Case Background
As part of the Florida Public Service
Commission’s (Commission) continuing environmental cost recovery clause (ECRC)
proceedings, the Commission conducted a hearing in this docket on November 5,
2018. The parties resolved all issues by stipulation, except for the
Commission’s review of Florida Power & Light Company’s (FPL or Company) Issues
1 through 4, 7, 10A, and 10B detailed within this recommendation. Issues 1
through 4 and 7 relate to the Turkey Point Cooling Canal Monitoring Plan project
(TPCCMP Project), Issue 10A to proposed modifications to the Manatee Temporary
Heating System project (MTHS Project), and 10B to proposed modifications to the
National Pollutant Discharge Elimination System Permit Renewal Requirements
project (NPDES Project).
Testimony on these issues was heard at the
November 5, 2018, hearing. On November 16, 2018, FPL, the Office of Public
Counsel (OPC), and Southern Alliance for Clean Energy (SACE) filed post-hearing
briefs.
The Commission has jurisdiction in this
matter pursuant to Section 366.8255, Florida Statutes (F.S.).
Discussion of Issues
Issue 1:
What
are the final environmental cost recovery true-up amounts for the period
January 2017 through December 2017?
Recommendation:
The
final true-up amount for the period January 2017 through December 2017 for FPL
is an over recovery of $31,560,081. There should be no adjustment to this
amount associated with the TPCCMP Project. (Ellis)
Position of
the Parties
FPL:
$31,560,081
over-recovery.
OPC:
No
position.
SACE:
The Commission should not approve FPL’s request for cost recovery of
TPCCMP remediation activities. FPL’s negligence in the operation of the CCS led
to violations of law and compliance requirements being placed on it. Additionally, FPL is not making timely
progress in meeting its compliance requirements. See Issue 3.
Staff
Analysis:
Parties’ Arguments
FPL
FPL
contends that the Company is eligible for cost recovery for the TPCCMP Project
expenditures associated compliance activities for the 2015 Consent Agreement
(CA) and 2016 Consent Agreement Addendum (CAA) with the Miami-Dade Department
of Environmental Resource Management (DERM) and for the 2016 Consent Order (CO)
with the Florida Department of Environmental Protection (FDEP), as they were
approved in the Commission’s Order No. PSC-2018-0014-FOF-EI during the 2017
ECRC proceeding. (FPL BR
1-2, 5-6) FPL argues that the Commission is not the appropriate regulator to
determine if remediation objectives are being met in a timely manner, but rather
FDEP and DERM are. (FPL BR 6) FPL asserts that the activities for which it
seeks recovery are pursuant to the requirements of the CA, CAA, and/or CO and
are therefore prudent and reasonable. (FPL BR 7-9) FPL states it is in
compliance with the DERM CAA. (FPL BR 9-10)
SACE
SACE
contests FPL’s recovery of TPCCMP Project expenditures as SACE claims that the
Company knew or should have known prior to 1993 that its Turkey Point Plant was
causing an underground hypersaline plume. (SACE BR 1, 3) SACE argues that FPL
ratepayers should not be responsible for FPL’s remediation costs due to the
Company’s imprudent operation of the Turkey Point Plant. (SACE BR 1, 3-4) SACE
contends that FPL has not met its burden of proof to demonstrate projected
costs are reasonable. (SACE BR 2, 4) Specifically, SACE argues that FPL is not
timely complying with its requirements under the CAA and therefore these costs
are not reasonable. (SACE BR 5-7)
Analysis
Final ECRC True-Up
Amount
Based on
the testimony and exhibits of FPL witness Deaton, FPL’s environmental cost recovery
true-up amount for 2017 for all programs is $31,560,081. (TR 22; EXH 13, p. 1)
FPL’s final total for 2017 expenditures for the TPCCMP Project is approximately
$14.2 million. (EXH 13,
p. 4, 9)
TPCCMP Project Eligibility
The
Commission initially approved recovery through the ECRC of FPL’s TPCCMP Project
in the 2009 ECRC Proceeding.
