parties shall avoid duplicative or repetitious cross-examination. Further, friendly
cross-examination will not be allowed. 	Cross-examination shall be limited to witnesses whose
testimony is adverse to the party desiring to cross-examine. Any party conducting what appears
to be a friendly cross-examination of a witness should be prepared to indicate why that witness's
direct testimony is adverse to its interests.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 6
VI. 	ORDER OF WITNESSES
Each witness whose name is preceded by an asterisk (*) is excused from the hearing.
Each witness whose name is preceded by a plus sign (+) will present direct and rebuttal
testimony together.
Witness 	Proffered By 	Issues #
Direct
*Tim Duff 	DEF 	1-7, 12-13
Jim Herndon 	FPL
DEF
TECO
FPUC
JEA
OUC
1
1-2, 7
1
1-5, 7
1-4, 7, 12-13
1-7, 12-13
+John F. Floyd 	FPL 	2-5, 7-13
+Andrew W. Whitley 	FPL 	3-7, 12-13
+Mark R. Roche 	TECO 	1-8, 12-13
*Derrick M. Craig 	FPUC 	1-6, 8, 12-13
*Michael T. Clark 	FPUC 	2
+Brian Pippin 	JEA 	1-8, 12-13
Bradley E. Kushner
Unavailable on 8/6
JEA
OUC
1, 3-5
3, 6, 12
+Kevin M. Noonan 	OUC 	1-5, 7, 12
*Jeff Pollock 	FIPUG 	3-4, 8, 12
*MacKenzie Marcelin 	FL Rising/ECOSWF/
LULAC
1-5, 7-9, 12
*Tony Georgis 	Nucor/PCS Phosphate 	2-5, 8, 12
*Steven W. Chriss 	Walmart 	3-4, 8A, 8B, 12

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 7
Witness 	Proffered By 	Issues #
Rebuttal
*Tim Duff 	DEF 	1-7, 12-13
+John F. Floyd 	FPL 	2-5, 7-9
+Andrew W. Whitley 	FPL 	3-5, 7
+Mark R. Roche 	TECO 	1-5, 7-8, 12
+Brian Pippin 	JEA 	12
+Kevin M. Noonan 	OUC 	1-5, 7, 12
VII. 	BASIC POSITIONS
FPL: 	Pursuant to the Florida Energy Efficiency and Conservation Act (FEECA) and
Rules 25- 17.001, 25-17.0021, and 25-17.008, Florida Administrative Code, FPL
has proposed numeric conservation Goals for reasonably achievable demand
savings and annual energy savings for the next ten years. As required by Rule 25-
17.0021(3), FPL’s proposed DSM Goals are based upon FPL’s most recent
planning process, used both the Participant and RIM test scenario and the
Participant and TRC test scenario, and considered the effects of free riders and
building codes and appliance efficiency standards.
FPL followed a rigorous, six-step analytical process similar to the process it has
used in past DSM Goal-setting proceedings to develop its DSM Goals. FPL’s
analyses demonstrate that FPL’s proposed DSM Goals are 419 megawatts (MW)
Summer demand, 326 MW Winter demand, and 931 gigawatt-hours (GWh) energy
reduction are reasonable and appropriate for serving FPL’s customers for the
2025-2034 DSM Goals period.
After careful analysis, FPL recommends goals for the period 2025-2034 that
reflect 	continuation 	of 	its 	current 	portfolio 	of 	energy-efficiency 	and 	load-
management programs, expansion of the existing low-income weatherization
program, and introduction of a new low- income Renter Pilot. FPL’s proposal
also includes expansion of the On Call ® load-management program with a new
“HVAC 	On-Bill 	Option.” 	This 	new 	option 	expands 	the 	On 	Call ® 	load-
management program, which has been approved by the Commission and been in
place since 1986, to allow greater customer access to new energy-saving HVAC

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 8
equipment in a way that also passes the RIM cost-effectiveness test. 	Under this
program, a customer will receive a new efficient HVAC unit that FPL will have
the ability to control in peak demand situations. Collectively, FPL’s proposed
DSM programs focus on the highest priorities of weather-sensitive peak demand,
continue to provide customer incentives for making energy-efficient investments,
and can be delivered with little to no incremental bill impact to customers.
FEL was the only party to take a position on FPL’s proposed 2025-2034 DSM
Goals. FEL opposes the use of the two-year-payback screening criterion but does
not offer an alternative method to screen the impacts of free riders as required by
Rule 25-17.0021(3). 	The two-year payback criterion is a reasonable mechanism
previously approved by the Commission to screen out measures that already have
a reasonable economic payback without any DSM incentive.
FEL recommends expanding FPL’s low-income programs to match Tampa
Electric Company’s (TECO) proposals on a per-capita basis – specifically,
reaching 	6.92 	times 	as 	many 	low-income 	customers 	as 	TECO. 	FEL 	also
recommends increasing FPL’s residential HVAC program enrollment target to
150,000 customers per year. FEL questions the proposed cap on the incentive to
be available under FPL’s proposed Low Income Renter Pilot, and whether the
costs of the upgraded appliance will be shifted from the landlord to the tenant.
Finally, FEL proposes that the credits for the CILC and CDR programs be cut by
at least half. The Commission previously determined that these credits would be
addressed in FPL’s next base rate case (per FPL’s Commission-approved 2021
Settlement Agreement).
FEL’s recommendations are not based on any assessment of the technical
potential of energy-efficiency measures, any cost-effectiveness analyses, nor any
cost, rate, or bill impact analyses. 	FEL’s proposals are not consistent with
Commission’s DSM Goals rules and overlook that this is not the appropriate
proceeding to reset the CILC and CDR credits due to FPL’s approved 2021 base
rate case settlement. Moreover, FEL’s proposals would result in significant rate
impacts to all of FPL’s customers, including low-income customers, renters, and
customers who are unable to participate in DSM programs. For these reasons, as
further 	explained 	in 	FPL’s 	rebuttal 	testimonies 	and 	exhibits, 	FEL’s
recommendations should be rejected.
For all the reasons discussed above, and as explained in more detail in the direct
and rebuttal testimony provided by its witnesses, FPL’s proposed DSM Goals
should be approved. FPL’s proposal complies with the requirements of Section
366.82, Florida Statutes, complies with Rules 25-17.0021 and 25-17.008, Florida
Administrative 	Code, 	and 	will 	establish 	DSM 	goals 	at 	a 	reasonable 	and
appropriate level given current projections of FPL system costs while continuing
to maintain low electric rates for all FPL customers.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 9
DEF: 	DEF has been offering energy efficiency programs and measures to its customers
for more than 35 years. In addition, changes in building codes, federal baseline
standards and economic conditions have increased the amount of efficiency that
customers are undertaking on their own, without incentive from the utility. These
factors over time will reduce the number of programs and measures that DEF can
cost-effectively 	offer 	its 	customers. 	Accordingly, 	the 	ten-year 	proposed
conservation goals set forth in the testimony of DEF witness Tim Duff are based
upon DEF’s most recent planning process of the total, cost-effective, winter and
summer peak demand (MW) and annual energy (GWH) savings reasonably
achievable in the residential and commercial/industrial classes through demand
side management. DEF’s projections of summer and winter demand savings,
annual energy savings, and participants reflect consideration of overlapping
measures, rebound effects, free riders, effects of changes to building codes and
appliance efficiency standards, and DEF’s evaluation of conservation programs
and measures.
The Company’s updated proposed Recommended goals are based on a collection
of programs and underlying measures that pass the Participant, Total Resource
Cost (“TRC”) and Rate Impact Measure (“RIM”) tests, with the exception of a
few measures included in programs targeting low-income customers. Specifically,
DEF is updating and proposing a goal of 373 MW of winter peak demand
reduction, 300 MW of summer peak demand reduction, and 582 GWh of energy
reduction over the 2025-2034 time period. The updated proposed cost-effective
DSM goals meet the requirements of Chapter 25-17, Florida Administrative Code
(F.A.C.). DEF proposes that the Commission set DSM goals based on programs
including measures that pass the PCT, TRC and RIM tests, because these tests are
well-balanced and ensure that the perspectives of participants and all other
ratepayers (including non-participants) are fairly considered.
The Commission should approve DEF’s overall Residential MW and GWh goals
and overall commercial/industrial MW and GWh goals set forth in Mr. Duff’s
testimony. 	These 	goals 	reflect 	the 	reasonably 	achievable 	demand 	side
management potential in DEF’s service territory over the ten-year period 2025-
2034 developed in DEF’s planning process.
In 	accordance 	with 	the 	2024 	Settlement 	Agreement 	filed 	in 	Docket 	No.
20240025-EI and the Joint Notice of Necessary Stipulations filed in this docket on
July 15, 2024, DEF has entered into Stipulations on Issue 8b and Issue 12 with the
signatories. If the Commission approves the proposed stipulations on Issues 8b
and 12, DEF is agreeable to Type 2 stipulations on all remaining issues, with the
exception of Issue 8a. 	If the Commission does not approve the proposed
stipulations as set forth in the Joint Notice, DEF reserves the right to reinstate its
original position on these issues as detailed in the Statement on Specific Issues
below.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 10
TECO: 	Based on the analysis performed by Tampa Electric for this current demand side
management ("DSM") goals setting process, the company's proposed reasonably
achievable generator level DSM goals for the 2025-2034 period are 149.0 MW of
summer demand savings, 197.1 MW of winter demand savings, and 450.5 GWh
of annual energy savings. These amounts are detailed on an annual basis for both
the residential and commercial/industrial sectors in Document No. 1 of the
Exhibit of Mr. Mark R. Roche (MRR-1).
The recommended adjustments to Tampa Electric’s proposed DSM program
participation and goals by Florida Rising, League of United Latin American
Citizens (“LULAC”), and Environmental Confederation of Southwest Florida
(“ECOSWF”) are mainly based upon opinions with no factual basis or a full
understanding of the underlying reasons and basis for the company’s proposed
participation levels that were used to develop Tampa Electric’s proposed DSM
goals and programs for the 2025-2034 period.
FPUC: 	FPUC’s proposed conservation goals for the 2025-2034 period, as described in
the testimony of FPUC’s witness Derrick M. Craig, are based upon FPUC’s most
recent planning process and reflect the total winter and summer peak demand and
annual energy savings reasonably achievable in the Company’s residential and
commercial/industrial classes through cost-effective demand side management.
They adequately reflect the costs and benefits to customers participating in DSM
measures, as well as the Company’s general body of ratepayers. Consistent with
the FEECA statute, the Company’s goals also give appropriate consideration to
the need for incentives to promote efficiency and renewable systems. 	As such,
FPUC’s proposed goals are consistent with FEECA.
FPUC’s proposed goals are also supported by the testimony and supporting
exhibits of Resource Innovations’ representative Jim Herndon. 	As part of a
collaborative process, Resource Innovations was retained by the FEECA utilities
for the purpose of assessing the technical potential for energy efficiency, demand
response, and demand-side renewable energy resources for reducing residential,
commercial, and industrial customer electric demand and seasonal peak capacity
demands. Resource Innovations also provided an economic analysis for a subset
of FEECA utilities, which included FPUC, and thereafter provided the Company
with a complete Technical Potential Study (TPS) that is filed with Mr. Herndon’s
Direct Testimony as Exhibit JH-5. 	In conducting the technical potential test,
which serves as the foundation for assessing the economic and achievable
potential, Resource Innovations included the full application of DSM technologies
commercially available to all residential, commercial, and industrial customers in
FPUC’s territory to determine which measures are cost-effective in which
circumstances, and to develop estimates of the potential impacts of adopting these
measures. The assessment utilized a current utility forecast, supported in this
proceeding FPUC consultant, Michael Ty Clark of Christensen Associates Energy

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 11
Consulting LLC. 	Using its proprietary TEA-POT model, Resource Innovations
considered a wide range of energy efficiency and demand response measures, as
well as rooftop solar photovoltaic systems, battery storage systems, and combined
heat and power systems screening for the required sensitivities. The results of this
analysis reflect that no energy efficiency measures passed the RIM test, and there
are no demand reduction measures or demand-side renewable energy systems that
are cost-effective for FPUC.
FPUC’s proposed DSM goals are based on the TRC scenario with a 2-year
minimum payback screen applied. These figures represent a 10-year goal time
frame. The total achievable residential potential is 5.1 GWh, commercial potential
is 4.3 GWh, and industrial potential is 2.5 GWh, resulting in a total 10-year goal
of 11.8 GWh. The achievable summer peak MW savings are 1.0 MW for
residential, 0.7 MW for commercial, and 0.3 MW for industrial, totaling 2.0 MW
for the Company’s system. FPUC's achievable winter potential for residential
savings is 1.2 MW, 0.7 MW for commercial, 0.3 MW for industrial, and a total of
2.2 MW for the system. There were no cost-effective demand response measures
for FPUC, nor did the study reflect any achievable potential for either commercial
or residential demand-side renewable technologies.
FPUC therefore proposes that its reasonably achievable goals for the period
covering 2025 to 2034 are as follows: The proposed 10-year goal for residential
energy efficiency is 3.8 GWh; for non-residential/commercial the proposed goal
is 2.3 GWh; and the total proposed energy efficiency goal of 6.1 GWh. For
summer MW goals, the Company proposes a residential target of 2.58 MW; a
non-residential/commercial target of 0.35 MW; and a cumulative total goal of
0.93 MW. 	The proposed achievable winter MW goals would be 1.15 MW for
residential 	and 	0.33 	MW 	for 	non-residential/commercial, 	culminating 	in 	a
combined total winter megawatt goal of 1.83 MW.
JEA: 	JEA is a municipal electric utility governed by a Board of Directors consisting of
seven Members, who set policies consistent with the best interests of JEA’s
customers and community. JEA is an electric utility within the meaning of Section
366.02(2), 	Florida 	Statutes 	(“F.S.”), 	and 	is 	subject 	to 	the 	Florida 	Energy
Efficiency Conservation Act (“FEECA”).
In 	developing 	its 	proposed 	goals, 	JEA 	retained 	Resource 	Innovations 	to
independently 	analyze 	the 	Technical 	Potential 	(“TP”) 	for 	demand-side
management 	(“DSM”) 	measures 	across 	JEA’s 	residential, 	commercial, 	and
industrial retail customer classes. 	JEA also retained Resource Innovations to
conduct an economic analysis of DSM measures, designed to determine which
DSM measures are cost-effective from different test perspectives and to develop
estimates of potential peak demand and energy reductions if these measures were
adopted in JEA’s service territory. In addition, JEA worked collaboratively with

