Florida Public Service Commission native order document 02440-2024

FILED 4/26/2024
DOCUMENT NO. 02440-2024
FPSC - COMMISSION CLERK
BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
In re: Petition for recovery of costs associated
with named tropical systems during the 2018-
2022 hurricane seasons and replenishment of
storm reserve, by Tam a Electric Com any.
DOCKET NO. 20230019-EI
ORDER NO. PSC-2024-0137-PHO-EI
ISSUED: April 26, 2024
PREHEARING ORDER
Pursuant to Notice and in accordance with Rule 28-106.209, Florida Administrative Co de
(F.A.C.), a Prehearing Co nference was held on April 24, 2024, in Tallahassee, Florida, before
Commissioner Art Graham, as Prehearing Officer.
APPEARANCES:
J. 	JEFFRY 	WAHLEN, 	MALCOLM 	MEANS, 	and 	VIRGINIA 	PONDER,
ESQUIRES, Ausley McMullen, Post Office Box 391, Tallahassee, Florida 32302
On behalf of Tampa Electric Co mpany (TECO).
WALT TRIERWEILER, Public Counsel, CHARLES REHWINKEL, and MARY
WESSLING, ESQUIRES, Office of Public Counsel, c/o The Florida Legislature,
111 W. Madison Street, Room 812, Tallahassee, Florida 32399
On behalf of the Office of Public Counsel (OPC).
STEPHANIE U. EATON, ESQUIRE, Spilman, Thomas & Battle, PLLC, 110
Oakwood Drive, Suite 500, Winston-Salem, North Carolina 27103
On behalf of Walmart, Inc. (Walmart).
DERRICK PRICE WILLIAMSON and STEVEN W. LEE, ESQUIRES, Spilman,
Thomas & Battle, PLLC, 1100 Bent Creek Blvd., Suite 101, Mechanicsburg,
Pennsylvania 17050
On behalf of Walmart, Inc. (Walmart).
MAJOR R . THOMPSON and RYAN P. SANDY, ESQUIRES, Florida Public
Service Com mission, 2540 Shumard Oak Boulevard, Tallahassee, Florida 32399
On behalf of the Florida Public Service Commission (StafO.
MARY ANNE HELTON, ESQUIRE, Deputy General Counsel, Florida Public
Service Commission, 2540 Shumard Oak Boulevard, Tallahassee, Florida 32399
Advisor to the Florida Public Service Commission.
KEITH C. 	HETRICK, 	ESQUIRE, 	General 	Counsel, 	Florida Public 	Service
Commission, 2540 Shumard Oak Boulevard, Tallahassee, Florida 32399
Florida Public Service Commission General Counsel