Subsequently, the Commission approved recovery of additional costs associated
with remediation and mitigation activities as required by various environmental
regulators. As a
result, SACE’s argument that FPL’s ratepayers should not be responsible for any
past or projected expenses associated with these activities ignores the
Commission’s prior decision allowing recovery of reasonable costs for the
TPCCMP Project. FPL’s actual, estimated, and projected expenditures for the
TPCCMP project are tied to remediation and mitigation activities required by
its environmental regulators. (TR 285; EXH 14, p. 112; EXH 38, p. 37; EXH 52) While
SACE also argues that TPCCMP Project costs are unreasonable based upon the
allegation that FPL is not timely complying with its environmental requirements,
staff observes that it is not within the Commission’s jurisdiction to determine
whether or not FPL is in compliance meeting its environmental requirements, but
rather that is the role of the environmental regulators. Moreover, staff notes
that FPL witness Sole testified that FPL is currently in compliance with the
CA, CAA, and CO. (TR 366) Therefore, staff recommends that FPL has demonstrated
its actual, estimated, and projected costs, including TPCCMP Project costs, are
reasonable and should be allowed for cost recovery.
Conclusion
The final
true-up amount for the period January 2017 through December 2017 for FPL is an
over-recovery of $31,560,081. There should be no adjustment to this amount
associated with the TPCCMP Project.
Issue 2:
What
are the estimated/actual environmental cost recovery true-up amounts for the
period January 2018 through December 2018?
Recommendation:
The
actual/estimated true-up amount for the period January 2018 through December
2018 for FPL is an under-recovery of $5,614,420. There should be no adjustment
to this amount associated with the TPCCMP Project. (Ellis)
Position of
the Parties
FPL:
$5,614,420 under-recovery.
OPC:
No position.
SACE:
The
Commission should not approve FPL’s request for cost recovery of TPCCMP remediation
activities. FPL’s negligence in the operation of the CCS led to violations of
law and compliance requirements being placed on it. Additionally, FPL is not making timely
progress in meeting its compliance requirements. See Issue 3.
Staff
Analysis:
Parties’ Arguments
FPL
As discussed in Issue 1, FPL argues it is eligible for
cost recovery for costs associated with the TPCCMP Project.
SACE
As
discussed in Issue 1, SACE argues that FPL should not be allowed to recover
costs for the TPCCMP Project as it engaged in imprudent activity and its
projected costs are unreasonable due to the Company being out of compliance
with the CAA.
Analysis
Estimated/Actual
ECRC True-Up Amount
Based on
the testimony and exhibits of FPL witness Deaton, FPL’s environmental cost recovery
true-up amount for 2018 for all programs is $5,614,420. (TR 23; EXH 12, p. 1)
FPL’s actual/estimated total for 2018 expenditures for the TPCCMP Project is
approximately $32.8 million.
(EXH 12, p. 4, 9)
TPCCMP Project Eligibility
As
discussed in Issue 1, the Commission has previously approved the inclusion of
costs for the TPCCMP Project. Staff recommends that FPL has reasonably
demonstrated its activities are associated with the TPCCMP Project and should
be allowed for cost recovery.
Conclusion
The
actual/estimated true-up amount for the period January 2018 through December
2018 for FPL is an under-recovery of $5,614,420. There should be no adjustment
to this amount associated with the TPCCMP Project.
Issue 3:
What
are the projected environmental cost recovery amounts for the period January
2019 through December 2019?
Recommendation:
The
projected amount for the period January 2019 through December 2019 for FPL is a
total of $187,365,910, which includes projected expenditures associated with
the TPCCMP Project. (Ellis)
Position of
the Parties
FPL:
$187,365,910.
OPC:
No position.
SACE:
The
Commission should not approve FPL’s request for cost recovery of TPCCMP
remediation activities. FPL’s negligence in the operation of the CCS led to
violations of law and compliance requirements being placed on it. Additionally, FPL is not making timely
progress in meeting its compliance requirements.
Staff
Analysis:
Parties’ Arguments
FPL
As
discussed in Issue 1, FPL argues it is eligible for cost recovery for costs
associated with the TPCCMP Project.
SACE
As
discussed in Issue 1, SACE argues that FPL should not be allowed to recover
costs for the TPCCMP Project as it engaged in imprudent activity and its
projected costs are unreasonable due to the Company being out of compliance
with the CAA.
Analysis
Projected
ECRC Amount
Based on
the testimony and exhibits of FPL witness Deaton, FPL’s environmental cost
recovery projected amount for 2019 for all programs is $187,365,910. (TR 31;
EXH 14, p. 1) FPL’s projected total includes expenditures for the TPCCMP
Project of approximately $24.3 million.
