20250016

Key events and submissions in this Florida Public Service Commission proceeding for the review of the 2026-2035 Storm Protection Plans (SPPs) include:

- Filing Deadline Change: The initial filing start date was unexpectedly moved from the second week of April to the second week of January 2025, with companies notified in advance and the Office of Public Counsel (OPC) notified on or about January 8, 2025 1.
- Plan Submissions: Each utility (including Tampa Electric, FPL, Duke Energy Florida, and FPUC) submitted its SPP filing for the 2026-2035 period by the January 2025 deadline 1.
- Hearing Scheduling: The Commission scheduled an administrative hearing for the consolidated dockets (all four major utilities) from May 20, 2025 through May 22, 2025 1.
- Commission Decision Deadline: By statute, the Commission must issue its decision within 180 days of each company’s filing. For this review cycle, the decision was required by July 14, 2025 1, 1.
- Discovery and Testimony: The proceeding allowed for two written rounds of discovery and a brief deposition window on company direct testimony, and a single written round plus deposition window on rebuttal testimony, due to the tight schedule 1, 1.
- Prehearing Order: A prehearing order governing the conduct of proceedings was issued on May 12, 2025 1.
- Post-Hearing Filings: Parties were required to submit post-hearing statements of issues and positions no later than June 6, 2025, if no bench decision was made at hearing 1.

All major filings and actions were governed by statutory and regulatory timelines, with strict enforcement of initial filing requirements and limited opportunities for supplemental or late-filed information 1, 1.

The primary areas of growth identified in the Tampa Electric Company's 2026-2035 Storm Protection Plan (SPP) docket are:

- Distribution Storm Surge Hardening Program
- Transmission Switch Hardening Program
- Lateral Undergrounding Program

Key considerations for each area:

1. Distribution Storm Surge Hardening Program
- Aimed at hardening distribution switchgear and transformers in critical flood zones, making them resistant to storm surge and freshwater flooding.
- Expected to reduce restoration costs and outage times associated with extreme weather and enhance reliability.
- The program was debated: Tampa Electric argued it meets statutory goals and rule requirements, while the Office of Public Counsel (OPC) recommended exclusion for non-compliance with filing requirements 1, 2.

2. Transmission Switch Hardening Program
- Focuses on hardening transmission switches to improve resilience against extreme weather.
- The plan states that approval for initial implementation (2026–2028) is not evidence of imprudence, but future retention in the SPP will be subject to further review.
- Like the distribution program, OPC recommended exclusion for non-compliance, whereas Tampa Electric and the stipulated resolution support inclusion 1, 2.

3. Lateral Undergrounding Program
- Involves converting overhead lateral distribution lines to underground to reduce storm-related outages and restoration times.
- The target for undergrounding was reduced from 75–100 miles per year in the previous SPP to 65–85 miles, and then further stipulated to 75 miles per year for the 2026–2035 SPP. This is an annual target, not a hard cap.
- The reduction was a result of negotiation and is intended to balance reliability improvements with cost considerations 2.

For each area, key considerations include:
- Compliance with statutory requirements (e.g., section 366.96, Florida Statutes) and administrative rules (rule 25-6.030, F.A.C.).
- The programs’ projected impact on restoration costs, outage durations, and overall system reliability.
- The balance between cost, feasibility, and benefit to customers.
- Stakeholder (utility and OPC) agreement or objections regarding plan elements and implementation pace 2, 1.

The financial and timeline risks and concerns discussed in this docket include:

Financial Risks and Concerns:
- The Office of Public Counsel (OPC) recommends slowing down the pace of the Storm Protection Plan (SPP) to reduce the jurisdictional revenue requirements by 3.9%, providing some level of rate relief for customers 1, 1.
- Concerns are mentioned regarding non-compliance with filing requirements for certain programs, which could result in their exclusion from the SPP and impact cost recovery 1.
- The SPP presents a range of estimated net benefits ($130 million to $450 million in reduced restoration costs over 50 years), but these savings depend on the frequency and severity of future storms, introducing significant uncertainty to the financial projections 2, 1.
- The plan’s cost and rate impacts are deemed reasonable by Tampa Electric, but OPC raises concerns about overall cost and potential redundancy of some programs, which could increase customer rates unnecessarily 1.