ORDER NO. PSC-2024-0137-PHO-EI
DOCKET NO. 20230019-EI
PAGE 2
I. 	CASE BACKGROUND
On January 23, 2023, pursuant to Rules 28-106.201 and 25-6.0143, F.A.C., Tampa
Electric Company (TECO or Utility) filed its Petition for Recovery of Costs Associated with
Named Tropical Systems During the 2018-2022 Hurricane Seasons and Replenishment of Storm
Reserve with actual incremental storm costs for the 2018 through 2021 storm seasons and
estimated incremental storm costs for the 2022 storm season. The Commission approved
TECO’s interim storm restoration charge on March 27, 2023, subject to final true-up.1
On August 16, 2023, TECO filed a Supplemental Petition to update the total storm
restoration costs to include updated accrued costs and to propose a modified recovery period. On
September 29, 2023, TECO filed a Petition for Approval of Actual Storm Restoration Costs
Associated with Named Tropical Systems During the 2018-2022 Hurricane Seasons and
Associated True-Up Mechanism on September 29, 2023, updating the estimated costs for the
2022 to actual costs and providing the required documentation of actual recoverable storm costs
and to propose a final true-up mechanism for the Interim Storm Restoration Charge.
On October 17, 2023, Order No. 2023-0309-PCO-EI was issued, establishing controlling
dates for this proceeding and scheduling an administrative hearing for these matters on May 1–2,
2024.
II. 	CONDUCT OF PROCEEDINGS
Pursuant to Rule 28-106.211, F.A.C., this Prehearing Order is issued to prevent delay and
to promote the just, speedy, and inexpensive determination of all aspects of this case.
III. 	JURISDICTION
This Commission is vested with jurisdiction over the subject matter by the provisions of
Chapter 120 and 366, Florida Statutes (F.S.). This hearing will be governed by said Chapter and
Chapters 25-6, 25-22, and 28-106, F.A.C., as well as any other applicable provisions of law.
IV. 	PROCEDURE FOR HANDLING CONFIDENTIAL INFORMATION
Information for which proprietary confidential business information status is requested
pursuant to Section 366.093, F.S., and Rule 25-22.006, F.A.C., shall be treated by the
Commission as confidential. 	The information shall be exempt from Section 119.07(1), F.S.,
pending a formal ruling on such request by the Commission or pending return of the information
to the person providing the information. 	If no determination of confidentiality has been made
and the information has not been made a part of the evidentiary record in this proceeding, it shall
1 Order No. PSC-2023-0116-PCO-EI, issued March 27, 2023, in this docket.

ORDER NO. PSC-2024-0137-PHO-EI
DOCKET NO. 20230019-EI
PAGE 3
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.
(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.

ORDER NO. PSC-2024-0137-PHO-EI
DOCKET NO. 20230019-EI
PAGE 4
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.
VI. 	ORDER OF WITNESSES
Each witness whose name is preceded by an asterisk (*) has been stipulated and excused.
The testimony and exhibits of stipulated witnesses shall be introduced into the record in the order
presented below.
Witness 	Proffered By 	Issues #
Direct
*Chip S. Whitworth 	TECO 	2-6, 9-10, B
*Richard J. Latta 	TECO 	1-14, B
*Ron Mavrides 	Staff 	1-12
*Carl Vinson 	Staff 	2
VII. 	BASIC POSITIONS
TECO: 	As noted in in Order Nos. PSC-2023-0116-PCO-EI, issued March 27, 2023 and
PSC-2023-0351-PCO-EI, issued November 20, 2023, this docket is open for the
final reconciliation of actual recoverable storm costs with the amount collected
pursuant to the interim storm restoration recovery charge and the calculation of a
refund or additional charge if warranted. The purpose of the May 1, 2024 hearing
is to determine actual recoverable storm costs.