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 12
Resource Innovations on the 	DSM program development process to develop
potential peak demand and energy reductions under three scenarios: (1) potential
DSM 	programs 	that 	contribute 	to 	proposed 	DSM 	goals 	(Proposed 	Goals
scenario): (2) potential DSM programs that pass the Participant and Rate Impact
Measure Tests (“RIM-scenario”); and (3) potential DSM programs that pass the
Participant and Total Resource Cost Tests (“TRC-scenario”).
As discussed in the pre-filed testimony of Brian Pippin and Jim Herndon, the
cost- effectiveness analysis of DSM programs shows that only one residential
program (Home Efficiency Upgrades) is cost-effective under the RIM and
Participant Tests combined, and no commercial/industrial programs (other than
demand response which, as discussed in Mr. Pippin’s testimony, is not included in
JEA’s proposed goals) pass the RIM and Participant Tests combined. Accordingly,
consistent with the approach previously approved by the Commission, JEA is
proposing 	numeric 	conservation 	goals 	based 	on 	DSM 	programs 	that 	JEA
currently offers with some modifications. The net effect is an increase in JEA’s
residential goals and a tripling of JEA’s commercial goals going forward. This
goal-setting approach is consistent with the Commission’s well-established policy
that, for FEECA municipal utilities such as JEA, “it is appropriate to defer to
municipal utilities’ governing bodies to determine the level of investment if
measures are not cost-effective.” Order No. PSC-2020-0200-PAA-EG, p.5 (June
24, 2020) (citing Order No. PSC- 2015-0324-PAA (Aug. 11, 2015)).
The Commission should reject Florida Rising’s proposal that the Commission
order JEA to expand its low-income Neighborhood Energy Efficiency (“NEE”)
Program by 500%. Florida Rising’s proposed 5-fold increase is an arbitrary figure
that is not supported by any analysis of achievability or cost-effectiveness as
required by Commission rules. Furthermore, the analyses performed by Resource
Innovations show that residential conservation measures of the type included in
JEA’s NEE Program do not pass the RIM test, and the NEE Program, as a whole,
does not pass the RIM test, meaning that the NEE Program puts upward pressure
(i.e., increases) JEA’s rates to its customer. Thus, imposition of Florida Rising’s
proposal would be inconsistent with the Commission’s long-standing policy
regarding the basis of establishing numeric goals for municipal utilities under
FEECA.
For all the reasons discussed above and below, and as explained in more detail in
the direct and rebuttal testimony provided by its witnesses, JEA’s proposed DSM
Goals should be approved. JEA’s proposed Goals comply with the requirements
of Section 366.82, F.S., comply with Rule 25-17.0021, F.A.C, and are consistent
with long-standing Commission policy regarding establishment of goals for
municipal utilities. Accordingly, the Commission should approve JEA’s proposed
goals.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 13
OUC: 	OUC provides reliable, reasonably priced electric service to approximately
275,000 customer accounts in the City of Orlando, the City of St. Cloud, and
portions of unincorporated Orange and Osceola Counties. In meeting the needs of
OUC’s customers and serving the overall public interest, in these Energy
Conservation Goals proceedings, OUC proposes an overall FEECA energy
conservation goal for 2025 that is more than three times its Commission-approved
goal for 2024. 	Supported by the values and desires of its customers and the
Orlando area community, including OUC’s commitment to achieve net-zero
greenhouse gas emissions by 2050, OUC’s overall demand-side and supply-side
energy conservation efforts achieve energy savings much greater than just those
realized through OUC’s FEECA DSM programs. 	In pursuing its broad energy
goals and serving the public interest, OUC must balance the benefits of its energy
efficiency programs under FEECA with the costs of those programs, particularly
their impacts on customer rates. OUC’s proposed goals and programs strike this
balance 	appropriately 	and 	meet 	all 	statutory 	and 	rule 	requirements. 	The
Commission 	should 	approve 	OUC’s 	proposed goals 	as 	submitted, 	and 	the
Commission should also approve OUC’s programs designed to achieve these
goals in due course.
OUC is an electric utility within the meaning of Section 366.02(2), Florida
Statutes, and is subject to FEECA. OUC’s electric service area covers 419 square
miles and includes the City of Orlando, portions of unincorporated Orange
County, and portions of unincorporated Osceola County. 	Additionally, pursuant
to an Interlocal Agreement, OUC serves the entire electric service requirements of
St. Cloud and treats the St. Cloud load and customers as part of OUC’s retail
obligations for planning and energy conservation purposes.
OUC 	currently 	serves 	approximately 	275,000 	electric 	customer 	accounts,
including approximately 242,000 electric residential customers, 28,000 electric
commercial customers, and 5,100 electric industrial customers. 	Approximately
43 percent of OUC’s residential customers (including those in St. Cloud) live in
multi-family residences, and many of these are rental units. 	Additionally, a
significant 	number 	of 	single-family 	residences 	served 	by 	OUC 	are 	renter-
occupied. 	Approximately 33 percent of OUC’s residential customers have
household incomes less than $50,000, which is approximately 1.6 times the
Federal Poverty Level for a family of four as of 2024.
OUC currently offers a number of programs that promote energy conservation
and summer and winter peak demand reductions. 	OUC continually seeks and
implements supply-side efficiency measures. 	OUC also has extensive solar
energy initiatives, including both demand-side and supply-side solar power
projects, and OUC also obtains renewable electricity generated using landfill gas.
OUC has committed to a goal of net-zero greenhouse gas emissions by 2050.

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DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
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PAGE 14
For these consolidated conservation goal-setting dockets, OUC joined with the
other utilities subject to FEECA – Florida Power & Light, Duke Energy Florida,
Tampa Electric Company, Florida Public Utilities Company, and JEA – to engage
Resource Innovations, Inc. (“RI”), to analyze and estimate the full Technical
Potential for energy conservation for all of the FEECA Utilities. 	OUC provided
extensive load and customer forecast information, as well as system cost and
avoided-cost information to support RI’s analyses. 	OUC also engaged RI to
conduct 	cost-effectiveness 	analyses 	of 	approximately 	400 	potential 	energy
conservation measures (combined in several thousand permutations of those
measures) identified in the Technical Potential analyses using the Commission-
prescribed Rate Impact Measure (“RIM”) test, Total Resource Cost (“TRC”) test,
and the Participant Test. 	OUC also engaged RI to conduct cost-effectiveness
analyses for a sensitivity case considering potential costs of complying with
future carbon emissions regulations.
OUC further engaged RI to assist with bundling conservation measures, including
nearly all of those offered through OUC’s existing DSM programs, into programs
based on the RIM and TRC test results and practical considerations including
program 	costs, 	incentives, 	and 	projected 	adoption 	of 	measures 	by 	OUC’s
customers. 	Energy and peak demand savings for these measures and programs
were calculated based on projected participation rates over the 2025-2034 period,
and the resulting energy and demand savings goals are those that these programs
are projected to produce. OUC’s proposed energy goal for 2025 is 4,242 MWH,
which is more than three times OUC’s Commission-approved energy goal of
1,370 MWH for 2024.
OUC has consistently exceeded its FEECA Goals with measures developed on
OUC’s initiative. 	OUC will continue to develop and implement both demand-
side and supply-side conservation and efficiency measures, as well as solar and
other renewable energy initiatives, based on OUC’s unique characteristics, OUC’s
knowledge of its system and customer base, and changing circumstances in the
energy sector. OUC will pursue this course, as it has successfully done for years,
to serve the State’s policies set forth in FEECA and to meet the needs and
circumstances of OUC’s customers. 	OUC respectfully asks the Commission to
approve OUC’s proposed FEECA Goals as submitted, and to approve OUC’s
proposed programs in due course.
FDACS: 	Pursuant to Section 366.81, F.S., the Legislature finds and declares that it is
critical to utilize the most efficient and cost-effective demand-side renewable
energy 	systems 	and 	conservation 	systems 	in 	order 	to 	protect 	the 	health,
prosperity, and general welfare of the State and its citizens. Reduction in, and
control of, the growth rates of electric consumption and weather-sensitive peak
demand are of particular importance. The goal of Florida’s energy policy should be
to secure a stable, reliable and diverse supply of energy in order to meet the

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DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
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PAGE 15
demands of Florida’s growing population. An all-of-the-above approach must be
employed in order to meet this objective and that includes energy efficiency and
conservation measures.
In establishing and setting goals to meet these mandates, the Commission should
consider various policy options to achieve a least-cost strategy, employ market-
based technologies, and yield greater efficiencies of electric consumption. The
effects of non-utility programs that are targeted at reducing and controlling the per
capita use of electricity in Florida should be considered, as well as the impact of
state and local building codes and appliance efficiency standards. These factors
may increase energy efficiency and reduce or control the per capita use of
electricity in the State, and thus reduce the level of appropriate goals and need for
utility- sponsored programs. The Commission should balance the importance of
pursuing energy efficiency and conservation programs against the cost of the
programs and their impact on all ratepayers.
FIPUG: 	Duke Energy Florida, LLC (“DEF”) provides demand credit rates for interruptible
service, curtailable service, stand-by generation, or similar potential demand
response programs to many customers, including FIPUG members. Utilities such
as DEF avoid having to build additional peaking generating units by having these
customers agree to be interrupted or curtailed when the utility in question
experiences peak load conditions on its system. In exchange for the customers’
agreement to have its power interrupted or curtailed, these customers receive
certain demand credit rates. 	The demand credit rates for interruptible service,
curtailable service, stand-by generation or similar potential demand response
programs should be addressed in the base rate proceedings for DEF and the rate
regulated FEECA Utilities.
The reasons to address these credits in base rate cases rather than the goals docket
are: 1). This Commission and recent Commissions have adjusted demand credit
rates in base rate cases. 	2). Base rate proceedings often result in settlement
agreements, in which credit adjustments are part and parcel of a negotiated
outcome, which must pass a public interest test. 3) Setting these demand credit
rates set in base rate cases provides clear and unambiguous notice that the proper
venue in which to consider this issue is a respective utility’s base rate case. 4)
Clearly adopting the Commission’s past practice of establishing demand credit
rates for interruptible service, curtailable service, stand-by generation or similar
potential demand response programs filing testimony in a utility’s base rate case
is more efficient in that affected intervenors will not have to file testimony in two
dockets, namely the company’s goals docket and the company’s base rate case
docket. 	Should these credits be addressed in the goals docket for DEF, the
appropriate credit sum for interruptible and curtailable service should be increased
as supported by the testimony of FIPUG witness Jeff Pollock.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 16
FL Rising/
ECOSWF/
LULAC: 	By 	passing 	the 	Florida 	Energy 	Efficiency 	and 	Conservation 	Act 	(“Energy
Efficiency Act”), the Florida legislature has recognized the importance of curbing
electricity consumption, increasing energy efficiency, and promoting demand-side
renewable energy to securing the economic future and health of Florida’s citizens.
To meet these objectives, the Energy Efficiency Act allocates responsibility to the
Florida Public Service Commission (“Commission”) to oversee the actions of
Florida’s major utilities. 	A major element of this responsibility involves the
Commission’s oversight over the utilities’ conservation goals to ensure that the
utilities meaningfully integrate lower cost and lower risk demand-side energy
efficiency and renewable resources into Florida’s energy resource portfolio.
Florida Rising, ECOSWF, and LULAC have intervened to advocate for utility
conservation goals that prioritize investment in cost-effective efficient sources of
energy and address the needs of low-income communities that predominantly bear
the burden of high energy costs.
While Florida Power & Light Co. (“FPL”), Duke Energy Florida (“DEF”), JEA,
Orlando Utilities Commission (“OUC”) and Tampa Electric Company (“TECO”)
(collectively, 	“the 	utilities”) 	have 	taken 	strides 	towards 	recognizing 	the
importance of addressing low-income communities’ energy burden compared to
the 2019 proceedings, their initial proposals still fail to adequately reflect the
needs of Floridians. 	By continuing to largely rely on analytical tests that
understate 	the 	value 	of 	energy 	efficiency, 	low 	projections 	for 	program
participation, and methodology that does not reflect the lived experiences of
Floridians, utilities propose setting unambitious goals resulting in some of the
worst energy efficiency performance in the nation.
First, the utilities’ use of “bill comparisons” for energy efficiency goal-setting
purposes premised on 1,000 kWh of usage rather than actual usage is misleading
and makes energy efficiency appear more costly than what people actually pay.
These deceptive comparisons understate the actual benefits of energy efficiency
while inflating the perceived costs, and when used to set energy efficiency goals,
that cost inflation is reflected in inadequate and weak proposed goals. 	Second,
while the utilities took a step back from relying entirely on the RIM and two-year
payback screen to evaluate the costs and benefits of potential programs and
measures, 	the 	two-year 	payback 	screen 	remains 	a 	crude 	and 	misleading
instrument that improperly eliminates a huge portion of cost-effective DSM from
consideration under the unsupported and indefensible assumptions that regular
people know the payback period for every efficiency measure, and, that those
same people have both the resolve and the cash on hand to install all such
measures. Without any factual basis for either of these premises in the record, it
is patently unreasonable to assume a DSM program with a sub-two-year payback
period will be plagued by free-ridership. 	Moreover, flaws in weighing the costs

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PAGE 17
and benefits of potential energy efficiency measures artificially constrain the
energy efficiency potential of utilities and compound on top of rising housing
costs and stagnant wages, subjecting residential and low income households to
exponentially increasing energy burdens while utility companies continue to
report record profits on the backs of Floridians.
The utilities understate their proposed goals for residential program participation
despite having shown that higher levels of participation are achievable. Many of
the utilities had higher program participation prior to scaling back energy
efficiency programs in 2014. Because of these historical levels of participation,
the utilities should set projected participation at levels much higher than they
currently propose. 	This understatement of participation levels in many of the
residential programs and measures tips the cost-benefit analysis of the programs
to make them appear more costly than the benefits they reap. The proposed MW
and GWh goals could be much stronger with less conservative estimates of
participation. 	The stipulations entered into the DEF docket have resolved these
issues in that docket.
The limited energy efficiency measures offered by the utilities also remain
unfairly distributed, with residential customers paying more into programs that
predominantly result in savings and benefits for industrial and commercial
customers. Most energy efficiency funding is spent on bill credits for commercial
interruptible and curtailable service programs despite these entities receiving little
to no interruption. 	As Mr. Marcelin testifies, almost half of FPL’s energy
conservation 	spending 	goes 	to 	its 	curtailable 	or 	interruptible 	commercial
customers although they have never been interrupted in recent history and FPL
has no plans to interrupt them in the future. And that unequal distribution remains
present across most of the utilities with commercial and industrial customers
receiving more than 50% of the energy savings shares through FPL, TECO, JEA,
and OUC in 2023. With this imbalance in energy savings and lack of interruption
in the curtailable and interruptible service programs, residential customers pay
into programs that they reap no actual benefits from.
The Commission should set meaningful goals that require the utilities to invest in
and deliver energy efficiency while ensuring its programs are distributed to
provide energy-savings benefits not only to commercial and industrial customers,
but to the residential customers that overwhelmingly pay into the costs of the
programs. The Commission should approve the stipulations entered into in the
DEF docket that are joined by Florida Rising and LULAC. 	Well-run residential
programs that encourage widespread participation will result in cost-effective
benefits 	for 	both 	customers 	and 	utilities. 	Aggressive 	investment 	in 	energy
efficiency programs is essential to pull Florida from one of the lowest performing
and most costly states in the nation to a leader in providing affordable and
efficient energy to its residents.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 18
Nucor: 	Consistent with the 2024 Settlement Agreement filed in Docket No. 20240025-EI,
and the Joint Notice of Necessary Stipulations filed in this docket on July 15,
2024, Nucor has entered into Stipulations on issues 8b and 12. Further, assuming
the Commission approves the Stipulations on issues 8b and 12, Nucor is willing to
enter into Type 2 stipulations on issues 2 through 5. If the Commission does not
approve the Stipulations on issues 8b and 12, then Nucor reserves the right to
contest these issues as noted in the Statement on Specific Issues below.
On Issue 8a, Nucor’s position is that the issue is moot assuming the Stipulation on
8b is approved since this stipulation approves the level of credits for the
Interruptible General Service (“IS”) and Curtailable General Service (“CS”)
programs going forward. Nevertheless, to the extent the Commission decides that
it needs to address the issue of where the credits should be decided as a policy
matter, Nucor’s position is that the level of the IS and CS credits should be
addressed in a base rate case proceeding instead of in a DSM goals proceeding.
PCS
Phosphate: 	In this proceeding, consistent with the requirements of the Florida Energy
Efficiency and Conservation Act (“FEECA”), DEF proposes to set its DSM goals
for 	the 	period 	2025-2034 	based 	on 	a 	portfolio 	of 	DSM 	programs 	that 	it
determined to be cost effective based on assessments using the Rate Impact
Measure (“RIM”), Total Resource Cost (“TRC”), and Participant Cost Tests
(“PCT”). DEF’s recommended portfolio of programs is based primarily on RIM
test results; but DEF also recommends some measures passing the TRC test, and
it proposes to implement some additional low-income measures that do not meet
any of the cost-effectiveness tests that it conducted but which Duke nonetheless
considered appropriate to include. DEF mentioned in passing that it would be
proposing changes to the existing Interruptible General Service (“IS”) and
Curtailable General Service (“CS”) program credits, but the proposed changes to
IS and CS programs actually appear in DEF’s pending general base rate case
(Docket No. 20240025-EI).
PCS supports the consideration of both the RIM and TRC tests in setting the
DEF’s DSM goals and notes that the TRC better reflects the ongoing system
benefit 	provided 	by 	existing 	demand 	response 	participation. 	Also, 	DEF’s
selection 	of 	a 	brownfield 	natural 	gas 	combustion 	turbine 	(“CT”) 	entering
commercial service in 2029 as its avoided marginal generation cost unit, and its
presumed costs of that unit systematically under-estimates the cost/benefit of
demand response under all methods studied.
Duke’s avoided marginal generation cost for its proposed avoided unit of
$735.20/kW is significantly lower than TECO’s avoided generation unit as well
as Duke’s other potential avoided units, which range from $949.40/kW for a
greenfield CT to $2,471/kW for solar generation with battery storage. (see