(EXH 14, p. 2, 52)
TPCCMP Project
Eligibility
As
discussed in Issue 1, the Commission has previously approved the inclusion of
costs for the TPCCMP Project. Staff recommends that FPL has reasonably
demonstrated its activities are associated with the TPCCMP Project and should
be allowed for cost recovery.
Conclusion
The projected
amount for the period January 2019 through December 2019 for FPL is a total of
$187,365,910, which includes projected expenditures associated with the TPCCMP
Project.
Issue 4:
What
are the environmental cost recovery amounts, including true-up amounts, for the
period January 2019 through December 2019?
Recommendation:
The
projected amount, including true-ups, for the period January 2019 through
December 2019 for FPL is a total of $161,536,472 to be recovered from
ratepayers, which includes projected expenditures associated with the TPCCMP
Project. (Ellis)
Position of
the Parties
FPL:
$161,536,472, including prior
period true-up amounts and revenue taxes.
OPC:
No position.
SACE:
The
Commission should not approve FPL’s request for cost recovery of TPCCMP
remediation activities. FPL’s negligence in the operation of the CCS led to
violations of law and compliance requirements being placed on it. Additionally, FPL is not making timely
progress in meeting its compliance requirements. See Issue 3.
Staff
Analysis:
Parties’ Arguments
FPL
As
discussed in Issue 1, FPL argues it is eligible for cost recovery for costs
associated with the TPCCMP Project.
SACE
As
discussed in Issue 1, SACE argues that FPL should not be allowed to recover
costs for the TPCCMP Project as it engaged in imprudent activity and its
projected costs are unreasonable due to the Company being out of compliance
with the CAA.
Analysis
Projected
ECRC Amount
Based on
the testimony and exhibits of FPL witness Deaton, FPL’s environmental cost recovery
amount, including true-up amounts, is $161,536,472. (TR 31; EXH 14, p. 1) FPL’s
expenditures for the period 2017 through 2019 for the TPCCMP Project are
approximately $71.2 million. (EXH
12, p. 4, 9; EXH 13, p. 4, 9; EXH 14, p. 2, 52)
TPCCMP Project
Eligibility
As
discussed in Issue 1, the Commission has previously approved the inclusion of
costs for the TPCCMP Project. Staff recommends that FPL has reasonably
demonstrated its activities are associated with the TPCCMP Project and should
be allowed for cost recovery.
Conclusion
The
projected amount, including true-ups, for the period January 2019 through
December 2019 for FPL is a total of $161,536,472 to be recovered from
ratepayers, which includes projected expenditures associated with the TPCCMP
Project.
Issue 7:
What are
the appropriate environmental cost recovery factors for the period January 2019
through December 2019 for each rate group?
Recommendation:
If
the Commission approves staff’s recommendation in Issue 4, staff recommends
approval of FPL’s factors as shown in FPL witness Deaton’s Exhibit RBD-4. If
the Commission denies staff’s recommendation in Issue 4, FPL should file
revised factors and associated tariffs implementing the Commission vote for
administrative approval by staff. (Ellis)
Position of
the Parties
FPL:
|
RATE CLASS
|
Environmental Cost Recovery Factor
(cents/kWh)
|
|
RS1/RTR1
|
0.159
|
|
GS1/GST1
|
0.157
|
|
GSD1/GSDT1/HLFT1
|
0.142
|
|
OS2
|
0.086
|
|
GSLD1/GSLDT1/CS1/CST1/HLFT2
|
0.139
|
|
GSLD2/GSLDT2/CS2/CST2/HLFT3
|
0.121
|
|
GSLD3/GSLDT3/CS3/CST3
|
0.121
|
|
SST1T
|
0.108
|
|
SST1D1/SST1D2/SST1D3
|
0.138
|
|
CILC D/CILC
G
|
0.121
|
|
CILC T
|
0.112
|
|
MET
|
0.130
|
|
OL1/SL1/SL1M/PL1
|
0.035
|
|
SL2/SL2M/GSCU1
|
0.113
|
|
|
|
|
Total
|
0.149
|
OPC:
No position.
SACE:
For FPL, the factor amount should not include any cost
recovery for remediation activities related to the TPCCMP.
Staff Analysis:
Parties’ Arguments
FPL
As
discussed in Issue 1, FPL argues it is eligible for cost recovery for costs
associated with the TPCCMP Project.