ORDER NO. PSC-2024-0137-PHO-EI
DOCKET NO. 20230019-EI
PAGE 5
The Commission should find that Tampa Electric complied with Rule 25-6.0143,
Florida Administrative Code, and its 2019 Stipulation and Settlement Agreement,
and approve Tampa Electric’s actual recoverable storm restoration costs in the
amount 	of 	$134,832,847.83. 	The 	Commission 	should 	also 	approve 	Tampa
Electric’s proposed true-up mechanism for the Interim Storm Restoration Charge.
OPC: 	The burden of proof in a Commission proceeding is always on a utility seeking a
rate change and upon other parties seeking to change established rates. Fla. Power
Corp. v. Cresse, 413 So. 2d 1187, 1191 (Fla. 1982). Tampa Electric Company has
the burden to prove whether the Commission should approve Tampa Electric’s
Petition for Approval of Actual Storm Restoration Costs Associated with Named
Tropical Systems During the 2018-2022 Hurricane Seasons and Associated True-
Up Mechanism.
As a result of the stipulation entered into among the parties to Docket No.
20170271-EI 	and 	approved 	in 	Order 	No. 	PSC-2019-0234-AS- 	EI 	(2019
Settlement), Tampa Electric agreed to follow certain processes for incurring storm
restoration costs. Tampa Electric also agreed to engage an independent accountant
to perform an audit of its compliance with the agreed processes.
The OPC has reviewed Tampa Electric’s audit plan, audit report and audit
workpapers, and the OPC further conducted discovery involving a review of a
representative sample of invoices and cost documentation. After conducting this
review and cooperatively meeting with Tampa Electric and their outside auditors,
the OPC determined that the company has materially complied with the 2019
Settlement and that the audit was well designed and executed. Tampa Electric has
also demonstrated that it maintains a practice of working to continuously improve
its stewardship of the resources it acquires for restoring service after severe
weather events.
Based on the entirety of the circumstances, Tampa Electric’s petition meets the
burden of proof established by the 2019 Settlement and other applicable laws. As
a result of the due diligence performed by the OPC and the cooperation by Tampa
Electric in this matter, OPC is in support of Tampa Electric’s commitment to an
ongoing, continuous storm restoration process improvement plan so that current
and future customers only pay for prudent, cost-effective storm restoration costs
incurred due to extreme weather events.
WALMART: Walmart takes no position regarding the amount of restoration costs or accounting
treatment of the same in this Docket. 	Walmart did raise an issue in its filed
Comments prior to TECO's recovery of storm costs at issue in this Docket, which
is set forth as a Contested Issue below. 	Namely, Walmart contends that TECO
should be required to recover storm costs from demand-metered customers on a
demand, or $/kW, charge, not through an energy, or $/kWh charge.

ORDER NO. PSC-2024-0137-PHO-EI
DOCKET NO. 20230019-EI
PAGE 6
As set forth in Walmart's March 7, 2023, Comments, Walmart's issue in this
Docket is an issue that Walmart raised before this Commission in relation to the
Storm Protection Plan ("SPP") and Storm Protection Plan Cost Recovery Clause
("SPPCRC") Dockets as early as 2020. 2 	Walmart's general concern is that
recovering demand-related costs through an energy charge could result in a shift
in demand cost responsibility from lower load factor customers to higher load
factor customers. 3 	Although both Duke Energy Florida, LLC, ("DEF") and
Florida Public Utility Company ("FPUC") sought recovery of SPP costs from
demand-metered customers through an energy charge, each Utility ultimately
entered into a Stipulation whereby each agreed to charge demand-metered
customers a demand charge related to SPP costs.4 	While Walmart readily
acknowledges that retroactive billing revisions would likely be administratively
prohibitive, as expressed by TECO in the Rebuttal Testimony of Jordan M.
Williams 5 , Walmart notes that TECO's collection of costs in this Docket are not
yet complete, and Walmart did, in fact, raise the issue in this Docket before
TECO's storm costs began being recovered from its customers from April 2023,
through December 2024.6 	Moreover, while Mr. Williams points out that this
Commission "has a long-standing history of approving the recovery of a utility's
storm restoration costs via the energy charge" for the last seventeen years,7 	it
does not mean that the Commission, Staff, Utilities, and ratepayers cannot
reevaluate the way the storm costs are recovered. 	In light of the fact that SPP
costs are recovered from demand-metered customers for TECO, DEF, FPUC and
Florida Power & Light ("FPL") through a demand-charge, and the fact that both
DEF and FPUC revised their respective cost recovery from demand-metered
customers in SPPCRC Dockets, Walmart urges consideration of this issue in this
Docket.
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.
2 See Comments at page 2.
3 See id., and Direct Testimony of Lisa V. Perry in the 2021 SPPCRC Docket, No. 2021—10-EI, p. 14, lines 6 – 21.
4 See Comments at page 2, at Footnote 1, and page 3.
5 Williams Test., March 28, 2024, at page 3, lines 20-25.
6 See Order No. PSC-2023-0351-PCO-EI, Nov. 20, 2023, ("Nov. 2023 Order") at pages 2-3, noting that the
originally approved recovery period was April 2023 through the last billing cycle of March 2024, and that TECO's
supplemental petition requested an amended storm surcharge and extended cost recovery through December 2024.
The Nov. 2023 Order states that the "disposition of any over or under recovery, and associated interest, will be
considered by us at a later date" and that "this docket shall remain open pending final reconciliation of actual
recoverable storm costs with the amount collected pursuant to the interim storm restoration recovery charge and the
calculation of a refund or additional charge if warranted."
7 Williams Test., at page 4, lines 1-14.