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DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
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PAGE 19
Georgis Testimony at 15-17). Applying a more representative cost for an avoided
generating unit will more realistically represent the expected cost effectiveness of
DEF demand response measures under both the RIM and TRC tests.
On July 15, 2024, DEF filed a proposed comprehensive base rate settlement
agreement in Docket No. 20240025-EI (“2024 Settlement Agreement”) that
encompasses certain questions presented in Issue #8 in this docket. Specifically,
the 2024 Settlement Agreement re-sets DEF’s curtailable, interruptible and
standby-generator credits and DEF commits not to propose revising those credits
in its next DSM goals submission. Contemporaneously with the submission of the
2024 Settlement Agreement, DEF filed a Joint Notice of Necessary Stipulations in
this 	docket 	that 	precisely 	tracks 	the 	above-noted 	provisions 	of 	the 	2024
Settlement Agreement because consistent Commission action is required on these
matters in both dockets. PCS Phosphate is a signatory and strongly supports both
the 2024 Settlement Agreement and the linked and necessary stipulations in this
docket. In PCS’ view, Commission adoption of the proposed stipulation of what is
now Issue # 8(b) (i.e., what is the appropriate level of those credits) effectively
resolves PCS concerns regarding Issues 2-5, and PCS would conditionally support
“Type 2” stipulations of those issues. Pending such Commission approval,
however, PCS must reserve its otherwise stated positions on those questions.
Finally, as to Issue # 8(a), in light of the DEF stipulation in Issue # 8(b) and the
fact that neither FPL nor TECO propose revising their curtailable/ interruptible
service programs or credits when setting their goals in this docket, Issue # 8(a) is
effectively moot and the Commission does not need to address it. More broadly,
the Commission should refrain from setting or adjusting demand charge credits
for CS and IS service in the DSM goals proceeding. DEF’s demand response
programs for residential, commercial and industrial customers specify rates, terms
and conditions for participation that are incorporated in its base rate tariffs.
Consequently, any changes to those rates, terms and conditions should be
addressed in DEF base rate proceedings. The Commission should clarify that all
tariff-based changes should be addressed in base rate cases.
SACE: 	As 	recognized 	by 	the 	Florida 	legislature, 	reducing 	the 	rate 	of 	electricity
consumption, increasing the overall efficiency and cost-effectiveness of electricity
use, and encouraging further development of demand-side renewable energy
systems are critical to Florida’s economic future and the health of its citizens. The
conservation goal setting process laid out by the legislature in the Florida Energy
Efficiency and Conservation Act (“FEECA”) provides a framework for the
Florida Public Service Commission to play a critical role in meeting these
objectives by setting goals that meaningfully integrate lower cost and lower risk
demand-side energy efficiency and renewable resources into Florida’s energy
resource portfolio. SACE has intervened to help the Commission set goals that
maximize utility investment in cost-effective energy efficiency, the cleanest and

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DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
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PAGE 20
cheapest 	resource 	to 	meet 	Floridians’ 	power 	needs, 	and 	support 	improved
valuation and increased development of demand-side renewable energy systems.
The Technical Potential Study conducted by Resource Innovations for all FEECA
utilities identifies huge potential for energy and demand savings in Florida with
available and proven technologies. However, neither the proposed annual nor 10-
year goals will achieve even the tiniest percentage of Florida’s annual retail sales of
electricity. Thus, adoption of the proposed DSM goals 	would 	constitute 	a
significant missed opportunity to reduce costs for ratepayers, strengthen the grid,
and eliminate waste.
While improved from the 2019 proceedings which resulted in “zero goals,”
utilities continue to propose unreasonably low savings goals. Despite a less
rigorous application of it, the utilities continue to rely on the Rate Impact Measure
(“RIM”) cost effectiveness test in establishing their proposed goals. the RIM test
should 	not 	be 	used 	to 	screen 	efficiency 	measures. 	Ratepayer 	impacts 	are
important to consider; however, the RIM test does not accurately calculate them.
The Total Resource Cost test more accurately depicts the costs and benefits of
energy efficiency for consumers in Florida. Florida should eliminate its use of the
RIM test.
The utilities justify their unreasonably low savings goals by asserting that they are
avoiding cross subsidization. However, a concern about cross subsidies is not a
sufficient reason to underinvest in cost effective energy efficiency. First, the
system-wide benefits of energy efficiency, including lower overall cost, accrue to
all customers, not just participating customers. Second, unlike with supply-side
resources, cross-subsidies in the efficiency context can be mitigated by increasing
participation rates, i.e. by turning non-participants into participants. This can be
done 	by 	offering 	well-designed, 	comprehensive 	programs 	that 	target 	each
customer 	sector, 	including 	hard-to-reach 	customers, 	such 	as 	low-income
residential households. Finally, the utilities ignore the fact that cross-subsidization
occurs on the supply-side of the energy picture. For example, customers who live
near power plants do not benefit from lower electricity costs as compared to
their counterparts who live further away from the plants, even though it costs the
utility less to deliver electricity from the plants to their homes than to more distant
homes.
The utilities further suppress the adoption of cost-effective measures when they
apply a two-year payback screen to account for “free ridership.” The utilities
blindly apply this screen across all measures without any data or information to
support 	that 	the 	measures 	are 	in 	fact 	being 	adopted 	by 	customers. 	The
Commission should direct the utilities to utilize best practices from other
jurisdictions that are less restrictive than the two-year payback screen.

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DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
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PAGE 21
The Commission should set meaningful goals that require the FEECA utilities to
aggressively and broadly invest in and deliver energy efficiency. Comprehensive,
well-run programs will allow all customers to save energy, lower their electricity
bills and allow utilities to lower their overall system cost and risk.
Walmart: 	Walmart has ambitious and significant company-wide renewable energy goals as
set forth in the Direct Testimony of Steve W. Chriss filed in the Consolidated
Dockets on June 5, 2024. 	In general, these renewable energy goals are met
through a combination of self-funded initiatives and projects and participation in
relevant 	utility-led 	DSM, 	energy 	efficiency 	("EE") 	and 	renewable 	energy
programs, as well as through third-party contracts such as power purchase
agreements ("PPAs"). 	Walmart is participating in the Consolidated Dockets to
both inform the Commission of its current company-wide renewable energy
goals, and to provide recommendations to assist the Commission in its through
and careful consideration of the customer impacts of each Utility's requests in the
Consolidated Dockets.
In light of the number of facilities in each Utility's respective service territory,
Walmart is focused on the proposals put forth by FPL, DEF, and TECO as those
proposals pertain to C&I customers, having no opinion on proposed goals or
programs for residential customers. Walmart takes no position as to the as-filed,
proposed goals of FPL and TECO, and does not oppose the C&I programs of
either FPL or TECO. In DEF's Docket, Walmart's position on Issues 8(b) and 12
are as stipulated in the Joint Notice of Necessary Stipulations to Issues 8(b) and
12 by DEF, FIPUG, Nucor, PCS Phosphate, Walmart, Florida Rising, and
LULAC filed on July 15, 2024. Otherwise, Walmart takes no position on DEF's
goals for its C&I customers and otherwise does not oppose DEF's C&I programs.
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.
VIII. 	ISSUES AND POSITIONS
For party positions in the FPUC docket (20240015-EG), see the proposed Type II
stipulations in Section X of this prehearing order.
ISSUE 1: 	Are the utility’s proposed goals based on an adequate assessment of the full
technical potential of all available demand-side and supply-side conservation
and efficiency measures, including demand-side renewable energy systems?

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FPL: 	Yes. An outside consultant, Resource Innovations, Inc., performed the Technical
Potential Study for each of the FEECA Utilities. The analysis required extensive
iterative work and continuous collaboration to ensure that it was comprehensive
and resulted in a thorough and wide-ranging reassessment of conservation and
efficiency measures. (Herndon)
DEF: 	Yes. DEF's technical potential, that is the basis for the updated proposed
Recommended 	goals, 	includes 	an 	evaluation 	of 	all 	potential 	demand-side
conservation 	and 	efficiency 	measures 	and 	demand-side 	renewable 	energy
systems. Demand-side renewable energy systems were evaluated based on the
same cost effectiveness standards that were used to evaluate other energy
efficiency measures. No renewable measures were found to be cost-effective and
therefore, none are included in the proposed goals. (Duff, Herndon).
TECO: 	Yes. 	Tampa Electric worked in concert with the other FEECA utilities and
Resource Innovations to develop a new Technical Potential Study. 	This new
Technical Potential Study for Tampa Electric was based upon the full load forecast
for the company, which ensures the proposed goals are based on an adequate
assessment of the full technical potential of all available demand-side and
efficiency measures, including demand-side renewable energy systems, pursuant to
Section 366.82(3), F.S. (Roche)
JEA: 	Yes. JEA’s proposed goals are based on an adequate assessment of the full
technical potential of all available demand-side and supply-side conservation and
efficiency measures, including demand-side renewable energy systems, pursuant to
Section 366.82(3), F.S. Consistent with the other FEECA utilities, JEA engaged
Resource Innovations to evaluate DSM measures in JEA's service territory.
Resource Innovations analyzed the technical potential for energy efficiency,
demand 	response, 	and 	demand 	side 	renewable 	energy 	across 	residential,
commercial, and industrial customer classes for the 2020-2029 time- period. For
JEA, Resourced Innovations also conducted the economic screening for the
economic 	and 	achievable 	scenarios 	and 	analyzed 	economic 	potential 	and
achievable potential based on the passing measures. (Pippin, Kushner, Herndon)
OUC: 	Yes. OUC’s proposed goals are based on a thorough and robust assessment of the
full technical potential of all available demand-side and supply-side conservation
and efficiency measures, including demand-side renewable energy resources.
(Noonan, Herndon)
FDACS: 	The utilities’ proposed goals appear to be an adequate assessment of the full
technical potential of all available demand-side and supply-side conservation and
efficiency measures. However, a thorough examination and analysis of this issue
by the Commission is necessary.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 23
FIPUG: 	No position.
FL Rising/
ECOSWF/
LULAC: 	No. (Marcelin)
Nucor: 	No position.
PCS
Phosphate: 	No position.
SACE: 	No.
Walmart: 	Walmart takes no position.
STAFF: 	No position.
ISSUE 2: 	Are the utility’s proposed goals based on savings reasonably achievable
through demand-side management programs over a ten year period?
FPL: 	Yes. FPL’s proposed DSM Goals include the following RIM- and TRC- passing
programs:
Residential Sector:
1. 	Residential HVAC
2. 	Residential Ceiling Insulation
3. 	Residential Low Income
a. 	Renter Pilot
4. 	Residential New Construction (BuildSmart®
)
5. 	Residential Load Management (On Call ®
) with new HVAC on-bill option
Commercial/Industrial Sector:
1. 	Business HVAC
2. 	Business Lighting
3. 	Commercial/Industrial Demand Reduction
4. 	Business Custom Incentive
5. 	Business On Call®
This proposal of RIM- and TRC-passing programs will allow FPL to continue
delivering 	meaningful 	energy-efficiency 	savings 	options 	to 	all 	customers
including owners, renters, and low-income customers. The proposed goals factor
in adjustments in participation levels to reflect market conditions and adjustments
in projections based on the 2024 Technical Potential Study measure impacts.
(Floyd)

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 24
DEF: 	Yes. DEF’s updated proposed Recommended goals were developed through a
well-tested data-driven process consistent with Florida statute and Commission
rules that appropriately considers market conditions and customer adoptions
curves to yield reasonably achievable goals over the 2025-2034 period. 	(Duff,
Herndon).
TECO: 	Yes. Tampa Electric used appropriate data to develop the proposed goals over the
ten-year period as required by Rule 25-17.0021, F.A.C. For the summer and winter
kW and annual energy (kWh) savings, the company used consistent sources for this
data as in prior DSM goals setting proceedings. These sources consisted of either
the Technical Potential Study, Historical Data, or the company’s Load Research
Data. To project reasonably achievable participation, Tampa Electric used factors
such as recent participation, overall program participation to evaluate saturation,
changes in proposed incentive levels, changes in equipment incremental cost, any
major changes or shifts in technology, current economic conditions, existing
program or new, changes in building codes, adoption models, and Bass curves.
(Roche)
JEA: 	Yes. JEA’s proposed goals are based on savings reasonably achievable through
demand-side management programs over a ten-year period. The proposed goals
are based on programs already implemented by JEA and the projected market
adoption forecasts collaboratively developed for the proposed programs by
Resource Innovations and JEA. (Pippin, Herndon)
OUC: 	Yes. OUC’s proposed goals are based on savings reasonably achievable through
OUC’s proposed DSM programs over the period 2025 through 2034. 	The
proposed goals are based on a sound assessment of the basic economic potential
of 	the 	measures 	incorporated 	into 	OUC’s 	proposed 	programs, 	program
administrative costs and incentives, and analyses of customer adoption and
participation in the programs. (Noonan)
FDACS: 	The utilities’ proposed goals appear to be based on savings reasonably achievable
through demand-side management programs over a ten-year period. However, a
thorough examination and analysis of this issue by the Commission is necessary.
FIPUG: 	Yes.
FL Rising/
ECOSWF/
LULAC: 	No. The utilities continue to discount potentially cost-effective conservation and
efficiency 	measures 	by 	overstating 	the 	costs 	of 	certain 	measures 	while
understating potential participation and benefits reaped from those measures. The
proposed goals underestimate the potential for more aggressive and widespread