SACE
As
discussed in Issue 1, SACE argues that FPL should not be allowed to recover
costs for the TPCCMP Project as it engaged in imprudent activity and its
projected costs are unreasonable due to the Company being out of compliance
with the CAA.
Analysis
If the
Commission approves staff’s recommendation in Issue 4, staff recommends
approval of FPL’s factors as shown in FPL witness Deaton’s Exhibit RBD-4 (EXH
14, p. 131). If the Commission denies staff recommendation in Issue 4, FPL
should file revised factors and associated tariffs implementing the Commission
vote for administrative approval by staff.
Issue 10A:
Should the
Commission approve FPL’s Petition for Approval of Modification to Manatee
Temporary Heating System Project and the recovery of the associated costs
through the ECRC pursuant to Section 366.8255, F.S.?
Recommendation:
Yes.
The Commission should approve FPL’s petition and be allowed to recover costs
associated with its proposed modification to the MTHS Project as it addresses
an environmental requirement triggered after the Company’s last rate case.
Reasonable costs associated with the project should be allowed to be recovered
through the ECRC. (Ellis)
Position of
the Parties
FPL:
Yes. The PFM MTHS Project is
being undertaken in order to comply with PFM’s Manatee Protection Plan during
periods when PFM is shut down for extended outages or because it is not being
economically dispatched. Installation of the proposed MTHS is a cost-effective
way to meet PFM’s compliance requirement.
OPC:
Maybe. The Commission must, nevertheless independently determine that
each cost submitted for recovery meets each element of the statutory
requirements for recovery through this clause as set out in Section 366.8255,
Florida Statutes. FPL has not proven that these costs fully meet the statutory
test to the extent it relies on prior approvals of similar types of projects
for meeting the Company’s burden of proof.
SACE:
No position.
Staff
Analysis:
Parties’ Arguments
FPL
FPL argues
that the proposed modifications to the MTHS Project to include an additional
heating system at the Plant Fort Myers (Fort Myers). (FPL BR 2, 11-13) FPL
asserts that it is required to install a new system as Fort Myers is no longer
adequately dispatched during manatee season, risking putting it out of
compliance with its environmental requirements. (FPL BR 12-14) FPL argues that
the proposed Fort Myers system is eligible for recovery under the ECRC and
represents the most cost-effective solution. (FPL BR 14-16)
OPC
OPC agrees
that FPL has submitted adequate evidence to meet all the criteria necessary to qualify
for recovery through the ECRC on a stand-alone basis. (OPC BR 2, 4) OPC expresses
concerns that the Company’s filing appears to rely upon the Commission’s prior
approval of similar projects, instead of independent approval, by including an
additional project under the MTHS Project. (OPC BR 1-4)
Analysis
MTHS Project
and Proposed Modifications
The
Commission initially approved recovery through the ECRC of FPL’s MTHS Project
in the 2009 ECRC proceeding, addressing the Company’s Riviera Beach and Cape
Canaveral facilities.
Subsequently, the Commission approved recovery of costs associated with the
Port Everglades and Dania Beach facilities in the 2012 and 2017 ECRC
proceedings, respectively.
As
described by FPL witness Sole, FPL is seeking to recover costs associated with
a heating system for Fort Myers to keep water temperatures high enough to
maintain a manatee refuge (TR 268-269). The proposed addition includes electric
heating equipment and associated intake and pumping systems. (TR 274)
Eligibility
Criteria
The ECRC, enacted into law in
1993, provides an investor-owned utility the opportunity to recover the costs
associated with changes in environmental regulations between rate cases. The
statute authorizes the Commission to review and decide whether a utility’s
environmental compliance costs are recoverable through an environmental cost
recovery factor. When the Commission first implemented the provisions of
Section 366.8255, F.S., it identified the criteria required to demonstrate eligibility
for cost recovery under the ECRC clause:
1. Such costs were prudently
incurred after April 13, 1993;
2. The activity is legally required
to comply with a governmentally imposed environmental regulation enacted,
became effective, or whose effect was triggered after the Company’s last test
year upon which rates are based; and,
3. Such costs are not recovered
through some other cost recovery mechanism or through base rates.
Pursuant to Section 366.8255, F.S., only the utility’s
prudently incurred environmental compliance costs are allowed to be recovered through
the ECRC. Staff
notes that its review of the proposed modification to the MTHS Project is based
upon the information in the hearing record regarding these specific modifications
and whether these modifications independently meet the ECRC criteria and
reasonableness tests.