ORDER NO. PSC-2024-0137-PHO-EI
DOCKET NO. 20230019-EI
PAGE 7
VIII. 	ISSUES AND POSITIONS
ISSUE 1: 	Proposed Type 1 Stipulation; see Section X.
ISSUE 2: 	Proposed Type 1 Stipulation; see Section X.
ISSUE 3: 	Proposed Type 1 Stipulation; see Section X.
ISSUE 4: 	Proposed Type 1 Stipulation; see Section X.
ISSUE 5: 	Proposed Type 1 Stipulation; see Section X.
ISSUE 6: 	Proposed Type 1 Stipulation; see Section X.
ISSUE 7: 	Proposed Type 1 Stipulation; see Section X.
ISSUE 8: 	Proposed Type 1 Stipulation; see Section X.
ISSUE 9: 	Proposed Type 1 Stipulation; see Section X.
ISSUE 10: 	Proposed Type 1 Stipulation; see Section X.
ISSUE 11: 	Proposed Type 1 Stipulation; see Section X.
ISSUE 12: 	Proposed Type 1 Stipulation; see Section X.
ISSUE 13: 	Proposed Type 2 Stipulation; see Section X.
ISSUE 14: 	Proposed Type 1 Stipulation; see Section X.
ISSUE B: 	Proposed Type 2 Stipulation; see Section X.
IX. 	EXHIBIT LIST
Each exhibit that is preceded by an asterisk (*) has been stipulated. All stipulated exhibits
shall be introduced into the record in the order presented below.
Witness 	Proffered By 	Exhibit 	Description
Direct
*Chip S. Whitworth 	TECO 	CSW-1 	Storm Restoration Costs by
Storm

ORDER NO. PSC-2024-0137-PHO-EI
DOCKET NO. 20230019-EI
PAGE 8
Witness 	Proffered By 	Exhibit 	Description
*Richard J. Latta 	TECO 	RJL-1 	(1) Total Restoration Costs by
Storm and Cost Category
(2) Incremental Recoverable
Restoration Costs by Storm
(3) PwC Audit Report
*Ron Mavrides 	Staff 	RM-1 	Auditor’s Report
Parties and Staff reserve the right to identify additional exhibits for the purpose of cross-
examination.
X. 	PROPOSED STIPULATIONS
There are proposed Type 1 and Type 2 stipulations on all issues. A Type 1 stipulation
occurs on an issue where the utility and intervenors agree on the resolution of the issue. A Type
2 stipulation8 occurs on an issue when the utility and staff, or the utility and at least one party
adversarial to the utility, agree on the resolution of the issue and the remaining parties (including
staff if they do not join in the agreement) do not object to the Commission relying on the agreed
language to resolve that issue in a final order. The proposed stipulations are as follows:
ISSUE 1: 	Should the incremental cost and capitalization approach (ICCA) found in Rule
25-6.0143, F.A.C., be used to determine the reasonable and prudent amounts to be
included in the restoration costs?
Type 1: 	Yes. The Commission should find that the company complied with the rule.
ISSUE 2: 	Have the terms of TECO’s 2019 Stipulation and Settlement, approved by Order
No. PSC-2019-0234-AS-EI, issued June 14, 2019, been complied with? 	If not,
why not?
Type 1: 	Yes. The Commission should find that the company complied with the 2019
Stipulation and Settlement.
8 The Office of Public Counsel’s (OPC’s) position on each Type 2 stipulation is as follows:
OPC takes no position on these issues, nor does it have the burden of proof related to them. As
such, the OPC represents that it will not contest or oppose the Commission taking action
approving a proposed stipulation between the utility and another party or staff as a final resolution
of the issue. No person is authorized to state that the OPC is a participant in, or party to, a
stipulation on these issues, either in this docket, in an order of the Commission or in a
representation to a Court