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 25
goals on the residential demand side that could be met over that ten year period.
(Marcelin)
Nucor: 	Nucor is willing to enter into a Type 2 stipulation on this issue such that Nucor does
not oppose DEF’s position. However, if the Commission does not approve issues 8b
and 12 as agreed to in the 2024 Settlement Agreement filed in Docket No. 20240025-
EI, Nucor reserves the right to take the following position: No.
PCS
Phosphate: 	No, but, subject to Commission approval of the proposed stipulation of Issue # 8(b),
PCS is conditionally willing to stipulate this issue.
SACE: 	Adopts the position of Florida Rising.
Walmart: 	Walmart takes no position.
STAFF: 	No position.
ISSUE 3: 	Do the utility’s proposed goals adequately reflect the costs and benefits
to customers participating?
FPL: 	Yes. Consistent with Rule 25-17.0021(3), Florida Administrative Code, FPL’s
proposed DSM Goals were developed using both the Participant and RIM cost-
effectiveness tests scenario and the Participant and TRC cost-effectiveness tests
scenario. The intent of the Participant test is to measure the cost-effectiveness of a
DSM measure from the participating customer's perspective. This test reflects the
costs and benefits to participating customers. The intent of the TRC test is to
measure the cost of a DSM measure to both the utility and its customers, without
consideration of the impact to rates. Specifically, the TRC test only considers the
incremental cost of the measure (equipment) and the administrative cost of
implementing the program. (Floyd, Whitley)
DEF: 	Yes. The DEF’s updated proposed Recommended goals are based on measures
that pass the Participant Cost Test. This test compares the incremental cost to
participants to the participant benefits (bill savings). This ensures that the
measures provide net benefits to participants. (Duff)
TECO: 	Yes. Tampa Electric utilized the Participant Cost Test (“PCT”), as delineated in
Rule 25-17.008, F.A.C., to adequately reflect the costs and benefits to customers
participating in a DSM measure thereby adhering to the requirement of Section
366.82(3)(a), F.S. (Roche)

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 26
JEA: 	Yes. JEA's proposed goals adequately reflect the costs and benefits to customers
participating 	in 	the 	measure, 	pursuant 	to 	Section 	366.82(3)(a), 	F.S. 	JEA's
proposed goals are based on forecasts of achievable potential that are driven
primarily 	by 	measure-level 	assessments 	of 	cost-effectiveness 	to 	customers.
Specifically, customer cost-effectiveness is assessed using the Participant Test,
where benefits are calculated based on customer bill savings and costs are based
on participant costs of acquiring and installing the energy efficiency measure (net
of utility program incentives). Both the participant benefits and participant costs
are assessed on present value basis over the life of the measure. (Pippin, Kushner,
Herndon)
OUC: 	Yes. 	OUC’s proposed goals are based on a full consideration of the results of
Participant Cost Test analyses performed by Resource Innovations, and those
analyses adequately and appropriately reflect the costs and benefits to customers
who might participate in the DSM measures and programs analyzed. 	Thus,
OUC’s proposed goals adequately reflect the costs and benefits to participating
customers. (Herndon, Kushner, Noonan)
FDACS: 	The utilities’ proposed goals appear to adequately reflect the costs and benefits to
customers participating in the measures. However, a thorough examination and
analysis of this issue by the Commission is necessary. The Commission should
consider policy options that can be implemented to achieve least-cost strategies that
take into account the costs and benefits of the programs and their impact on all
ratepayers.
FIPUG: 	Yes, for the most part, except the credit rates for interruptible service, curtailable
service, stand-by generation, or similar potential demand response programs for
Duke Energy Florida, Inc. should be increased in the DEF pending base rate case.
FL Rising/
ECOSWF/
LULAC: 	No. The proposed goals overstate the costs and understate the benefits of certain
measures by using an arbitrary two-year screen and misleading methodology that
makes energy efficiency measures appear more costly than they are in practice.
(Marcelin)
Nucor: 	Nucor is willing to enter into a Type 2 stipulation on this issue such that Nucor
does not oppose DEF’s position. However, if the Commission does not approve
issues 8b and 12 as agreed to in the 2024 Settlement Agreement filed in Docket
No. 20240025-EI, Nucor reserves the right to take the following position: No.
DEF’s cost-effectiveness tests systematically understate the value of the CS and
IS programs. Further, DEF’s chosen avoided cost generating unit (a brownfield
combustion turbine), does not reflect actual planned additions and retirements and

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 27
therefore understates the value of DEF’s proposed DSM programs. Nucor takes
no position regarding the other utilities.
PCS
Phosphate: 	No, but, subject to Commission approval of the proposed stipulation of Issue #
8(b), PCS is conditionally willing to stipulate this issue.
SACE: 	No.
Walmart: 	Walmart takes no position as to any of the utility's positions except for DEF's
litigation position, which has now been resolved pursuant to the Stipulation
referenced in Section VII. below.
STAFF: 	No position.
ISSUE 4: 	Do the utility’s proposed goals adequately reflect the costs and benefits to the
general body of rate payers as a whole, including utility incentives and
participant contributions?
FPL: 	Yes. Consistent with Rule 25-17.0021(3), Florida Administrative Code, FPL’s
proposed DSM Goals were developed using both the Participant and RIM cost-
effectiveness tests scenario and the Participant and TRC cost-effectiveness tests
scenario. The intent of the TRC test is to measure the cost-effectiveness of a DSM
measure to both the utility and its customers, without consideration of the impact
to rates. The RIM test includes consideration of the cost of incentives paid to
participating customers, the revenue impact on the general body of ratepayers
resulting from the DSM program, and the cost of implementing the program itself
(administrative cost). (Floyd, Whitley)
DEF: 	Yes. DEF’s updated proposed Recommended goals do adequately reflect the costs
and benefits to the general body of ratepayers, as a whole, because the goals are
based on measures that pass both the RIM and Participant tests. The Participant,
TRC and RIM tests, in combination with each other, effectively ensure that both
participants and non-participants benefit. (Duff)
TECO: 	Yes. Tampa Electric utilized the cost-effectiveness methodologies, as delineated
in Rule 25-17.008, F.A.C., to adequately reflect the costs and benefits to the general
body of ratepayers as a whole, including utility incentives and participant
contributions. (Roche)
JEA: 	Yes. JEA's proposed goals are based on market adoption forecasts that included
consideration of the costs and benefits to the general body of ratepayers as a

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 28
whole, including utility incentives and participant contributions, through use of
the RIM and Participant tests. (Pippin, Kushner, Herndon)
OUC: 	Yes. 	OUC’s proposed goals adequately and appropriately reflect the costs and
benefits of potential customer-funded DSM measures to the general body of
OUC’s ratepayers considered as a whole, including consideration of utility
incentives and participant contributions. The costs and benefits to OUC’s general
body of customers are fully reflected in RI’s RIM Test analyses. 	(Herndon,
Noonan)
FDACS: 	The utilities’ proposed goals appear to adequately reflect the costs and benefits to
the general body of rate payers as a whole, including utility incentives and
participant contributions. However, a thorough examination and analysis of this
issue by the Commission is necessary. The Commission should consider policy
options that can be implemented to achieve least-cost strategies that take into
account the costs and benefits of the programs and their impact on all ratepayers.
FIPUG: 	Adopts position of PCS Phosphate.
FL Rising/
ECOSWF/
LULAC: 	No. The utilities’ proposed goals falsely inflate the benefits of the curtailable and
interruptible service programs while attempting to diminish the costs that the
programs impose on the general body of ratepayers. 	Further, cost-effective
programs for low-income households continue to be screened out by the use of
the RIM test. (Marcelin)
Nucor: 	Nucor is willing to enter into a Type 2 stipulation on this issue such that Nucor
does not oppose DEF’s position. However, if the Commission does not approve
issues 8b and 12 as agreed to in the 2024 Settlement Agreement filed in Docket
No. 20240025-EI, Nucor reserves the right to take the following position: No.
DEF’s cost-effectiveness tests systematically understate the value of the CS and
IS programs. Further, DEF’s chosen avoided cost generating unit (a brownfield
combustion turbine), does not reflect actual planned additions and retirements and
therefore understates the value of DEF’s proposed DSM programs. Nucor takes
no position regarding the other utilities.
PCS
Phosphate: 	No. DEF’s proposed goals are based on a cost-effectiveness test reflecting an
assumed avoided 2029 brownfield CT. It is more appropriate to use a greenfield
CT to evaluate avoided marginal generation costs. To the extent that DEF’s goals
and proposed utility incentives would change under such an assumption, DEF’s
current proposed goals are not reasonable and do not reflect the costs to

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 29
ratepayers as a whole. However, subject to Commission approval of the proposed
stipulation of Issue # 8(b), PCS is conditionally willing to stipulate this issue.
SACE: 	No. Although proposals in these dockets rely less rigorously on the Rate Impact
Measure (“RIM”) Test than in past dockets, application of the RIM Test
nevertheless resulted in utilities ruling out most DSM measures, which has the
effect of precluding investments that would quickly reduce electric bills for
customers who participate in DSM programs, and that would ultimately reduce
electric bills for non-participating customers through cost savings across the
electric system. Notwithstanding the long practice of the Commission and FEECA
utilities, the use of the RIM Test is contrary to Section 366.82(3)(b), F.S., because
the RIM Test does not reflect “costs and benefits to the general body of ratepayers
as a whole, including utility incentives and participant contributions.” The RIM
Test focuses exclusively on rates. It excludes both the participants’ contributions
and the participants’ benefits, which come in the form of reduced energy
expenditures and lower energy bills. Because the Total Resource Cost (“TRC”)
Test better satisfies this legislative mandate, the Commission should require an
expansion of its use.
Walmart: 	Walmart takes no position as to any of the utility's positions except for DEF's
litigation position, which has now been resolved pursuant to the Stipulation
referenced in Section VII. below.
STAFF: 	No position.
ISSUE 5: 	Do the utility’s proposed goals adequately reflect the need for incentives to
promote 	both 	customer-owned 	and 	utility-owned 	energy 	efficiency 	and
demand side renewable energy systems?
FPL: 	Yes. Cost-effective incentives for participating customers are reflected in FPL’s
proposed DSM Goals because they are included and considered in the Participant
and RIM screening tests and the Participant and TRC screening tests required by
Rule 25- 17.0021(3), Florida Administrative Code. There is no need to establish
incentives for utilities in this proceeding. (Floyd, Whitley)
DEF: 	Yes, the utility’s updated proposed Recommended goals adequately reflect the
need for incentives to promote both customer-owned and utility-owned energy
efficiency systems. DEF does not believe there is currently a need for incentives
to promote demand-side renewable energy systems as the demand-side renewable
market has continued to mature and there has been significant growth in customer
sited demand-side renewable energy systems. Florida currently ranks among the
top ten states based on the cumulative amount of solar electric capacity installed.
The cost to install solar has dropped significantly in recent years, and with that,

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 30
DEF is seeing continued growth in the number of customers installing demand-
side renewable systems on their own, without incentives from the utility. (Duff)
TECO: 	Yes. 	For 	measures 	that 	remained 	cost-effective 	after 	taking 	into 	account
administrative costs but with no incentives, and after the two-year payback screen,
Tampa Electric designed the proposed DSM programs that would maximize the
proposed DSM goal amounts. Demand side renewable systems proved to remain
non-cost effective. In addition, Tampa Electric does not believe incentives for
demand side renewable systems are necessary due to the large amount of naturally
occurring installations of these systems. (Roche)
JEA: 	Yes. 	JEA has comprehensively analyzed customer-owned energy efficiency
measures and only one program was found to be cost-effective. JEA's load
forecast reflects the impacts of net metering associated with customer-owned
rooftop 	solar 	photovoltaic 	(“PV”) 	systems, 	and 	this 	load 	forecast 	was
incorporated 	in 	the 	cost-effectiveness 	analysis 	performed 	for 	demand-side
renewable energy (“DSRE”) systems in this docket, which found no DSRE
measures were cost-effective under the RIM Test. JEA also reviewed current
FEECA programs and evaluated updates to incentives for these programs. As
such, 	incentives 	to 	promote 	customer-owned 	energy 	efficiency 	and 	DSRE
systems are adequately reflected in JEA's proposed goals. Utility-owned energy
efficiency and renewable energy systems are supply-side issues. (Pippin, Kushner,
Herndon)
OUC: 	Yes. OUC’s proposed goals adequately reflect the need for incentives to promote
both customer-owned and utility-owned energy efficiency and demand-side
renewable energy systems. (Herndon, Noonan)
FDACS: 	In determining whether the proposed goals reflect the need for incentives to
promote both customer-owned and utility-owned energy efficiency and demand-
side renewable energy systems, the Commission should examine and consider the
impact of state and local building codes and appliance efficiency standards on the
need for utility-sponsored measures and programs. The Commission should
consider policy options that can be implemented to achieve least-cost strategies that
take into account the costs and benefits of the programs and their impact on all
ratepayers.
FIPUG: 	No position.
FL Rising/
ECOSWF/
LULAC: 	No. The continued use of the arbitrary two-year payback screen artificially limits
available energy efficiency measures, especially for low-income communities.
(Marcelin)

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 31
Nucor: 	Nucor is willing to enter into a Type 2 stipulation on this issue such that Nucor
does not oppose DEF’s position. However, if the Commission does not approve
issues 8b and 12 as agreed to in the 2024 Settlement Agreement filed in Docket
No. 20240025-EI, Nucor reserves the right to take the following position: DEF’s
proposed CS and IS credits do not adequately incentivize continued or additional
participation in the CS and IS programs. Nucor takes no position regarding the
other utilities.
PCS
Phosphate: 	No, but, subject to Commission approval of the proposed stipulation of Issue #
8(b), PCS is conditionally willing to stipulate this issue.
SACE: 	No. The utilities’ analyses to arrive at their proposed goals over-rely on the RIM
Test and arbitrarily apply a two-year payback screen to address “free-ridership”
even though a shorter payback timeframe might be necessary to appropriately
incentivize consumer adoption of energy efficiency measures.
Walmart: 	Walmart takes no position.
STAFF: 	No position.
ISSUE 6: 	Do the utility’s proposed goals adequately reflect the costs imposed by state
and federal regulations on the emissions of greenhouse gases?
FPL: 	Yes. Consistent with the direction provided in the Order Establishing Procedure
for this docket (Order No. PSC-2024-0022-PCO-EG), FPL did not account for
projected CO2 compliance costs in these screening tests. Rather, because FPL
considers CO2 compliance costs in all of its other resource planning analyses,
FPL analyzed the impact of projected CO2 compliance costs in a sensitivity
screening analysis, which are reflected in Exhibit AWW-3. (Whitley)
DEF: 	Yes. Given the uncertainty of future carbon regulation, it is reasonable to exclude
the cost of carbon emissions in this goal setting process. (Duff)
TECO: 	Yes. Currently, there are no state or federal regulations on the emissions of
greenhouse gases nor is there any time horizon established on which any such
regulation may be enacted. 	Therefore, the appropriate greenhouse gas emissions
cost utilized by Tampa Electric in the determination of its proposed DSM goals was
zero. (Roche)
JEA: 	Yes. At the time JEA’s proposed goals were filed in this docket, there were no
existing or pending regulations that would impose costs for the emissions of
greenhouse gases (“CO 2”). The U.S. Environmental Protection Agency (“EPA”)

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 32
has since adopted rules that will potentially limit or otherwise affect the operation
of some new and existing generating units, but do not assess a direct cost of
emissions of CO2 . 	Furthermore, the new regulations do not apply within the
planning period for this FEECA goal-setting proceeding. 	JEA performed a
sensitivity analysis that considered a 25% increase to the avoided energy costs,
which may be viewed as a proxy for the potential impact of costs associated with
possible future regulations of CO2 emissions.
OUC: 	Yes. Even though at this time there are no costs imposed by either state or federal
regulations on emissions of greenhouse gases, OUC engaged RI to conduct a
sensitivity analysis of the potential costs of future greenhouse gas regulations on
the 	cost-effectiveness 	of 	potential 	energy 	efficiency 	program, 	and 	OUC
considered these results in developing its proposed goals and FEECA programs.
(Herndon, Kushner)
FDACS: 	The utilities’ proposed goals appear to adequately reflect the costs imposed by state
and federal regulations currently in existence, on the emission of greenhouse gases
over the past five years.
FIPUG: 	No position.
FL Rising/
ECOSWF/
LULAC: 	No. Nothing pertinent to this question has changed since March 25, 2024, when
the 	Commission, 	in 	Order 	No. 	PSC-2024-0078-FOF-EI, 	based 	key 	cost-
effectiveness findings on imminent high carbon-costs taking effect in less than 18
months (January of 2026). Either the Commission was wrong then, or those same
carbon costs should be reflected in this proceeding.
Nucor: 	No position.
PCS
Phosphate: 	No position.
SACE: 	No.
Walmart: 	Walmart takes no position.
STAFF: 	No position.
ISSUE 7: 	Do the utility’s proposed goals appropriately reflect consideration of free
riders?