Eligibility Criteria Review
As the proposed
modification to the MTHS Project was implemented beginning in 2018, it meets
the first criterion. FPL witness Sole states that FPL is not recovering any
MTHS Project costs through an alternate mechanism, which addresses the third
criterion. (TR 278)
The second
criterion is dependent upon timing of the Utility’s last rate case and the
environmental regulation. FPL’s most recent rate case was resolved by a
settlement between many parties, including FPL and OPC, and approved by the
Commission in Order No. PSC-16-0560-AS-EI. FPL
witness Sole identifies the environmental regulation requiring the proposed modification
of the MTHS Project as FDEP’s Industrial Wastewater Facility Permit (Permit)
for Fort Myers, issued January 20, 2016. (EXH 4) The Permit states, in relevant
part, “The permittee shall continue compliance with the facility's Manatee
Protection Plan approved by [FDEP] on August 18, 1999.” (TR 269; EXH 4). This
requires FPL to maintain a warm water manatee refuge during mid-November
through the end of March annually, unless it endangers the safety or
reliability of Fort Myers. (EXH 5) FPL witness Sole argues that operating
circumstances have changed since FPL’s most recent rate case, effectively
triggering the effects of the Permit, due to a combination of scheduled
maintenance outages and reductions in the projected economic dispatch of Fort
Myers. (TR 270-273) The proposed MTHS Project therefore meets the second
criterion.
Regarding
the reasonableness of expenditures for the modification to the MTHS Project,
FPL evaluated alternatives including operating Fort Myers out of economic
dispatch or using a temporary diesel system. (TR 272-273; EXH 36, p. 6) No other
available alternative was as cost-effective at meeting the environmental
requirement as the proposed system at Fort Myers. Therefore, the costs
associated with the modification of the MTHS Project appear reasonable at this
time.
Conclusion
The Commission should approve FPL’s petition and be
allowed to recover costs associated with its proposed modification to the MTHS
Project as it addresses an environmental requirement triggered after the Company’s
last rate case. Reasonable costs associated with the project should be allowed
to be recovered through the ECRC.
Issue 10B:
Should
the Commission approve FPL’s Petition for Approval of Modification to National
Pollution Discharge Elimination System Permit Renewal Requirement Project and
the recovery of the associated costs through the ECRC pursuant to Section
366.8255, F.S.?
Recommendation:
No. The
proposed modification to the NPDES Project does not meet the threshold
requirement of being necessary to comply with environmental regulations as
required by Section 366.8255, F.S. Therefore, the Commission should deny recovery
of costs through the ECRC at this time. (Ellis)
Position of
the Parties
FPL:
Yes. It is anticipated that Plant
Scherer’s renewed NPDES permit will include a limit on copper discharges. Repacking
Scherer Unit 4’s cooling tower fill medium is a cost-effective way to reduce
copper levels.
OPC:
No. The Commission must, nevertheless independently determine that each
cost submitted for recovery meets each element of the statutory requirements
for recovery through this clause as set out in Section 366.8255, Florida
Statutes. FPL has not proven that these costs fully meet the statutory test to
the extent it relies on prior approvals of similar types of projects for
meeting the Company’s burden of proof. This project may not be ripe for
approval.
SACE:
No position.
Staff
Analysis:
Parties’ Arguments
FPL
FPL states
that its proposed modification to the NPDES Project includes the replacement of
cooling tower packing material at Plant Scherer Unit 4 (Scherer). (FPL BR 2,
16) FPL asserts that Scherer is likely to be required to limit copper discharge
in future environmental permits, and the replacement addressed this concern.
(FPL BR 17-19) FPL seeks ECRC recovery of the modifications to the NPDES
Project contingent upon the issuance of a future environmental permit including
the copper limitation requirement. (FPL BR 20) FPL argues that the modification
to the NPDES Project satisfies the requirements of recovery for the ECRC as it
is based on an anticipated environmental regulation. (FPL BR 20-21)
OPC
OPC
expresses concern that the contingent nature of FPL’s request for a modification
to the NPDES Project is outside of the scope of Section 366.8255, F.S. (OPC BR
1, 5) OPC objects that the Company’s filing appears to rely upon the Commission’s
prior approval of similarly named projects, instead of independent approval.