ORDER NO. PSC-2024-0137-PHO-EI
DOCKET NO. 20230019-EI
PAGE 9
ISSUE 3: 	What is the reasonable and prudent amount of regular payroll expense to be
included in the restoration costs?
Type 1: 	The Commission should approve $3,281,788.00 as the reasonable and prudent
amount of regular payroll expense to be included in the restoration costs.
ISSUE 4: 	What is the reasonable and prudent amount of overtime payroll expense to be
included in the restoration costs?
Type 1: 	The Commission should approve $6,832,831.08 as the reasonable and prudent
amount of overtime payroll expense to be included in the restoration costs.
ISSUE 5: 	What is the reasonable and prudent amount of contractor costs to be included in
the restoration costs?
Type 1: 	The Commission should approve $90,569,291.92 as the reasonable and prudent
amount of contractor costs to be included in the restoration costs. This amount is
slightly lower than the previously reported amount of $90,852,788.61 because a
few final invoices came in slightly lower than the accrued expense amounts.
ISSUE 6: 	What is the reasonable and prudent amount of vegetation and line clearing costs
to be included in the restoration costs?
Type 1: 	The Commission should approve $10,884,426.12 as the reasonable and prudent
amount of vegetation and line clearing costs to be included in the restoration
costs.
ISSUE 7: 	What is the reasonable and prudent amount of employee expenses to be included
in the restoration costs?
Type 1: 	Zero. Tampa Electric did not request recovery of Tampa Electric employee
expenses.
ISSUE 8: 	What is the reasonable and prudent amount of materials and supplies expense to
be included in the restoration costs?
Type 1: 	Zero. Tampa Electric did not request recovery of materials and supplies expenses.
ISSUE 9: 	What is the reasonable and prudent amount of logistics costs to be included in the
restoration costs?
Type 1: 	The Commission should approve $18,893,127.42 as the reasonable and prudent
amount of logistics costs to be included in the restoration costs. There are
additional costs related to interest income, examination costs, and ARCOS (GPS

ORDER NO. PSC-2024-0137-PHO-EI
DOCKET NO. 20230019-EI
PAGE 10
tracking technology) implementation costs totaling $3,592,865.25; $381,000; and
$397,518.04 respectively.
ISSUE 10: 	What is the reasonable and prudent total amount of costs to be included in the
restoration costs?
Type 1: 	The Commission should approve $134,832,847.83 as the reasonable and prudent
total amount of costs to be included in the restoration costs. This is $266,249.88
lower than the total presented in witness Latta’s testimony of $135,099,097.71.
This change is because of final invoice payments and adjustments to accrued
interest income based on the current month’s Commercial Paper interest rate. As
of March 31, 2024, all invoices relevant to this docket have been processed.
ISSUE 11: 	What is the reasonable and prudent amount of storm-related costs that should be
capitalized?
Type 1: 	The Commission should approve $4,799.217.43 as the reasonable an prudent
amount of storm-related costs that should be capitalized.
ISSUE 12: 	What is the appropriate accounting treatment associated with any storm costs
found to have been imprudently incurred?
Type 1: 	The accounting treatment for any storm costs found to be imprudently incurred,
and initially posted to the storm reserve, is to remove the charge from the reserve
and post the charge to the company’s applicable O&M account, or capital as
identified; however, the current total restoration cost presented in this docket does
not contain any imprudently incurred costs.
ISSUE 13: 	If applicable, how should any under-recovery or over-recovery be handled?
Type 2: 	Any under or over-recovery will be recovered/refunded through an adjustment to
the energy conservation cost recovery clause.
ISSUE B: 	What additional storm restoration process improvements should Tampa Electric
follow in future storms?
Type 2: 	In addition to the process improvements in Tampa Electric’s 2019 Storm Cost
Settlement Agreement, Tampa Electric also agrees to follow the additional
process improvements described in Attachment A to this Prehearing Order.
ISSUE 14: 	Should this docket be closed?
Type 1: 	No. This docket should remain open so the company can file supplemental
testimony 	comparing 	the 	final 	recoverable 	storm 	costs 	approved 	by 	the
Commission with the actual revenues from the Interim Storm Restoration Charge