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
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PAGE 33
FPL: 	Yes. FPL’s proposed Goals reflect consideration of free riders, as required by Rule
25-17.0021(3), Florida Administrative Code. FPL utilized the two-year payback
screening criterion to minimize the impact of “free riders.” The two-year payback
criterion is a reasonable mechanism previously approved by the Commission to
screen out measures with a short payback that, by including in a DSM program,
would result in unnecessary expense for all customers as these measures already
have a reasonable economic payback. However, FPL’s proposed Low Income
program does include measures with less than a two-year payback, as FPL
recognizes that low-income customers may not have the financial resources to
make energy-efficiency investments regardless of the payback period. (Floyd,
Whitley)
DEF: 	Yes. The DEF’s updated proposed Recommend goals are based on measures that
have greater than a two-year payback period. A two-year payback period is a
reasonable time-period in which to limit measures and assume that customers will
adopt 	the 	measures 	absent 	a 	utility 	incentive. 	This 	time-period 	has 	been
recognized by the Commission in past proceedings as a reasonable proxy to
eliminate free riders. (Duff, Herndon).
TECO: 	Yes. 	Tampa Electric utilized a longstanding Commission practice, initially
approved in the 1994 DSM goals proceeding, of screening out measures having a
payback period of two years or less without any incentive. This two-year payback
criterion is the appropriate means to apply to consider free ridership as required by
the Commission's rule. Tampa Electric also provided sensitivities of one and three-
year paybacks due to considering free ridership with this method. (Roche)
JEA: 	Yes. The screening criteria were based on simple payback to the customer (2
years of less) and were designed to remove measures from the achievable
potential forecasts that exhibit the key characteristic most associated with high
levels of free-ridership in utility rebate programs, i.e., measures with naturally
high 	levels 	of 	cost-effectiveness 	to 	the 	customer. 	The 	sensitivity 	of 	total
achievable 	potential 	to 	this 	particular 	screening 	criterion 	was 	tested 	using
alternative simple payback screening values (1 year and 3 years). In addition to
this screening step, the naturally occurring analysis performed in estimating
achievable potential represents an estimate of the amount of "free riders" that are
reasonably expected to participate in the particular program offering simulated. In
this sense, the payback-based screening criteria were implemented to develop
portfolios with necessarily low free-ridership levels, and within the achievable
potential forecasts for those portfolios, the forecasting methodology produces
explicit estimates of the expected level of free-ridership within those programs.
(Pippin, Herndon)
OUC: 	Yes. 	OUC’s proposed goals appropriately reflect consideration of free riders by
application of the two-year payback screen that the Commission has approved for

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 34
the past 30 years. 	The free ridership issue is important because free riders, by
definition, are customers who receive incentive payments, paid for by OUC’s
other 	customers, 	to 	implement 	DSM 	measures 	that 	they 	would 	otherwise
implement without any utility-funded incentive payment to do so. In other words,
where free ridership occurs, all OUC customers are paying unnecessarily for the
conservation benefits provided by the free rider’s DSM measures. 	Based on the
PSC’s consistent approval of the two-year payback screen over the past 30 years,
OUC has come to believe that the two-year screen strikes a reasonable and
appropriate balance between the desire for greater energy conservation and the
desire to avoid the adverse economic effects of free ridership, i.e., that free riders
cause all customers to pay more than necessary to achieve the conservation
benefits flowing from free riders’ participation in DSM programs. 	(Herndon,
Noonan)
FDACS: 	In considering whether the utilities’ proposed goals appropriately reflect free riders,
the Commission should consider policy options that take into account the payback
period of the proposed program measures consistent with prior Commission
practice.
FIPUG: 	No position.
FL Rising/
ECOSWF/
LULAC: 	No. The continued use of the two-year payback screen is not backed by empirical
evidence and results in double-counting for freeriders resulting in otherwise cost-
effective measures being screened out, especially measures that are important to
low-income communities. (Marcelin)
Nucor: 	No position.
PCS
Phosphate: 	No position.
SACE: 	No. Blanket use of two-year payback screen is an inappropriate method to address
free ridership because it is assigned arbitrarily and is not based on evidence of the
behavior of actual customers. The concept of the two-year payback screen wrongly
assumes that a customer who is able to do so will take advantage of any measure
that has return that pays for itself within 2 years from its implementation. A
customer might never become aware of such measure without an incentive or rebate
tied to it. A customer might not understand the calculation to determine the payback
period or know where to find the information to make the calculation. Rather than
a ”free rider,” a customer might be a “fence sitter” and be motivated by an incentive
to participate, even though the return on investment offers a short payback. A
customer that does not fall within the low-income category can nevertheless feel

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 35
budget constraints or cash flow limitations that restrain participation in the absence
of an incentive. In making improper assumptions instead of using data to identify
free riders, the two-year payback screen makes the cost-effectiveness tests even
more restrictive and rejects the easiest and cheapest savings. The Commission
should require utilities to adopt a data-driven methodology like those used in other
jurisdictions, or at a minimum, should reduce the payback period to 1 year.
Walmart: 	Walmart takes no position.
STAFF: 	No position.
ISSUE 8A: 	Should demand credit rates for interruptible service, curtailable service,
stand-by generation, or similar potential demand response programs be
addressed in this proceeding or in the base rate proceedings for the rate
regulated FEECA Utilities?
FPL: 	For FPL, this is not the appropriate proceeding to reset the Commercial and
Industrial Load Control (CILC) and Commercial Demand Response (CDR) credits
for FPL’s commercial and industrial demand response programs. 	The current
CILC and CDR credits were set in FPL’s 2021 Rate Case Settlement Agreement,
which was approved by the Commission in Order Nos. PSC-2021-0446-S-EI,
PSC-2021-0446A-S-EI and PSC-2024-0078-FOF-EI. Importantly, Paragraph 4(e)
of the FPL 2021 Base Rate Case Settlement provides, in pertinent part, that the
CILC and CDR credits are to be reset in a general base rate proceeding. (Floyd)
DEF: 	Absent 	a 	comprehensive 	settlement 	agreement 	approved 	in 	a 	separate
Commission docket (e.g., in a rate case settlement), under 25-17.0021(1), the
credit rates should be addressed in this proceeding for the rate-regulated FEECA
Utilities.
TECO: 	Credit 	rates 	are 	normally 	addressed 	in 	the 	Commission’s 	demand-side
management dockets. These credit rates, however, may also be addressed in
utility base rate cases. One illustration is Tampa Electric’s 2021 Settlement
Agreement, which established the company’s current standby generator credit and
commercial demand response credit rates.
JEA: 	This issue does not apply to JEA. As such, JEA takes no position.
OUC: 	This Issue 8 is not at issue for OUC.
FDACS: 	No position on this ratemaking issue.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 36
FIPUG: 	The demand credit rates for interruptible service, curtailable service, stand-by
generation, or similar potential demand response programs should be addressed in
the 	base 	rate 	proceedings 	for 	the 	rate 	regulated 	FEECA 	Utilities. 	This
Commission and recent Commissions have adjusted demand credit rates in base
rate cases. Base rate proceedings often result in settlement agreements, in which
credit adjustments are part and parcel of a negotiated outcome which must pass a
public interest test. 	Setting these demand credit rates set in base rate cases
provides clear and unambiguous notice that the proper venue in which to consider
this issue is a respective utility’s base rate case. Adopting the Commission’s past
practice of establishing demand credit rates for interruptible service, curtailable
service, stand-by generation, or similar potential demand response programs in a
utility’s base rate case is more efficient, since affected intervenors will not have to
file testimony in two dockets, the company’s goals docket and the company’s
base rate case docket.
FL Rising/
ECOSWF/
LULAC: 	This proceeding.
Nucor: 	This issue is inappropriate for consideration in this docket. 	The credits for
interruptible service, curtailable service, standby generation or similar tariff-based
demand response programs should be set in base rate proceedings, where all the
rates, terms and conditions of such tariffs may be considered.
PCS
Phosphate: 	All adjustments to the rates, terms and conditions of tariff-based DEF demand
response programs should be made in base rate proceedings.
SACE: 	Adopts the position of Florida Rising, LULAC, and ECOSWF.
Walmart: 	This is a legal issue which should be handled the same way for each of the rate-
regulated Florida Energy Efficiency and Conservation Act ("FEECA") Utilities:
FPL, DEF, and TECO. Demand credit rates for interruptible service, curtailable
service, stand-by generation, or similar potential demand response programs
(collectively, "credits") should be set in base rate proceedings for FPL, DEF, and
TECO for the following reasons:
1. 	For consistency with the Commission's and rate-regulated FEECA
Utilities' 	addressing 	and 	adjusting 	credits 	in 	prior 	base 	rate
proceedings for each of the rate-regulated FEECA Utilities;
2. 	For compliance with Settlement Agreements in base rate proceedings
wherein agreements on the credits have been addressed and resolved,
such 	as 	the 	approved 	2021 	TECO 	Base 	Rate 	Case Settlement

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 37
Agreement in Docket 20210034-EI, approved 2021 FPL Base Rate
Case Settlement Agreement in Docket 20210015-EI, and filed 2024
DEF Settlement Agreement in Docket 20240025-EI, for which review
by the Commission is forthcoming;
3. 	For consistency with the rate-regulated FEECA Utilities' tariff-filing
requirements per Fla. Admin. Code. Rules 25-9.007, R. 9.031, and R.
9.068;
4. 	For consistency with FEECA, which is not a base rate proceeding but
a 	forward-looking, 	conservation 	goal 	setting 	process 	to 	address
technical and economic potential to achieve efficiency, but where the
benefits for the interruptible and curtailable services programs are
understated, which could potentially impact customer deployment of
dispatchable DER to support grid reliability and resilience; and
5. 	For process efficiency, so this issue is handled in only one Docket for
each of the rate-regulated FEECA Utilities and participating parties,
not both.
STAFF: 	No position.
ISSUE 8B: 	If this proceeding, what demand credit rates are appropriate for purposes of
establishing the utilities’ goals?
FPL: 	Not applicable. The appropriate demand credits for FPL’s CILC and CDR
programs in this proceeding are the credits approved by the Commission in Order
Nos. PSC-2021-0446-S-EI, PSC-2021-0446A-S-EI and PSC-2024-0078-FOF-EI.
(Floyd)
DEF: 	The Stipulating Parties reserve the right to take positions on Issue 8(a). However,
for purpose of Stipulation, and in accordance with the provisions of the 2024
Settlement Agreement filed contemporaneously in Docket No. 20240025-EI, the
parties agree to stipulate the level of demand credit rates. The Stipulation on Issue
8(b) to set the level of credits should not be construed to indicate that parties have
agreed that the DSM goals case is the proper forum to set the level of credits, and
acceptance of the Stipulations as to the level of credits should be considered
independently of the question of where the credits should be set. The following
levels of clause-recoverable credits for Interruptible (“IS”), Curtailable (“CS”),
and Standby Generation (“GSLM-2”) customers shall be in effect beginning with
the first billing cycle of 2025:

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 38
Customer Type 	Credit Level
IS 	$8.00/kw‐month
CS 	$8.00/kw‐month
GSLM‐2 	$8.11 x C + $0.10 x kwh monthly
No changes in these credits shall be implemented any earlier than the effective
date of new DEF base rates implemented pursuant to a general base rate
proceeding, and that such new IS/CS/GSLM-2 credits shall only be implemented
prospectively from such effective date. At such time as DEF’s base rates are reset
in a general base rate proceeding, the IS/CS/GSLM-2 credits shall be reset. In the
next Demand Side Management goals and plan approval proceeding (currently
anticipated to occur in 2029), DEF shall not propose to change the level of the
credits.
TECO: 	Tampa Electric proposes the following appropriate demand credit rates for
curtailable service, stand-by generation, or similar demand response programs
(other than GSLM 2 & 3) for the 2025-2034 period:
Residential Programs:
Prime Time Plus 	Appliance Controlled 	Monthly Credit
Electric Water Heater 	$6.00
Heating and Cooling Equipment 	$12.00
Swimming Pool Pump 	$3.00
Level II Electric Vehicle Charger 	$9.00
Commercial/Industrial Programs:
Demand Response
Monthly Credit: $6.15 per kW of transferrable or curtailable load
Commercial Load Management (GSLM 1)
Monthly Credit: 	$5.00 per kW of demand reduction (cyclic control)
$5.50 per kW of demand reduction (extended control)
Standby Generator
Monthly Credit: $6.15 per kW of transferrable load
JEA: 	This issue does not apply to JEA. As such, JEA takes no position.
OUC: 	This Issue 8 is not at issue for OUC.
FDACS: 	No position on this ratemaking issue.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 39
FIPUG: 	Should the Commission not adopt the stipulation flowing from the pending DEF
Settlement Agreement with FIPUG and a number of other parties, and should the
Commission decide to handle demand credit rates in this docket rather than DEF’s
base rate case, the Commission should adopt the DEF demand credits as proposed
by FIPUG witness Jeff Pollock of $9.15 per kW per month. While TECO and
FPL are contractually precluded from addressing the demand credits outside of
their respective base rate cases by in place settlement agreements, should the the
Commission decide to address the demand credit rates in this docket, the demand
credit rates of both companies should not be changed or increased by the
consumer price index.
FL Rising/
ECOSWF/
LULAC: 	Interruptible and curtailable service programs should not be used by utilities in
setting conservation goals when the service never actually gets interrupted.
Because of this fatal flaw in the program, the general body of ratepayers
essentially provides funding for commercial and industrial entities to receive
energy savings credits without actually bearing any burden. 	For this reason, the
Commission should dramatically cut (or eliminate) the demand credit rates in the
FPL docket and cut the demand credit rates in the TECO docket. 	(Marcelin
testimony). 	For the DEF docket, Florida Rising and LULAC have stipulated to
the following position: The Stipulating Parties reserve the right to take positions
on Issue 8(a). 	However, for purpose of Stipulation, and in accordance with the
provisions of the 2024 Settlement Agreement filed contemporaneously in Docket
No. 20240025-EI, the parties agree to stipulate the level of demand credit rates.
The Stipulation on Issue 8(b) to set the level of credits should not be construed to
indicate that parties have agreed that the DSM goals case is the proper forum to
set the level of credits, and acceptance of the Stipulations as to the level of credits
should be considered independently of where the credits should be set. 	The
following levels of clause-recoverable credits for Interruptible (“IS”), Curtailable
(“CS”), and Standby Generation (“GSLM-2”) customers shall be in effect
beginning with the first billing cycle of 2025:
Customer Type 	Credit Level
IS 	$8.00/kw-month
CS 	$8.00/kw-month
GSLM-2 	$8.11 x C + $0.10 x kwh monthly
No changes in these credits shall be implemented any earlier than the effective
date of new DEF base rates implemented pursuant to a general base rate
proceeding, and that such new IS/CS/GSLM-2 credits shall only be implemented
prospectively from such effective date. At such time as DEF’s base rates are reset
in a general base rate proceeding, the IS/CS/GSLM-2 credits shall be reset. In the
next Demand Side Management goals and plan approval proceeding (currently