(OPC BR 5-6, 7-8) OPC argues that the proposed project is significantly
different from the prior projects approved under the NPDES Project. (OPC BR 6)
OPC also asserts that as the project has already been completed, there is no
urgency requiring a contingent approval. (OPC BR 7)
Analysis
NPDES Project and Proposed Modifications
The
Commission initially approved recovery through the ECRC of FPL’s NPDES Project
in the 2011 ECRC proceeding. The
project was focused on complying with then-new FDEP requirements to establish
whole effluent toxicity limits and prepare storm water pollution prevention plans.
Subsequently, the Commission approved recovery of costs associated with the St.
Lucie facility’s renewed permit, specifically a requirement to conduct a total
residual oxidants plan of study, in the 2012 ECRC proceeding.
As
described by FPL witness Sole, FPL is seeking to recover costs associated with
the replacement of cooling tower packing material at Scherer due to meet
anticipated permit conditions. (TR 279) The replacement of cooling tower packing
material began in March 2018 and was completed in May 2018. (EXH 14, p. 118) FPL
is a joint owner of Scherer and its requested recovery is proportional to its
ownership interest in Scherer. (EXH 36, p. 13) FPL initially estimated its
portion of costs was $9 million, but the actual cost was $7.9 million. (EXH 14,
p. 118) FPL witness Deaton notes FPL is not seeking recovery through the ECRC
at this time, therefore the cost of the project does not affect FPL’s proposed
ECRC expenditures discussed above in Issues 3 and 4. (TR 18)
Eligibility
Criteria
As discussed in Issue 10A, the criteria required to
demonstrate eligibility for cost recovery under the ECRC include whether: (1) costs
were prudently incurred after April 13, 1993; (2) the activity is legally
required to comply with a governmentally imposed environmental regulation after
the Company’s last rate case test year; and (3) costs are not recovered through
another mechanism or through base rates. Pursuant
to Section 366.8255, F.S., only the utility’s prudently incurred environmental
compliance costs are allowed to be recovered through the ECRC. Staff
notes that its review of the proposed modification to the NPDES Project is
based upon the information in the hearing record regarding these specific
modifications and whether these modifications independently meet the ECRC
criteria and reasonableness tests.
Eligibility Criteria Review
As the
proposed modification to the NPDES Project was implemented in 2018, it
therefore meets the first criterion. FPL witness Deaton states that FPL is not
currently seeking recovery of costs associated with the proposed modification
to the NPDES Project, and that the Company plans to recover costs in base
capital accounts prior to issuance of the revised permit. (TR 18) The Company
requests approval to transfer recovery to the ECRC if the anticipated
environmental requirement occurs. (TR 18-19) As such, current base rates are
supporting the expenditures associated with the proposed modification to the
NPDES Project.
The second
criterion is dependent upon timing of the Utility’s last rate case and the
environmental regulation. As discussed in Issue 10A, FPL’s base rates were last
established by a settlement by Order No. PSC-16-0560-AS-EI, issued December 15,
2016. The
Company describes repacking activities in 2018 as the modification to the NPDES
Project to address anticipated permit conditions. (TR 326; EXH 50, NPDES
Project petition) FPL witness Deaton specifies that the Company’s request is
contingent upon a possible outcome of a future permit for Scherer. (TR 18) FPL witness
Sole states that there are “indications that there is a probability that there
is a concern” regarding copper at Scherer. (TR 338)
Based on
the record in this docket, staff recommends that it is premature to approve
recovery of the proposed modification to the NPDES Project, as the
environmental regulation has not yet been enacted, become effective, or had its
effects triggered. Therefore, the proposed modification to the NPDES Project
fails the second criterion at this time.
Conclusion
The proposed
modification to the NPDES Project does not meet the threshold requirement of
being incurred to comply with environmental regulations as required by Section
366.8255, F.S. Therefore, the Commission should deny recovery of costs through
the ECRC at this time.
Order No.
PSC-05-0164-PAA-EI, issued on February 10, 2005, in Docket No. 20041300-EI, In re: Petition for Approval of New
Environmental Program for Cost Recovery Through Environmental Cost Recovery
Clause, by Tampa Electric Company.
Order No.
PSC-05-0164-PAA-EI, issued on February 10, 2005, in Docket No. 20041300-EI, In re: Petition for Approval of New
Environmental Program for Cost Recovery Through Environmental Cost Recovery
Clause, by Tampa Electric Company.