ORDER NO. PSC-2024-0137-PHO-EI
DOCKET NO. 20230019-EI
PAGE 11
and calculating the resulting excess or shortfall, so that the true-up amount can be
recovered from or credited to the energy conservation cost recovery clause or
disposed of in some other manner as approved by the Commission.
XI. 	PENDING MOTIONS
There are no pending motions at this time.
XII. 	PENDING CONFIDENTIALITY MATTERS
There are no pending confidentiality matters at this time.
XIII. 	POST-HEARING PROCEDURES
If no bench decision is made, each party shall file a post-hearing statement of issues and
positions. A summary of each position, set off with asterisks, shall be included in that statement.
If a party's position has not changed since the issuance of this Prehearing Order, the post-hearing
statement may simply restate the prehearing position; however, if the prehearing position is
longer than 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 40
pages and shall be filed at the same time.
XIV. 	RULINGS
1. 	Striking Walmart’s Contested Issue A
In its Prehearing Statement, Walmart proposed an Issue A: “Should any cost recovery
approved in this docket be recovered from demand-metered customers through the demand
charge?” Having heard the parties’ arguments, I find that Issue A shall be stricken. TECO’s 2021
Settlement Agreement9 provides that the storm damage recovery that is at issue in this
proceeding shall be made with the rate design and cost allocation methods approved in the
agreement. As the issue is resolved by the 2021 Settlement Agreement, Walmart’s issue is not
appropriate in this proceeding.
9 Order No. PSC-2021-0423-S-EI, issued November 10, 2021, in Docket Nos. 20210034-EI, In re: Petition for rate
increase by Tampa Electric Company and 20200264-EI, In re: Petition for approval of 2020 depreciation and
dismantlement study and capital recovery schedules, by Tampa Electric Company (p. 35-36).

ORDER NO. PSC-2024-0137-PHO-EI
DOCKET NO. 20230019-EI
PAGE 12
2. 	Striking Intervenor and Rebuttal Testimony and Exhibits
On February 16, 2024, Walmart prefiled testimony of its witness Lisa V. Perry, together
with supporting exhibits LVP-1 and LVP-2, in support of its position on Contested Issue A. On
March 28, 2024, TECO prefiled testimony of its witness Jordan M. Williams, in rebuttal to
Walmart’s witness. In light of my ruling on Issue A, I find it appropriate to strike the intervenor
and rebuttal testimonies and exhibits.
3. 	Opening Statements
Opening statements, if any, shall not exceed three 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 26th day of April,
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.
MRT

ORDER NO. PSC-2024-0137-PHO-EI
DOCKET NO. 20230019-EI
PAGE 13
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.