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 40
anticipated to occur in 2029), DEF shall not propose to change the level of the
credits.
Nucor: 	The Stipulating Parties reserve the right to take positions on Issue 8(a). However,
for purpose of Stipulation, and in accordance with the provisions of the 2024
Settlement Agreement filed contemporaneously in Docket No. 20240025-EI, the
parties agree to stipulate the level of demand credit rates. The Stipulation on Issue
8(b) to set the level of credits should not be construed to indicate that parties have
agreed that the DSM goals case is the proper forum to set the level of credits, and
acceptance of the Stipulations as to the level of credits should be considered
independently of the question of where the credits should be set. The following
levels of clause-recoverable credits for Interruptible (“IS”), Curtailable (“CS”),
and Standby Generation (“GSLM-2”) customers shall be in effect beginning with
the first billing cycle of 2025:
Customer Type 	Credit Level
IS 	$8.00/kw‐month
CS 	$8.00/kw‐month
GSLM‐2 	$8.11 x C + $0.10 x kwh monthly
No changes in these credits shall be implemented any earlier than the effective
date of new DEF base rates implemented pursuant to a general base rate
proceeding, and that such new IS/CS/GSLM-2 credits shall only be implemented
prospectively from such effective date. At such time as DEF’s base rates are reset
in a general base rate proceeding, the IS/CS/GSLM-2 credits shall be reset. In the
next Demand Side Management goals and plan approval proceeding (currently
anticipated to occur in 2029), DEF shall not propose to change the level of the
credits.
PCS
Phosphate: 	The Commission should approve the revised credit rates that are set forth in the
Joint Notice of Necessary Stipulations filed on July 15, 2024. If the Commission
does not approve the stipulated credit levels, but chooses nonetheless to set DEF’s
CS and IS credit rates in this proceeding, the Commission should adopt a CS and
IS credit level of at least $9.00/kW-month as recommended in the testimony of
Florida Industrial Power Users Group witness Jeffry Pollock. This level is based
on a more reasonable avoided generation unit of a greenfield CT.
SACE: 	Adopts the position of Florida Rising, LULAC, and ECOSWF.
Walmart: 	For FPL, this issue is moot because of FPL's 2021 Base Rate Case Settlement
Agreement, which was approved by the Commission in Order Nos. PSC-2021-
0446-S-EI, PSC-2021-0446A-S-EI and PSC-2024-0078-FOF-EI. Paragraph 4(e)

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 41
of the FPL 2021 Base Rate Case Settlement Agreement provides that the
Commercial 	Industrial 	Load 	Control 	("CILC") 	and 	Commercial/Industrial
Demand Reduction ("CDR") credits are to be reset in a general base rate
proceeding.
For TECO, this issue is moot because of TECO's 2021 Base Rate Case Settlement
Agreement, which was approved by the Commission in Order No. Order No.
PSC-2021-0423-S-EI, 	establishes 	standby 	generator 	credit 	and 	commercial
demand response credit rates. TECO proposes to maintain these credit values in this
proceeding.
For DEF, this issue is moot because of the Joint Notice of Necessary Stipulations
to Issues 8(b) and 12 by DEF, Florida Industrial Power Users Group ("FIPUG"),
Nucor Steel Florida, Inc. ("Nucor"), White Springs Agricultural Chemical, Inc.
d/b/a PCS Phosphate – White Springs ("PCS Phosphate"), Walmart, Florida
Rising, Inc. ("Florida Rising"), and LULAC Florida, Inc. ("LULAC") filed in
Docket 20240013-EG on July 15, 2024.
STAFF: 	No position.
ISSUE 9: 	Should the savings associated with FPL’s Residential Low Income Renter
Pilot program be included in its conservation goals?
FPL: 	Yes. FPL’s Residential Low Income Renter Pilot program is a new DSM measure
that allows low-income renters to receive the energy-saving benefit of more
efficient HVAC equipment while keeping the landlord whole from a capital
investment perspective. Under this new low-income program, FPL will pay the
incremental cost of a more efficient HVAC unit, up to $1,000, such that a landlord
replacing an HVAC unit for a tenant property will essentially pay the same cost
for the more efficient HVAC unit as they would have for a less efficient/standard
HVAC unit. This will eliminate the disincentive the landlord has to make an
incremental investment in energy-efficient equipment while allowing the low-
income renter to receive the benefit of the more efficient HVAC equipment on their
energy consumption and electric bill. FPL is proposing to limit this program to
three years with an annual cap of 500 participants in order to test and evaluate the
effectiveness of this new program and determine if a similar low-income program
should be offered in the future. (Floyd)
DEF: 	No position.
TECO: 	No position. (Roche)
JEA: 	This issue does not apply to JEA. As such, JEA takes no position.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 42
OUC: 	This Issue 9 is not at issue for OUC.
FDACS: 	No position on this utility-specific issue.
FIPUG: 	No position.
FL Rising/
ECOSWF/
LULAC: 	FL Rising, ECOSWF, and LULAC retain concerns with the logistics surrounding
the Residential Low Income Renter Pilot Program. The proposed $1,000 credit
may not be enough to upgrade to a more efficient HVAC unit and FPL falsely
assumes that simply because it is providing this credit, landlords will not use the
upgraded HVAC system as an excuse to raise rent to recover installation costs.
However, Florida Rising, ECOSWF, and LULAC do not believe FPL’s proposed
goals, as they are very low relative to the size of the utility, should be cut if this
program is not approved. (Marcelin)
Nucor: 	No position.
PCS
Phosphate: 	No position.
SACE: 	The Commission should require FPL to demonstrate that the incentive to a landlord
to upgrade HVAC units will not result in higher rents for tenants as a consequence
of the landlord’s portion of the cost being recovered through rent increases.
Nevertheless, even if the program is not approved, FPL’s goals should not be
reduced.
Walmart: 	Walmart takes no position.
STAFF: 	No position.
ISSUE 10: 	Is FPL’s proposed HVAC On-Bill option for its existing Residential On-Call
program with its associated HVAC Services Agreement (proposed Tariff
sheets 9.858 through 9.866) a regulated activity within the jurisdiction of the
Commission? If not, should the savings associated with FPL’s HVAC On-Bill
option and HVAC Services Agreement be removed from its conservation
goals?
FPL: 	Yes. FPL’s proposed HVAC On-Bill option expands the existing On Call ® load-
management program to allow greater customer access to new energy-saving
HVAC equipment in a way that also passes the RIM cost-effectiveness test. In
direct support of FPL’s production, transmission, and delivery of electric power to

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 43
its customers, the voluntary HVAC On-Bill tariff program will provide interested
customers with an opportunity to acquire a new, more energy-efficient HVAC unit
for a fixed monthly charge, and FPL will have the ability to control that HVAC
unit in peak demand situations with this load-control measure. The forecasted
peak demand reductions arising from the On- Bill Program will be factored into
the resource planning for FPL’s generation system required to serve customers.
See § 366.02(4), Fla. Stat. 	Consistent with the goals and provisions of Sections
366.81 and 366.82, Florida Statutes, this proposed DSM program will focus on
the highest priorities of weather-sensitive peak demand while also providing
benefit to the general body of customers from the avoided capacity savings related
to FPL retaining control of the HVAC equipment. 	This proposed regulated
activity 	represents 	an 	efficiency 	investment 	across 	FPL’s 	generation,
transmission, and distribution as well as within its customer base. (Floyd)
DEF: 	No position.
TECO: 	No position. (Roche)
JEA: 	This issue does not apply to JEA. As such, JEA takes no position.
OUC: 	This Issue 10 is not at issue for OUC.
FDACS: 	No position on this utility-specific issue.
FIPUG: 	No position.
FL Rising/
ECOSWF/
LULAC: 	No. FPL’s HVAC On-Bill option for its Residential On-Call program essentially
gives FPL the role of a middleman or salesman for its contracted HVAC
providers. Because this eventually results in the sale of the HVAC system, which
FPL concedes is transferred into ownership of the customer at the end of the
program period, this should not be considered a regulated activity falling under
the Commission’s jurisdiction. However, given how low FPL’s proposed goals
are and how they should be increased to reflect the cost-effective reasonably
achievable potential for energy efficiency in its territory, the savings associated
with the program should not be removed from FPL’s conservation goals.
Nucor: 	No position.
PCS
Phosphate: 	No position.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 44
SACE: 	With respect to the first question in this issue, adopts the position of FPL. With
respect to the second question in this issue, FPL’s goals should not be reduced,
regardless of how the Commission answers the first question.
Walmart: 	Walmart takes no position.
STAFF: 	No position.
ISSUE 11: 	Should the Commission approve FPL’s proposed plan to cap participation for
non- RIM Test passing programs once sector-level goals are achieved?
FPL: 	Yes. FPL’s proposed DSM Goals include both RIM- and TRC-passing programs,
which 	will 	allow 	FPL 	to 	continue 	delivering 	meaningful 	energy-efficiency
savings options to all customers including owners, renters, and low-income
customers. RIM-passing programs result in the lowest rate impact, benefit all
customers, and avoid cross-subsidization of participants by non-participants.
TRC-passing measures can expose all utility customers, whether they participate
in a DSM program or not, to higher electric rates. 	Thus, as an appropriate
guardrail on such measures, FPL proposes to limit costs of non-RIM passing
programs by capping participation once sector-level goals are met, which is
consistent with FPL’s last two Commission-approved DSM Plans. This limitation
on 	participation 	would 	only 	apply 	to 	non-RIM-passing 	energy 	efficiency
programs and provides a way to limit overall portfolio costs while still making
valuable energy savings programs available to FPL customers. (Floyd)
DEF: 	No position.
TECO: 	No position. (Roche)
JEA: 	This issue does not apply to JEA. As such, JEA takes no position.
OUC: 	This Issue 11 is not at issue for OUC.
FDACS: 	No position on this utility-specific issue.
FIPUG: 	No position.
FL Rising/
ECOSWF/
LULAC: 	No. 	This could artificially cap participation in low-income programs, which
should remain uncapped given how low they are in relation to other utilities in
Florida.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 45
Nucor: 	No position.
PCS
Phosphate: 	No position.
SACE: 	No. FPL’s goals are inappropriately low relative to its size and given their relation
to the goals of other utilities in Florida. Any cap could result in reduced
participation by customers, including low-income customers.
Walmart: 	Walmart takes no position.
STAFF: 	No position.
ISSUE 12: 	What residential and commercial/industrial summer and winter megawatt
(MW) and annual Gigawatt-hour (GWh) goals should be established for the
period 2025- 2034?
FPL: 	The proposed DSM goals based on the FPL Proposed Resource Plan are 419 MW
Summer demand, 326 MW Winter demand, and 931 GWh energy reduction for
the period 2025 through 2034. (Floyd, Whitley)
2025 	2026 	2027 	2028 	2029 	2030 	2031 	2032 	2033 	2034 Cumulative
Summer MW
Residential 	26.22 	26.46 	26.85 	26.87 	26.99 	27.15 	27.36 	27.59 	27.87 	28.18 	271.54
Commercial/Industrial 	16.24 	16.26 	16.28 	13.89 	13.94 	14.00 	14.05 	14.11 	14.17 	14.23 	147.17
Total1 	42.46 	42.72 	43.13 	40.76 	40.93 	41.15 	41.41 	41.70 	42.04 	42.41 	418.71
Winter MW
Residential 	20.76 	21.65 	22.75 	23.15 	23.62 	24.12 	24.66 	25.24 	25.85 	26.51 	238.32
Commercial/Industrial 	9.65 	9.68 	9.71 	8.28 	8.33 	8.38 	8.43 	8.48 	8.54 	8.59 	88.06
Total1 	30.42 	31.34 	32.46 	31.43 	31.94 	32.50 	33.09 	33.72 	34.39 	35.10 	326.38
Annual GWh
Residential 	43.71 	43.00 	42.39 	41.42 	40.99 	40.65 	40.38 	40.18 	40.03 	39.93 	412.68
Commercial/Industrial 	48.40 	49.13 	49.87 	50.60 	51.37 	52.15 	52.95 	53.76 	54.58 	55.42 	518.24
Total1 	92.11 	92.13 	92.26 	92.02 	92.37 	92.81 	93.33 	93.94 	94.61 	95.35 	930.93
(1) Totals may not add due to rounding.
DEF: 	DEF’s energy efficiency goals will reflect their proposed goals, plus an increase
in participation for Neighborhood Energy Saver by 10% and an increase the
installation of smart thermostats from 10% to 40%. This results in the following
goals for the 10-year period:

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 46
(Duff)
TECO: 	Tampa Electric proposes the following residential and commercial/industrial
summer and winter megawatt (MW) and annual Gigawatt-hour (GWh) goals
should be established for the period 2025-2034 in the charts below:
Tampa Electric's
2025-2034 Proposed Residential
DSM Goals at the Generator
Year
Summer Demand
(MW)
Winter Demand
(MW)
Annual Energy
(GWh)
Incremental 	Incremental 	Incremental
2025 	7.8 	13.8 	24.2
2026 	7.8 	13.8 	24.2
2027 	8.7 	14.4 	24.8
2028 	8.5 	14.3 	24.2
2029 	8.5 	14.3 	24.2
2030 	9.5 	15.0 	25.2
2031 	9.4 	14.9 	24.7
2032 	9.4 	14.9 	24.7
2033 	9.5 	15.0 	25.2
2034 	9.4 	14.9 	24.7
The cumulative effect of these residential goals through 2034 would be a summer
MW reduction of 88.6 MW, a winter MW reduction of 145.4 MW and cumulative
energy savings of 246.2 GWh.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 47
Tampa Electric's
2025-2034 Proposed Commercial/Industrial
DSM Goals at the Generator
Year
Summer Demand
(MW)
Winter Demand
(MW)
Annual Energy
(GWh)
Incremental 	Incremental 	Incremental
2025 	6.4 	5.4 	22.2
2026 	6.3 	5.4 	22.2
2027 	6.9 	5.9 	22.3
2028 	6.4 	5.4 	22.3
2029 	6.4 	5.4 	22.3
2030 	5.9 	5.1 	18.6
2031 	5.4 	4.6 	18.6
2032 	5.4 	4.6 	18.6
2033 	6.0 	5.1 	18.6
2034 	5.4 	4.6 	18.6
The cumulative effect of these commercial/industrial goals through 2034 would be
a summer MW reduction of 60.5 MW, a winter MW reduction of 51.7 MW and
cumulative energy savings of 204.4 GWh. (Roche)
JEA: 	The Commission should establish the goals set for in the following table.
Consistent 	with 	the 	goals 	previously 	approved 	by 	the 	Commission, 	JEA’s
proposed numeric conservation goals are based on the DSM programs that JEA
currently offers with some modifications. This goal-setting approach is consistent
with 	the 	Commission’s 	well-established 	policy 	that 	for 	FEECA 	municipal
utilities, such as JEA, “it is appropriate to defer to municipal utilities’ governing
bodies to determine the level of investment if measures are not cost-effective.”
Order No. PSC-2020-0200-PAA-EG, p.5 (June 24, 2020) (citing Order No. PSC-
2015-0324-PAA (Aug. 11, 2015).
The Commission should reject Florida Rising’s proposal that the Commission
order JEA to expand its low-income NEE Program by 500% and increase JEA’s
goals accordingly. Florida Rising’s proposed 5-fold increase is an arbitrary figure
that is not supported by any analysis of achievability or cost-effectiveness as
required by Commission rules. Furthermore, the analyses performed by Resource
Innovations show that residential conservation measures of the type included in
JEA’s NEE Program do not pass the RIM Test, and the NEE Program, as a whole,
does not pass the RIM Test, meaning that the NEE Program puts upward pressure
(i.e., increases) JEA’s rates to its customer. Thus, imposition of Florida Rising’s

