Case Background
On
September 5, 2017, Tampa Electric Company (TECO or company) filed a petition
seeking Commission approval for revisions to its Lighting Service (LS-1)
tariff. The LS-1 tariff is applicable to any customer for the sole purpose of
lighting roadways or other outdoor areas. Specifically, TECO proposed to close
its existing 17 Light Emitting Diode (LED) fixture offerings to new customers,
approve 21 new LED fixture offerings, add two new pole options, close two pole
options to new customers, and revise the outdoor lighting agreement. The
proposed tariff revisions are shown in Exhibit A to the petition. Due to their
voluminous nature, the tariffs have not been attached to this recommendation.
TECO
filed this docket in conjunction with Docket No. 20170199-EI, in which TECO
requested approval of its conservation street and outdoor lighting conversion program
as a Demand Side Management program. The conversion program would allow TECO to
convert its non-LED lighting facilities to LED service over the next five
years.
The Commission
first approved TECO’s LED lighting tariff in 2013. In 2015, the High Pressure Sodium (HPS)
and Metal Halide (MH) lighting services and their associated tariffs were
closed to new customers. The closure of the HPS and MH lighting
resulted in TECO offering only LED lighting to new outdoor lighting customers. Existing
customers who were receiving service under the HPS and MH tariffs at that time
were grandfathered in and continue to receive such service today.
On September 15,
2017, TECO waived the 60-day file and suspend provision per Section 366.06(3),
Florida Statutes (F.S.). During the review of TECO’s petition, staff issued
three data requests to the Company and held an informal, noticed meeting
related to this docket and Docket No. 20170199-EI on November 18, 2017. On
November 20, 2017, TECO filed a letter summarizing the representations made by
the company at the November 18, 2017 meeting.
On December 15,
2017, TECO filed a letter with the Commission stating that the company is no
longer requesting Commission approval of a capital recovery schedule referred
to in paragraphs 22, 23, and 27 of the petition in the instant docket. The
letter served as an amendment to TECO’s petition.
The cities of
Tampa, Temple Terrace, Plant City, and Winter Haven, and Polk County filed
letters on November 27, 2017, December 15, 2017, December 28, 2017 and on January
24, 2018, respectively, supporting the company’s proposed LED Lighting
Conversion Program. On January 11, 2018, Southern Alliance for Clean Energy
also filed a letter in support of TECO’s program. The Commission has
jurisdiction over this matter pursuant to Sections 366.03, 366.04, 366.05, and
366.06, F.S.
Discussion
of Issues
Issue 1:
Should the Commission approve TECO's proposed lighting
service tariff revisions?
Recommendation:
Yes. The Commission should approve TECO’s proposed lighting
service tariff revisions effective February 6, 2018. (Guffey)
Staff Analysis:
TECO provides outdoor lighting utilizing three
lighting technologies: (1) HSP, (2) MH, and (3) LED. TECO offers only LED
lighting to new customers with both HPS and MH service closed to new customers.
The company asserts that 35 percent of TECO’s lighting customers are government
customers and consist primarily of roadway lighting service.
Proposed Tariff Revisions
In conjunction with the proposed conversion program
discussed in Docket No. 20170199-EI, TECO proposed revisions to its lighting
tariffs as a vehicle for implementing the conversion program. The proposed
tariff revisions are discussed in more detail below.
TECO proposed to close its 17 existing LED offerings to
new customers (Tariff Sheet No. 6.808). The company, in its response to staff’s
first data request stated that the currently approved LED tariffs were based on
2012 LED material costs. Since then, the material costs have decreased and the
efficiency of the lighting fixtures has improved, resulting in revised lighting
charges.
Therefore, TECO proposed 21 new
LED fixture offerings (Tariff Sheet No. 6.809) and associated charges. The
charges for the new LED lighting category are comprised of three components: a
fixture charge, a maintenance charge, and a non-fuel energy charge, consistent
with TECO’s other lighting options. The fixture charges were developed based on
material costs (luminaire, bracket, and materials handling) plus labor and
vehicle costs associated with installation. The maintenance charges were
developed based on TECO’s estimated maintenance costs by fixture type; primary
elements of expected maintenance costs pertain to the luminaire unit and
luminaire parts. The non-fuel energy
charge is determined by multiplying the estimated kilowatt-hour (kWh) usage by
fixture type by the non-fuel energy charge as approved in TECO’s most recent
rate proceeding.
The new LED fixtures will utilize
a next generation photocell called a Networked Lighting Controller (NLC) that
contains embedded wireless communication technology that will enable the
company to remotely sense maintenance and outage events, provide remote on and
off capabilities, measure real time input voltage, current, power factor,
energy consumption, GPS location, and have the ability to communicate the
information back to the company via the communication network. The costs of the
NLC are included in the monthly fixture charges and the expected maintenance
costs of the NLC are included in the monthly maintenance charge for each LED
fixture.
In addition to the above discussed lighting requests, TECO
proposed to add two new pole options while closing two pole options (Round and
Winston pole style) to new customers. The proposed new poles (Winston and
Waterside pole style) are aluminum and, as explained by TECO in response to
staff discovery, are expected to provide reduced maintenance issues. As the
Round and Winston poles fail over time, they will be replaced with the new
Winston and Waterside pole offerings; however, the poles are not part of the
conversion program.
Finally, TECO proposed revisions to its outdoor lighting
agreement, which contains an initial 10-year term. The conversion program does
not require the customers to sign a new lighting agreement nor does the conversion
program require that customers agree to any extension of service obligation
under their existing agreement. The proposed changes to the agreement include
language to allow for other services made available via NLC, language to
provide flexibility to manage the pace of luminaire technology progression, and
remove language that is duplicated within the tariff.
Customer Notification
TECO has prepared general correspondence, including a news
release and letter, describing the benefits of LED lighting and the conversion
program to existing lighting customers and door hangers for customers whose HPS
or MH fixture will be replaced with an LED fixture upon failure. Customers in
planned geographical areas will receive targeted communication directly before
the conversion begins. TECO stated that it has had communication with larger
volume lighting customers, such as cities and counties, about the planned
conversions. TECO also stated that customers whose bills will increase as a
result of the conversion will receive a letter from the company and TECO will
provide options for additional communications through email and phone calls.
Conclusion
TECO asserts
that approval of new tariffs for new LEDs which when implemented will utilize
less energy, and thereby provide energy conservation benefits to its customers.
While the cost of HPS and MH is increasing due to lower production, the new
generation LED lighting costs have decreased substantially allowing for lower
cost of ownership. Additional features of new generation LED lighting include reliability,
uniformity of foot-candles, less stray light, and fewer unit failures (due to
fewer components, and due to operating closer to ambient temperatures). For the
reasons stated above, staff recommends approval of TECO’s proposed lighting service
tariff revisions effective February 6, 2018.
Issue 2:
Should this docket be closed?
Recommendation:
Yes. If Issue 1 is approved, the tariffs should
become effective on February 6, 2018. If a protest is filed within 21 days of
the issuance of the order, the tariffs should remain in effect, with any
revenues held subject to refund, pending resolution of the protest. If no
timely protest is filed, the docket should be closed upon the issuance of a
consummating order. (Trierweiler)
Staff Analysis:
If Issue 1 is approved, the tariffs should become
effective on February 6, 2018. If a protest is filed within 21 days of the
issuance of the order, the tariffs should remain in effect, with any revenues
held subject to refund, pending resolution of the protest. If no timely protest
is filed, the docket should be closed upon the issuance of a consummating
order.