ORDER NO. PSC-2024-0137-PHO-EI 	Attachment A
DOCKET NO. 20230019-EI
PAGE 14
Attachment A
Tampa Electric Company’s Prehearing Statement
Ongoing, Continuous Storm Restoration Process Improvements
Tampa Electric Company’s (“Tampa Electric” or the “company”) 2019 Storm Cost
Settlement Agreement includes several “Future Process Improvements” covering a broad range
of storm cost recovery issues, including: (1) contracting and vendor engagement; (2) travel and
work policies; (3) cost documentation; (4) auditing and regulatory recovery processes; and (5) a
methodology for determining incremental costs. See Order No. PSC-2019-0234-AS-EI, issued
June 14, 2019 in Docket No. 20170271-EI.
Since that time, Tampa Electric has continued to document lessons learned from storm
restoration 	efforts 	and 	has 	as 	a 	part 	of 	the 	ongoing, 	continuous 	improvement 	process
implemented several additional process improvements.
Tampa 	Electric 	commits 	that 	it 	will 	continue 	to 	apply 	the 	2019 	storm 	process
improvements, as well as the additional new process improvements listed below, whenever such
implementation does not interfere with safe, timely, and cost-effective restoration of service
following a storm, and that they will remain in effect until modified by an order of the Florida
Public Service Commission. The company will meet with OPC to evaluate the company’s storm
restoration processes in the first quarter of 2025 and every two years thereafter.
1. 	Lodging Procurement and Tracking. Tampa Electric retained a third-party booking
agency that provides a disaster lodging service for emergency lodging needs. This
agency provides and books accommodations according to requesters’ specific needs,
utilizing their extensive and detailed database of lodging vendors and pre-negotiated
contracts. They can identify vendors’ specific capabilities such as emergency power,
parking, food, and laundry services. Additionally, their booking software platform can
track detailed information about acquired lodging and utilization rates to help identify
unused accommodation to inform decision making. After the emergency, they provide
comprehensive invoice tracking and payment support to quickly resolve payment to
vendors.
2. 	Storm Surge Damage Mitigation. Tampa 	Electric developed a new process to
anticipate and mitigate storm surge damage by working with Tampa Electric’s weather
partners, 	including 	the 	National 	Weather 	Service 	(“NWS”) 	and 	a 	Florida-based
meteorologist. Tampa Electric is the first utility in Florida to be recognized as a “Storm
Ready” partner, allowing access to NWS weather data and forecasts. Additionally,
Tampa 	Electric 	contracted 	with 	a 	Florida 	based 	meteorologist 	to 	enhance 	our
understanding and interpretation of weather data as it relates to our local geographic
conditions. Being able to anticipate the damage more accurately to underground
electrical equipment will allow Tampa Electric to better estimate the correct number of
external resources required to help restore this equipment.

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3. 	Base Camp Staging Model. Tampa Electric maintains contracts with several vendors
that supply turn-key emergency accommodations including lodging, meals, sanitation
and transportation management. These base camps can be rapidly deployed (usually
within 24 hours) to staging sites post-storm and mitigate the company’s storm recovery
personnel needs.
4. 	Eliminating Delays. Tampa Electric began pre-staging crews in nearby locations,
allowing the company to utilize responding crews in the working hours immediately
following the passage of storm conditions, even before local staging sites are completely
set up.
5. 	Distribution Control Center (DCC) Process Changes. In storm response scenarios,
Tampa Electric transitions control from the central DCC to the company’s various
service areas. One lesson learned was to reduce the transition time from DCC control to
service area control, which results in less down time for field personnel and faster
restoration of service.
6. 	“Cut and Clear” Improvements. The company improved the locked-out circuit
isolation process (“cut-and-clear”) by creating a mobile app to transmit faster updates
from the field and for easier tracking of work. Re-energizing distribution circuits that
have been locked out as quickly as possible after a storm provides one of the greatest
values in restoring service to customers. Getting clear and faster updates through a
mobile app ensures that this process is carried out without delays.
7. 	Improved Outage Detection. The company improved the detection of outages by
having streetlights turned on as soon as restoration begins.
8. 	Improved DCC and Service Area Communications. Tampa Electric implemented
multiple process changes to eliminate confusion and miscommunication between the
DCC and Service Area Restoration teams. The DCC and the service area restoration
teams are the two most critical areas during storm restoration. Clear and up-to-date
communications are vital for a successful restoration effort.
9. 	Circuit Reconfiguration Logs. Performing overnight work reduces the overall time to
restore service to all customers, but poor communication of work performed overnight
to the daytime crews can result in delays. Consequently, the company implemented the
use of “abnormal switching logs” in the Advanced Distribution Management System
(“ADMS”) to communicate circuit reconfigurations performed overnight by the DCC to
the service area restoration teams. This helps ensure clear communication of the
overnight work to the day crews and eliminates potential delays.
10. New Safety Measures. Tampa Electric added steps to reduce the safety risk to field
personnel while performing circuit isolation work, such as opening the terminal pole
switch and adding “men at work” pole wrap. These steps were added as extra safety
measures in addition to steps that were already in place. Given the large amount of field
personnel working during storm restoration, adding several layers of protection shows