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 48
proposal would be inconsistent with the Commission’s long- standing policy
regarding the basis of establishing numeric goals for municipal utilities under
FEECA.
OUC: 	The Commission should approve the FEECA Goals recommended by OUC’s
witness Kevin M. Noonan. 	The following table summarizes OUC’s proposed
MWH Energy Savings, Summer KW Savings, and Winter KW Savings goals for
2025, 2030, and 2034; annual goals are presented in Mr. Noonan’s testimony and
exhibits. (Herndon Kushner, Noonan)
Goal 	2025 	2030 	2034
Summer KW Savings 	590 	580 	890
Winter KW Savings 	560 	730 	810
Energy (NEL) Savings (MWH) 	4,242 	5,760 	6,382
FDACS: 	FDACS has no position as to the appropriate commercial/industrial summer and
winter MW and annual GWh goals that should be established for the 2025-2034
period. However, the Commission should balance the goal of energy efficiency
and conservation with the impact of the costs and benefits of these programs on
rates and overall customer bills.
FIPUG: 	No position.
FL Rising/
ECOSWF/
LULAC: 	The Commission should approve residential goals consistent with the testimony
of Witness Marcelin. Each utility should aim to increase ambition in setting their
summer and winter MW and GWh goals. By increasing goals for participation in
residential energy efficiency goals based on levels of participation prior to cuts to

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
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PAGE 49
energy efficiency goals in 2014, each utility is capable of achieving much more
robust and ambitious MW and GWh goals than currently proposed. (Marcelin)
Nucor: 	DEF’s energy efficiency goals will reflect their proposed goals, plus an increase
in participation for Neighborhood Energy Saver by 10% and an increase in the
installation of smart thermostats from 10% to 40%. This results in the following
goals for the 10-year period:
PCS
Phosphate: 	The Commission should approve the annual residential and commercial/industrial
summer and winter MW and GWh goals that are set forth in the Joint Notice of
Necessary Stipulations filed on July 15, 2024.
SACE: 	Adopts the position of Florida Rising, LULAC, and ECOSWF.
Walmart: 	Walmart takes no position.
STAFF: 	No position.
ISSUE 13: 	What goals, if any, should be established for increasing the development of
demand-side renewable energy systems?
FPL: 	Goals of zero should be established for demand-side renewable energy systems
because such systems are not cost-effective for FPL’s customers. In total, there
were 9 unique demand-side renewable measures evaluated in the goals process.
However, the demand-side renewable measures fail both the RIM and the TRC
economic screening tests. Setting Goals at zero for demand-side renewable energy
systems would be consistent with past Commission practice of setting DSM Goals
at zero for FEECA Utilities when no demand-side renewable measures are cost-
effective, but addressed through the Commission’s net metering program. A Goal

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 50
level of zero would best protect the general body 	of 	customers 	and 	minimize
cross-subsidies between participants and non- 	participants. (Floyd, Whitley)
DEF: 	Given that renewable systems were not deemed cost effective under the RIM test,
it would not be appropriate to establish goals for demand-side renewable systems
in this goal setting proceeding. Demand-side renewable systems were evaluated
using the same criteria used for other energy efficiency measures. Programs that
provide incentives to customers who install renewable systems would result in
cross subsidies between participants and non-participants and increase rates to all
customers. (Duff)
TECO: 	Goals should not be established for increasing the development of demand-side
renewable energy systems as they continue to be non-cost effective. If any goals
are set, they should be set at zero, as these measures are not cost-effective. (Roche)
JEA: 	The cost-effectiveness analysis of demand-side renewable energy systems shows
that they are not cost-effective. Therefore, no goals should be established for
demand-side renewable systems. (Pippin, Herndon)
OUC: 	Because there are no cost-effective demand-side renewable energy measures
available for OUC, the Commission should not approve any numeric goals for
such systems in the current FEECA Goals proceedings. (Herndon)
FDACS: 	The Legislature has declared that it is critical to utilize the most efficient and cost-
effective 	demand-side 	renewable 	energy 	systems. 	The 	Commission 	should
consider policy options that can be implemented to achieve least-cost strategies that
take into account the costs and benefits of the programs and their impact on all
ratepayers.
FIPUG: 	No position.
FL Rising/
ECOSWF/
LULAC: 	Net-metering should be required for all utilities subject to this proceeding in order
to increase the development of demand-side renewable energy systems.
Nucor: 	No position.
PCS
Phosphate: 	No position.
SACE: 	Adopts the position of Florida Rising, LULAC, and ECOSWF.
Walmart: 	Walmart takes no position.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 51
STAFF: 	No position.
ISSUE 14: 	Should these dockets be closed?
IX. 	EXHIBIT LIST
Witness 	Proffered By 	Description
Direct
John F. Floyd 	FPL 	JNF-1 	Historical DSM Participation and
Achievements
John F. Floyd 	FPL 	JNF-2 	Current DSM Programs and
Associated Measures
John F. Floyd 	FPL 	JNF-3 	List of Measures Evaluated for
Technical Potential
John F. Floyd 	FPL 	JNF-4
(Corrected
by Floyd
Errata
filed on
July 12,
2024)
2025-2034 Goals Scenarios and
Potential Programs
John F. Floyd 	FPL 	JNF-5
(Corrected
by Floyd
Errata
filed on
July 12,
2024)
Comparison of Current Programs
to Proposed Programs
Andrew W. Whitley 	FPL 	AWW-1 	Economic Elements Accounted for
in DSM Preliminary Screening
Tests: Benefits & Costs
Andrew W. Whitley 	FPL 	AWW-2 	Summary Results of Preliminary
Economic Screening of Individual
DSM Measures

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
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PAGE 52
Witness 	Proffered By 	Description
Andrew W. Whitley 	FPL 	AWW-3 	Summary Results of Preliminary
Economic Screening of Individual
DSM Measures: Sensitivity Cases
Andrew W. Whitley 	FPL 	AWW-4 	Forecasted Fuel and Environmental
Compliance Costs
Andrew W. Whitley 	FPL 	AWW-5 	Projection of FPL's Resource
Needs for 2024 - 2035 with No
Incremental DSM Signups After
2024
Andrew W. Whitley 	FPL 	AWW-6
(Corrected
by Whitley
Errata
filed on
July 12,
2024)
Comparison of DSM Reasonably
Achievable Summer MW Values
with FPL’s Projected Summer
Resource Needs
Andrew W. Whitley 	FPL 	AWW-7
(Corrected
by Whitley
Errata
filed on
July 12,
2024)
Overview of Supply Only and
With DSM Resource Plans
Andrew W. Whitley 	FPL 	AWW-8 	Levelized System Average
Electric Rate Calculation for the
Supply Only Resource Plan
Andrew W. Whitley 	FPL 	AWW-9 	Levelized System Average Electric
Rate Calculation for the RIM
Resource Plan
Andrew W. Whitley 	FPL 	AWW-10
(Corrected
by Whitley
Errata
filed on
July 12,
2024)
Levelized System Average Electric
Rate Calculation for the FPL
Proposed Resource Plan

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 53
Witness 	Proffered By 	Description
Andrew W. Whitley 	FPL 	AWW-11
(Corrected
by Whitley
Errata
filed on
July 12,
2024)
Levelized System Average Electric
Rate Calculation for the TRC
Resource Plan
Andrew W. Whitley 	FPL 	AWW-12
(Corrected
by Whitley
Errata
filed on
July 12,
2024)
Comparison of the Resource Plans:
Economic Analyses Results
Andrew W. Whitley 	FPL 	AWW-13
(Corrected
by Whitley
Errata
filed on
July 12,
2024)
Additional Cost Needed to be
Added to the RIM Plan to Increase
its Levelized System Average
Electric Rate to That of the TRC
Plan
Andrew W. Whitley 	FPL 	AWW-14
(Corrected
by Whitley
Errata
filed on
July 12,
2024)
Additional Cost Needed to be
Added to the FPL Proposed Plan
to Increase its Levelized System
Average Electric Rate to That of
the TRC Plan
Andrew W. Whitley 	FPL 	AWW-15
(Corrected
by Whitley
Errata
filed on
July 12,
2024)
Comparison of the Resource Plans:
Projection of System Average
Electric Rates and Customer Bills
(Assuming 1,000 kWh Usage)
Andrew W. Whitley 	FPL 	AWW-16 	Comparison of the Resource Plans:
Projection of System Emissions

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 54
Witness 	Proffered By 	Description
Andrew W. Whitley 	FPL 	AWW-17 	Comparison of the Resource
Plans: Projection of System Oil
and Natural Gas Usage
Jim Herndon 	FPL
DEF
TECO
FPUC
JEA
OUC
JH-1 	Herndon Background and
Qualifications
Jim Herndon 	FPL 	JH-2 	TPS for Florida Power Light &
Light Company
Jim Herndon 	DEF 	JH-3 	Technical Potential Study of DSM
for DEF
Jim Herndon 	TECO 	JH-4 	Technical Potential Study for
Tampa Electric Company
Jim Herndon 	FPUC 	JH-5 	Technical Potential Study of
Demand-Side Management in
Florida Public Utilities Company’s
Territory (3-7-2024)
Jim Herndon 	JEA 	JH-6 	TPS for JEA
Jim Herndon 	OUC 	JH-7 	Technical Potential Study for
OUC
Jim Herndon 	FPL
DEF
TECO
FPUC
JEA
OUC
JH-8 	2024 Measure List
Jim Herndon 	FPL
DEF
TECO
FPUC
JEA
OUC
JH-9 	Comparison of Comprehensive
2019 Measure Lists to the 2024
Comprehensive Measure Lists

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 55
Witness 	Proffered By 	Description
Jim Herndon 	DEF 	JH-10 	DEF Measure Screening and
Economic Sensitivities
Jim Herndon 	FPUC 	JH-11 	FPUC Measure Screening and
Economic 23 Sensitivities
Jim Herndon 	JEA 	JH-12 	JEA Measure Screening &
Economic Sensitivities
Jim Herndon 	OUC 	JH-13 	OUC Measure Screening and
Economic Sensitivities
Jim Herndon 	FPUC 	JH-14 	FPUC Program Development
Summary
Jim Herndon 	JEA 	JH-15 	JEA Program Development
Summary
Jim Herndon 	OUC 	JH-16 	OUC Program Development
Summary
Tim Duff 	DEF 	TD-1 	Proposed Residential and Non-
Residential Annual Potential RIM
Evaluation for 2025-2034 (at the
Generator)
Tim Duff 	DEF 	TD-2 	Proposed Residential and Non-
Residential Annual Potential TRC
Evaluation for 2025-2034 (at the
Generator)
Tim Duff 	DEF 	TD-3 	Proposed Residential and Non-
Residential Annual Potential
Recommended Evaluation for
2025-2034 (at the Generator)
Tim Duff 	DEF 	TD-4 	Avoided Cost Assumptions
Tim Duff 	DEF 	TD-5 	Projected Total Portfolio Costs &
Residential Rate Impacts
Tim Duff 	DEF 	TD-6 	RIM, TRC & Participant Tests
Benefits & Cost Analysis for all
Programs for all portfolios

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 56
Witness 	Proffered By 	Description
Tim Duff 	DEF 	TD-7 	Cost-Effectiveness Tests for all
DSM Programs in RIM Portfolio
Tim Duff 	DEF 	TD-8 	Cost-Effectiveness Tests for all
DSM Programs in TRC Portfolio
Mark R. Roche 	TECO 	MRR-1 	1. 	Tampa 	Electric’s 	proposed
DSM goals at the generator for
the 	2025-2034 	period 	and 	the
portfolio of DSM programs that
make up this goal.
2. Tampa Electric’s Rate Impact
Measure test (“RIM”) based DSM
goals at the generator for the 2025-
2034 period and the portfolio of
DSM programs that make up this
goal.
3. 	Tampa 	Electric’s 	Total
Resource Cost test (“TRC”) based
DSM goals at the generator for the
2025-2034 period and the portfolio
of DSM programs that make up
this goal.
4. Overall process used to develop
the 	company’s 	proposed 	DSM
goals for the 2025-2034 period.
5. 	Tampa 	Electric’s 	Technical
Potential Study of Demand Side
Management Report.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 57
Witness 	Proffered By 	Description
6. Comprehensive DSM Measure
List.
7. 	Process 	used 	to 	develop 	the
Technical Potential.
8. 	Tampa 	Electric’s 	DSM
Technical 	Potential 	for 	Energy
Efficiency, Demand Response, and
Distributed Energy Resources.
9. 	Process 	used 	to 	develop 	the
Economic Potential.
10. Tampa Electric’s avoided unit
cost 	data 	used 	for 	cost-
effectiveness evaluations.
11. Assumptions used for the
performance of cost- effectiveness.
12. Tampa Electric’s 2025-2034
DSM Economic Potential for the
RIM and TRC cost-effectiveness
tests.
13. Process used to develop the
Economic Potential sensitivity
analyses.
14. DSM Economic Potential
Sensitivities
15. Free-Ridership Consideration.
16. Proposed individual DSM
program detail that supports the
proposed DSM goals for the 2025-
2034 period.
17. Proposed RIM based
individual DSM program detail
that supports the RIM based DSM
goals for the 2025-2034 period.
18. Proposed TRC based
individual DSM program detail
that supports the TRC based DSM
goals for the 2025-2034 period.
19. Tampa Electric’s current DSM
programs and achievements.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 58
Witness 	Proffered By 	Description
20. Tampa Electric’s proposed
DSM Goals.
21. Tampa Electric’s proposed
DSM programs that achieve the
proposed goals.
Derrick M. Craig 	FPUC 	DMC-1 	CV
Derrick M. Craig 	FPUC 	DMC-2 	FPUC 2020 (Current) DSM
Programs and Standards
Derrick M. Craig 	FPUC 	DMC-3 	2019-2023 FPUC Electric
Conservation Goals and annual
program participation rates
Derrick M. Craig 	FPUC 	DMC-4 	FPUC Current DSM Goals 2015-
2024
Michael T. Clark 	FPUC 	MTC-1 	Michael Ty Clark Resume
Michael T. Clark 	FPUC 	MTC-2 	Christensen Associates Energy
Consulting Report on FPUC’s
Long Term Avoided Costs (4-2-
2024)
Brian Pippin 	JEA 	BP-1 	Brian Pippin Resume
Brian Pippin 	JEA 	BP-2 	JEA’s Existing FEECA Goals
Brian Pippin 	JEA 	BP-3 	Current JEA FEECA Programs
Brian Pippin 	JEA 	BP-4 	Historical Participation in Current
JEA FEECA Programs
Brian Pippin 	JEA 	BP-5 	Summary of JEA’s Marketing and
Educational Activities
Brian Pippin 	JEA 	BP-6 	JEA Residential Bill Impact
Analysis
Brian Pippin 	JEA 	BP-7 	JEA’s Proposed Demand-Side
Management Goals
Brian Pippin 	JEA 	BP-8 	JEA’s Existing v. Proposed
Demand-Side Management
Programs

