Case Background
On October 4,
2017, Florida Power & Light Company (FPL or company) filed a petition
requesting modifications to its curtailable service (CS) tariffs. The company
is seeking to institute a 30-day notice for customers enrolled in its CS tariffs,
including CS Time of Use, to transfer to the Commercial/Industrial Demand
Reduction Rider (CDR) tariff. The CS and CDR are optional tariffs for
Commercial/Industrial (C/I) customers who are willing to curtail a portion of
their demand in exchange for a monthly credit. In addition, FPL proposes to
close the CS tariffs to new customers due to a lack of interest.
On October 13, 2017, FPL waived the 60-day suspension
deadline through March 1, 2018. Staff issued a data request to FPL on November
13, 2017, and the company responded on November 27, 2017. Also on November 27,
2017, FPL filed a notice of correction to its petition, correcting a
scrivener’s error. Staff issued its second data request on December 4, 2017,
for which responses were received on December 11, 2017. Attachment A of this
recommendation provides the CS tariff pages indicating the proposed changes. The
Commission has jurisdiction over this matter pursuant to Sections 288.035 and
366.06, Florida Statutes.
Discussion
of Issues
Issue 1:
Should the Commission approve FPL’s petition for curtailable
service tariff modifications?
Recommendation:
Yes. The Commission should approve FPL’s proposed curtailable
service tariff modifications. Staff believes that this proposal provides load
control benefits to the company and ratepayers. C/I customers also benefit from
higher credits. Closure of the CS tariffs is acceptable due to lack of
interest. (Morgan)
Staff Analysis:
The CS and CDR Tariffs
The CS tariffs are available to C/I customers with a monthly demand of
500 kilowatts (kW) or greater. Customers who choose to take service under CS
agree to curtail at least 200 kW of their load when requested by the company.
For their compliance, the customer receives a credit of $1.93 per kW of
curtailable load. Customers are required to provide three years’ notice to
discontinue service under the CS tariffs.
The CDR is available to C/I customers who have at least
200 kW of non-firm demand, above their firm demand level, available for the
utility to control. This demand must be demonstrated for at least three out of
seven months of the summer Controllable Rating Period (April 1 through October
31). Customers who take service under the CDR agree to have load control
equipment installed at their site. A credit of $8.20 is given for each kW of utility-controlled
demand. The CDR provides higher credits than the CS tariffs since the customer cedes
control of a portion of their demand to FPL. Both tariffs appear to be
cost-effective according to the Commission’s standards.
FPL’s Proposal
FPL is seeking to institute a 30-day notice for existing
customers to transfer from the CS tariffs directly to the CDR. FPL’s tariffs do
not offer a direct transfer between non-firm service options at this time. Customers
currently must terminate service from the CS tariffs with three years’ notice in
order to then join the CDR.
Currently, the company provides service to 31 customers under CS
tariffs. According to FPL, 16 of those customers have the required demand to
qualify for the CDR. Out of those 16, seven customers have expressed interest
in a direct transfer from the CS tariffs to the CDR. The credits provided to
customers under both tariffs are recovered by the company as Demand-Side
Management programs through the Energy Conservation Cost Recovery Clause (ECCR).
In the company’s petition, FPL states that the ECCR impact of all 16 eligible
customers transferring to the CDR would be 0.0008 cents per kilowatt hour (kWh)
or less than $0.01 per 1,000 kWh. These 16 potential transferees would join 526
customers who presently take service under the CDR.
FPL also seeks to close the CS tariffs to new customers.
According to FPL, no new customers have opted to take service under the CS
tariffs since 2010. It should be noted that this petition will allow CS
customers to transfer to any non-firm service option, but the CDR is the only
current alternative. FPL will also update Tariff Sheet Nos. 8.542 and 8.545 to correct
outdated cross-references.
Conclusion
Staff considers the proposed
change an efficient transfer between Commission-approved, cost-effective
programs. As stated by FPL, the customers will benefit from higher credits
while the company and ratepayers will benefit from improved load control. The closure
of the CS tariffs is reasonable due to the lack of new participants since 2010.
Staff recommends approval of FPL’s curtailable service tariff modifications.
Issue 2:
Should this docket be closed?
Recommendation: If Issue 1 is approved and a protest is filed within 21 days of the
issuance of the order, the tariffs should not go into effect, pending resolution
of the protest. If no timely protest is filed, this docket should be closed and
the tariff shall become effective upon the issuance of a consummating order.
(Brownless)
Staff Analysis:
If Issue 1 is approved and a protest is filed within 21
days of the issuance of the order, the tariffs should not go into effect,
pending resolution of the protest. If no timely protest is filed, this docket
should be closed and the tariff shall become effective upon the issuance of a
consummating order.