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PAGE 16
Tampa Electric’s commitment to the company’s highest objective: “Safety of life shall
outweigh all other considerations.”
11. Additional Distribution System Operators. The company added more Distribution
System Operators and assigned two per affected service area. This eliminated the need
to train personnel who were not familiar with ADMS/CAD on how to update ADMS
when field restoration is complete. The result is a quicker update of customer outage
counts and more accurate estimated times of restoration (“ETR”) reflected in the
customer-facing 	outage 	map. 	The 	company 	believes 	communications 	with 	our
customers are just as important as internal communications, and these changes ensure
that we communicate outages and ETRs to our customers during the times when they
need such information the most.
12. Retaining Some Foreign Crews in Partial Incident Command Structure (“ICS”).
Tampa Electric determined that retaining a small contingent of foreign crews following
the transition to partial ICS can help quickly restore the remaining small pockets of
outages (secondary, service, etc.). It takes longer to find and fix these smaller outages,
and having more crews reduces the time it takes to conduct this effort.
13. Additional Documentation for Foreign Line Crews. Tampa Electric added specific
terms and conditions to the rate schedule template that is provided to and completed by
the foreign companies. In addition, a “Storm Restoration Documentation and Other
Requirements” document and an initial email that outlines requirements are provided to
each foreign company when they are secured. These measures ensure invoiced costs are
fair and meet the requirements of the Storm Cost Settlement Agreement.
14. Foreign Line Crew Rate Schedules. Tampa Electric now collects storm rate schedules
prior to storm season that identify agreed-upon rates with the foreign contractor. The
company has compiled 59 such schedules to date. These schedules are ranked by cost
from lowest cost to highest, and if Tampa Electric directly secures foreign contractors,
the list is contacted in that order. If a foreign contractor is assigned to Tampa Electric by
the SEE, the list is used to determine which companies may be released from restoration
first.
15. Foreign Company “Tracker” Files. During and after restoration, the Resource
Management team updates a “Tracker” file that documents contacts, headcounts, dates,
and other pertinent information by foreign company so that Tampa Electric can ensure
that all required information needed for proper billing has been collected.
16. Foreign Line Crew Composition Review. Before foreign companies are approved to
deploy, Tampa Electric now examines rosters provided by the foreign companies
immediately after they are secured to ensure that the distribution crew make-ups are no
more than four team members per crew (to ensure fair invoicing), and that the crews
have at least two line workers and a hot apprentice (minimum standard to safely perform
work).

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PAGE 17
In addition to these process improvements that are already in place, Tampa Electric also
identified two additional improvements that the company commits to implement in future
storms:
1. 	Standardized Rate Schedules. Tampa Electric currently implements a standardized rate
schedule for contracts with line restoration crews. The company also commits to
negotiate for and implement standardized rate schedules for contracts with vegetation
management crews in future storms.
2. 	Formalized Exception Reports. To better implement Section II.A of the Future Process
Improvements in the 2019 Storm Cost Settlement Agreement, Tampa Electric will
formally 	document 	all 	exceptions 	to 	standardized 	requirements 	that 	have 	been
communicated to foreign companies.
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