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
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Witness 	Proffered By 	Description
Bradley Kushner 	JEA 	BEK-1 	Resumé of Bradley E. Kushner
Bradley Kushner 	JEA 	BEK-2 	Summary of Avoided Unit Costs
Bradley Kushner 	OUC 	BEK-1 	Resume' of Bradley E. Kushner
Bradley Kushner 	OUC 	BEK-2 	Summary of Avoided Unit
Costs
Bradley Kushner 	OUC 	BEK-3 	Carbon Regulation Compliance
Costs
Kevin M. Noonan 	OUC 	KMN-1 	Resumé of Kevin M. Noonan
Kevin M. Noonan 	OUC 	KMN-2 	OUC’s 2024 Annual
Conservation Report: Demand-
Side Management and
Conservation Programs Offered
in Calendar Year 2023
Kevin M. Noonan 	OUC 	KMN-3 	OUC’s Proposed Numeric
Demand and Energy Goals,
2025-2034
Kevin M. Noonan 	OUC 	KMN-4 	OUC’s Existing and Proposed
FEECA Programs
Kevin M. Noonan 	OUC 	KMN-5 	Estimated Bill Impact per 1,000
kWh Residential Service
Jeff Pollock 	FIPUG 	JP-1 	Trends in Generation Capital Costs
Jeff Pollock 	FIPUG 	JP-2 	Installed Cost of Generation
Capacity Additions Since 2012
Jeff Pollock 	FIPUG 	JP-3 	CS & IS Monthly Incentive
Reflecting Avoided Capital Costs
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-1 	2023 State Average Monthly Bill –
Residential

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 60
Witness 	Proffered By 	Description
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-2 	2022 State Average Monthly Bill –
Residential
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-3 	2021 State Average Monthly Bill –
Residential
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-4 	2020 State Average Monthly Bill –
Residential
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-5 	2019 State Average Monthly Bill –
Residential
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-6 	2018 State Average Monthly Bill –
Residential
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-7 	2017 State Average Monthly Bill –
Residential
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-8 	2016 State Average Monthly Bill –
Residential
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-9 	2015 State Average Monthly Bill –
Residential
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-10 	2014 State Average Monthly Bill –
Residential
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-11 	TECO's Answers to FLL's 1st RFA
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-12 	023 Utility Average Monthly Bill -
Residential

ORDER NO. PSC-2024-0293-PHO-EG
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Witness 	Proffered By 	Description
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-13 	2022 Utility Average Monthly Bill
- Residential
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-14 	SACE Energy Efficiency in the
Southeast 5th Report (2023)
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-15 	FPL DSM Annual Report (2023)
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-16 	DEF DSM Annual Report (2023)
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-17 	TECO DSM Annual Report (2023)
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-18 	JEA DSM Annual Report (2023)
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-19 	OUC DSM Annual Report (2023)
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-20 	FPL 10-Year Site Plan Excerpt
(2024)
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-21 	DEF 10-Year Site Plan Excerpt
(2024)
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-22 	TECO 10-Year Site Plan Excerpt
(2024)
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-23 	JEA 10-Year Site Plan Excerpt
(2024)

ORDER NO. PSC-2024-0293-PHO-EG
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Witness 	Proffered By 	Description
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-24 	OUC 10-Year Site Plan Excerpt
(2024)
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-25 	Utility Energy Efficiency
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-26 	FPL Low Income Program
Workpapers
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-27 	FPL DSM Report (2019)
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-28 	FPL DSM Report (2014)
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-29 	FPL Response to FEL’s 1st
Interrogatories
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-30 	FPL Expenditures on Load Control
Programs
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-31 	Duke Spending on Industrial and
Commercial Customers
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-32 	Duke Response to FLL's 1st
Interrogatories
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-33 	TECO Historical Performance
(2014)
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-34 	TECO Spending on Industrial and
Commercial Customers

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 63
Witness 	Proffered By 	Description
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-35 	OUC Proposed Program Planner
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-36 	Energy Burden Impacts: Florida in
Focus; Impacts of Energy Burden
for Jacksonville (Sierra Club,
March 2023)
MacKenzie Marcelin 	FL Rising/
ECOSWF/
LULAC
MM-37 	Duke Residential Program Level
Goals
Tony Georgis 	Nucor/PCS
Phosphate
TMG-1 	Resume and Record of
Testimony of Tony Georgis
Tony Georgis 	Nucor/PCS
Phosphate
TMG-2 	Select Duke Responses to
Interrogatories
Tony Georgis 	Nucor/PCS
Phosphate
TMG-3 	Select Duke Curtailable and
Interruptible Service Tariffs
Tony Georgis 	Nucor/PCS
Phosphate
TMG-4 	Duke Energy Florida, LLC’s 2024
Ten-Year Site Plan
Tony Georgis 	Nucor/PCS
Phosphate
TMG-5 	Progress Energy Florida, Inc.’s
2005 Ten-Year Site Plan
Steven W. Chriss 	Walmart 	SWC-1 	Witness Qualifications Statement
Steven W. Chriss 	Walmart 	SWC-2 	U.S. Energy Information
Administration, "Capital Cost and
Performance Characteristics for
Utility-Scale Electric Power
Generating Technologies," Table
1-2
Rebuttal
John F. Floyd 	FPL 	JNF-6 	Revised Low Income Program
Savings
John F. Floyd 	FPL 	JNF-7 	HVAC Incremental Measure Costs

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 64
Witness 	Proffered By 	Description
Andrew W. Whitley 	FPL 	AWW-18
(Corrected
by Whitley
Errata
filed on
July 12,
2024)
FEL Plan Analysis: Levelized
System Average Electric Rate
Andrew W. Whitley 	FPL 	AWW-19
(Corrected
by Whitley
Errata
filed on
July 12,
2024)
FEL Plan Analysis: Comparison of
Levelized System Average Electric
Rates
Andrew W. Whitley 	FPL 	AWW-20
(Corrected
by Whitley
Errata
filed on
July 12,
2024)
FEL Plan Analysis: Additional
Cost Needed to be Added to FPL’s
Proposed Plan to Increase its
Levelized System Average
Electric Rate to That of FEL Plan
Analysis
Andrew W. Whitley 	FPL 	AWW-21
(Corrected
by Whitley
Errata
filed on
July 12,
2024)
FEL Plan Analysis: Comparison of
the Resource Plans: Projection of
System Average Electric Rates and
Customer Bills (Assuming 1,000
kWh Usage)
Mark R. Roche 	TECO 	MRR-2 	Additional Cost Impacts of Mr.
Marcelin’s Recommendations
Brian Pippin 	JEA 	BP-9 	Summary of JEA’s Neighborhood
Energy Efficiency Program kW
and kWh Reductions
Kevin M. Noonan 	OUC 	KMN-6 	OUC Responses to Staff’s Data
Requests – 2024 Annual
Conservation Report

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 65
Parties and Staff reserve the right to identify additional exhibits for the purpose of cross-
examination.
X. 	PROPOSED STIPULATIONS
DEF – Docket No. 20240013-EG
DEF, FIPUG, Nucor, PCS Phosphate, Walmart, Florida Rising, and LULAC, by
Document No. 07555-2024 filed July 15, 2024, have agreed to the following Necessary
Stipulations on Issues 8(b) and 12 and, conditioned upon approval, have agreed to Type II
stipulations on Issues 1-7 and 13.
ISSUE 8B: 	If this proceeding, what demand credit rates are appropriate for purposes of
establishing the utilities’ goals?
The Stipulating Parties reserve the right to take positions on Issue 8(a). However, for purpose of
Stipulation, and in accordance with the provisions of the 2024 Settlement Agreement filed
contemporaneously in Docket No. 20240025-EI, the parties agree to stipulate the level of
demand credit rates. The Stipulation on Issue 8(b) to set the level of credits should not be
construed to indicate that parties have agreed that the DSM goals case is the proper forum to set
the level of credits, and acceptance of the Stipulations as to the level of credits should be
considered independently of the question of where the credits should be set. The following levels
of 	clause-recoverable 	credits 	for 	Interruptible 	(“IS”), 	Curtailable 	(“CS”), 	and 	Standby
Generation (“GSLM-2”) customers shall be in effect beginning with the first billing cycle of
2025:
Customer Type 	Credit Level
IS 	$8.00/kw-month
CS 	$8.00/kw-month
GSLM-2 	$8.11 x C + $0.10 x kwh monthly
No changes in these credits shall be implemented any earlier than the effective date of new DEF
base rates implemented pursuant to a general base rate proceeding, and that such new
IS/CS/GSLM-2 credits shall only be implemented prospectively from such effective date. At such
time as DEF’s base rates are reset in a general base rate proceeding, the IS/CS/GSLM-2 credits
shall be reset. In the next Demand Side Management goals and plan approval proceeding
(currently anticipated to occur in 2029), DEF shall not propose to change the level of the
credits.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 66
ISSUE 12: 	What residential and commercial/industrial summer and winter megawatt
(MW) and annual Gigawatt-hour (GWh) goals should be established for the
period 2025- 2034?
DEF’s energy efficiency goals will reflect their proposed goals, plus an increase in participation
for Neighborhood Energy Saver by 10% and an increase in the installation of smart thermostats
from 10% to 40%. This results in the following goals for the 10-year period:
FPUC – Docket 20240015-EG
The parties have agreed to Type II stipulations for all issues as follows:
ISSUE 1: 	Are the utility’s proposed goals based on an adequate assessment of the full
technical potential of all available demand-side and supply-side conservation
and efficiency measures, including demand-side renewable energy systems?
Yes. The utility’s proposed goals are based on an assessment of the full technical potential of all
available demand-side and supply-side conservation and efficiency measures as required by
Section 366.82(3), F.S.
ISSUE 2: 	Are the utility’s proposed goals based on savings reasonably achievable
through demand-side management programs over a ten year period?
Yes. The utility’s proposed goals are based on savings reasonably achievable through demand-
side management programs over the period 2025-2034 as required by Rule 25-17.0021(1)(b),
F.A.C.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 67
ISSUE 3: 	Do the utility’s proposed goals adequately reflect the costs and benefits to
customers participating?
Yes. The utility’s proposed goals reflect the costs and benefits to customers of the proposed
programs as required by Section 366.82(3)(a), F.S.
ISSUE 4: 	Do the utility’s proposed goals adequately reflect the costs and benefits to the
general body of rate payers as a whole, including utility incentives and
participant contributions?
Yes. The utility’s proposed goals reflect the costs and benefits of the proposed programs to the
general body of ratepayer as a whole as required by Section 366.82(3)(b), F.S.
ISSUE 5: 	Do the utility’s proposed goals adequately reflect the need for incentives to
promote 	both 	customer-owned 	and 	utility-owned 	energy 	efficiency 	and
demand-side renewable energy systems?
Yes. The proposed goals reflect the need for incentives as required by Section 366.82(3)(c), F.S.
ISSUE 6: 	Do the utility’s proposed goals adequately reflect the costs imposed by state
and federal regulations on the emissions of greenhouse gases?
Yes. There are no current costs imposed by state and federal regulations on the emission of
greenhouse gases to consider as required by Section 366.82(3)(d), F.S.
ISSUE 7: 	Do the utility’s proposed goals appropriately reflect consideration of free
riders?
Yes. The utility’s proposed goals reflect consideration of free riders in their program design as
required by Rule 25-17.0021(3), F.A.C.
ISSUE 8: 	Should demand credit rates for interruptible service, curtailable service,
stand-by generation, or similar potential demand response programs be
addressed in this proceeding or in the base rate proceedings for the rate
regulated FEECA Utilities? If this proceeding, what demand credit rates are
appropriate for purposes of establishing the utilities’ goals?
Demand credits are not included in FPUC’s proposed goals, and therefore this issue is moot.

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 68
ISSUE 12: 	What residential and commercial/industrial summer and winter megawatt
(MW) and annual Gigawatt-hour (GWh) goals should be established for the
period 2025-2034?
The Commission should adopt the goals based on the studies by witness Herndon, and the
annual 	summer 	demand, 	winter 	demand, 	and 	annual 	energy 	savings 	should 	reflect 	the
residential and commercial/industrial subtotals reflected on pages 3 and 4 of Exhibit JH-14.
ISSUE 13: 	What goals are appropriate for increasing the development of demand-side
renewable energy systems?
The utility should continue to implement the provisions of Rule 25-6.065, F.A.C., Interconnection
and Net Metering of Customer-Owned Renewable Generation. The rule is an appropriate means
to encourage the development of demand-side renewable energy
XI. 	PENDING MOTIONS
There are no pending motions at this time.
XII. 	PENDING CONFIDENTIALITY MATTERS
FPL
 	DN 03340-2024 filed May 20, 2024: Request for confidential classification of [DN
03341-2024] information provided in response to Staff's 1st request for PODs (No. 2).
 	DN 06837-2024 filed June 21, 2024: Request for confidential classification of [DN
06838-2024] 	information 	provided 	in 	response 	to 	FL 	Rising, 	ECOSWF, 	and
LULAC’s 1st request for PODs (Nos. 1 and 2).
DEF
 	DN 04629-2024 filed June 5, 2024: DEF’s Request for Confidential Classification
concerning its Response to FL Rising & LULAC’s First Set of Interrogatories (1-
52) and First Request for Production of Documents (1-2).
 	DN 	07936-2024 	filed 	July 	29, 	2024: 	DEF’s 	Request 	for 	Confidential
Classification concerning its Responses to Staff’s Fifth Set of Interrogatories
(Nos. 50-52).
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

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 69
statement may simply restate the prehearing position; however, if the prehearing position is
longer than 50 words, it must be reduced to no more than 50 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.
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 50
pages, inclusive of attachments, and shall be filed at the same time.
XIV. 	RULINGS
Opening statements, if any, shall not exceed five minutes per party.
It is therefore,
ORDERED by Commissioner Art Graham, 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 Art Graham, as Prehearing Officer, this 2nd day of August,
2024.
ART GRAHAM
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.
JHR/JDI

ORDER NO. PSC-2024-0293-PHO-EG
DOCKET NOS. 20240012-EG, 20240013-EG, 20240014-EG,
20240015-EG, 20240016-EG, 20240017-EG
PAGE 70
NOTICE OF FURTHER PROCEEDINGS OR JUDICIAL REVIEW
The Florida Public Service Commission is required by Section 120.569(1), Florida
Statutes, to notify parties of any administrative hearing or judicial review of Commission orders
that is available under Sections 120.57 or 120.68, Florida Statutes, as well as the procedures and
time limits that apply. 	This notice should not be construed to mean all requests for an
administrative hearing or judicial review will be granted or result in the relief sought.
Mediation may be available on a case-by-case basis. 	If mediation is conducted, it does
not affect a substantially interested person's right to a hearing.
Any 	party 	adversely 	affected 	by 	this 	order, 	which 	is 	preliminary, 	procedural 	or
intermediate in nature, may request: (1) reconsideration within 10 days pursuant to Rule 25-
22.0376, Florida Administrative Code; or (2) judicial review by the Florida Supreme Court, in
the case of an electric, gas or telephone utility, or the First District Court of Appeal, in the case
of a water or wastewater utility. 	A motion for reconsideration shall be filed with the Office of
Commission Clerk, in the form prescribed by Rule 25-22.0376, Florida Administrative Code.
Judicial review of a preliminary, procedural or intermediate ruling or order is available if review
of the final action will not provide an adequate remedy. Such review may be requested from the
appropriate court, as described above, pursuant to Rule 9.100, Florida Rules of Appellate
Procedure.