Timeline Risks and Concerns:
- The pace of program deployment is influenced by contractor availability, system capacity, safety, efficiency, and the need to obtain competitive pricing. Delays in these areas could increase costs and postpone benefits to customers 3.
- The company’s selected three-year timeline for switchgear and transformer upgrades is based on executing the work with dedicated crews at a rate of about four switchgears per week. A longer timeline was not considered because it would delay the anticipated benefits and potentially increase both costs and risks 3.
- OPC recommends considering a reduction in the pace of deployment as a risk mitigation strategy, aligning with statutory authority to modify the plan if needed 1, 1.

In summary, financial risks revolve around cost recovery, rate impacts, and benefit uncertainties, while timeline risks include potential delays due to resource limitations and the possible need to slow deployment to ensure customer affordability and compliance.

The main stakeholders in this docket (review of Tampa Electric Company's 2026-2035 Storm Protection Plan, docket no. 20250016-EI) are:

- Tampa Electric Company (TECO)
- Office of Public Counsel (OPC)
- Florida Public Service Commission (FPSC) staff
- Attorneys representing Tampa Electric and the Office of Public Counsel
- Other parties such as PCS Phosphate (mentioned in relation to other dockets in the same set of proceedings)

Stakeholder Positions:

1. Tampa Electric Company (TECO)
- Supports approval of its 2026-2035 Storm Protection Plan (SPP), including the Distribution Storm Surge Hardening program and Transmission Switch Hardening program.
- Agreed to modifications such as setting the annual underground conversion target at 75 miles per year (not a hard cap) in response to negotiations with OPC 1.

2. Office of Public Counsel (OPC)
- Initially opposed the inclusion of the Distribution Storm Surge Hardening program and Transmission Switch Hardening program in the SPP for non-compliance with filing requirements 2.
- Reached a settlement with TECO, agreeing to the joint stipulations and resolutions, including the modified annual undergrounding target. The parties agreed that these positions are not precedential and may be revisited in future proceedings 1, 1.

3. Florida Public Service Commission (FPSC) Staff
- Staff did not take a specific position on the inclusion or exclusion of the storm surge hardening programs at the time referenced in the excerpts 2.

4. Attorneys
- Attorneys for both TECO and OPC are actively involved, representing their respective clients and submitting joint stipulations to the FPSC for approval 1, 1, 1.

Summary of Support/Opposition:
- TECO: For approval of its plan as modified in negotiations.
- OPC: Initially against specific SPP programs but ultimately agreed to a modified plan through joint stipulations.
- FPSC Staff: No stated position at the time cited.
- Other stakeholders like PCS Phosphate are referenced in the context of other dockets but not as active parties in this specific docket.

In conclusion, TECO and OPC have reached a compromise supporting the modified SPP, while staff has not expressed a position on the contentious programs 1, 2, 1, 1.

Docket No. 20250016-EI concerns the Florida Public Service Commission’s review of Tampa Electric Company's (TECO) 2026–2035 Storm Protection Plan (SPP), as required by Rule 25-6.030, Florida Administrative Code. The proceeding involved TECO and the Office of Public Counsel (OPC) submitting joint stipulations and a proposed resolution which, pending Commission approval, would fully resolve their respective issues in this docket. Both parties agreed to admit all pre-filed testimony, exhibits, and staff exhibits into the record, to waive cross-examination of witnesses, and to stipulate positions on each issue identified in the prehearing order. The stipulations expressly state they have no precedential value for future proceedings and that parties may advocate different positions in the future.

Key issues addressed included whether TECO's proposed distribution storm surge hardening and transmission switch hardening programs should be included in the SPP. TECO argued these programs meet statutory and regulatory requirements by reducing restoration costs, outage times, and enhancing reliability in flood-prone areas. OPC objected, recommending exclusion of these programs for non-compliance with filing requirements and suggesting a slower deployment pace to provide rate relief for customers.

The docket also addressed recovery mechanisms for storm hardening costs, with some expenditures eligible for recovery through the Storm Protection Plan Cost Recovery Clause (SPPCRC), while others, such as distribution pole replacements, remain in base rates. The financial impact on customer bills for 2026–2028 was calculated based on these allocations 1, 2, 3.