Case Background
On October 7,
2019, Florida Power & Light Company (FPL) filed a petition for a one-year
extension of its Voluntary Solar Partnership (VSP) pilot program and associated
tariff. The VSP program was first approved in 2014 (2014 order) as a pilot with
a termination date of December 31, 2017. The VSP pilot program offers all FPL
customers an opportunity, for $9 per month, to participate in a voluntary program
designed to fully-fund the construction and operation of solar photovoltaic
generation facilities. These solar facilities are located in communities
throughout FPL’s service territory. FPL markets the VSP pilot program to
customers as FPL SolarNow. Customers may enroll or cancel their enrollment at
any time.
In 2017, the
Commission approved a one-year extension to allow FPL to gather additional data
regarding the durability of customer interest over a more substantial period. In 2018, the Commission approved an
additional one-year extension to allow FPL to complete and evaluate research
regarding how the VSP pilot program and a community shared solar program,
scheduled to be filed in 2019, may impact one another. On March 13, 2019, FPL filed the community
shared solar program and tariff, known as SolarTogether, for approval before
the Commission.
Since the Commission
is not scheduled to make a decision regarding SolarTogether until 2020, FPL is
requesting an additional one-year extension to the VSP pilot program. This
additional extension will allow FPL to assess and evaluate the potential
overlap in customer interest for the two programs, if SolarTogether is approved
by the Commission. FPL’s proposed VSP tariff revision, as shown in Attachment A
to this recommendation, changes the termination date for service under the pilot
program from December 31, 2019, to December 31, 2020.
FPL waived the
60-day file and suspend provision of Section 366.06(3), Florida Statutes
(F.S.), until the December 10, 2019 Agenda Conference. During the evaluation of
the petition, staff issued data requests to FPL for which responses were filed
on October 29, November 4, and November 14, 2019. The Commission has
jurisdiction over this matter pursuant to Sections 366.05, 366.06, and 366.075,
F.S.
Discussion
of Issues
Issue 1:
Should the Commission approve FPL’s one-year
extension of its VSP pilot program?
Recommendation:
Yes. The Commission should approve the one-year
extension of the VSP pilot program. This extension would allow FPL to evaluate
the potential overlap in customer interest for the proposed SolarTogether
program and the VSP pilot program, if SolarTogether is approved in 2020. The
revised tariff, as shown in Attachment A, should be effective January 1 to
December 31, 2020. FPL should petition the Commission regarding the future status
of the VSP pilot program, prior to its expiration. (Hampson)
Staff Analysis:
Description of the Current VSP Pilot Program
The VSP pilot program is designed to be fully-funded by
customers who contribute on a voluntary basis. Participants contribute to the
revenue requirement associated with constructing and operating solar structures.
The revenue requirement includes a return, depreciation, operations and maintenance
expenses, and other costs such as property taxes and insurance. As required by
the 2014 order, marketing and administrative expenses are capped at 20 percent
of participant contributions. FPL has met this requirement each year since the
VSP pilot program’s inception.
Since 2016, FPL has demonstrated that the revenues
received under the VSP pilot program exceed the revenue requirement of the
solar facilities. FPL projects that the 2019 voluntary customer contributions
will total $5,231,000 by end-of-year, while the 2019 revenue requirement for the
VSP pilot program will total $4,670,000 by end-of-year. The
electricity generated by the solar facilities displaces fuel that otherwise
would have been used for generation, resulting in avoided fuel costs. FPL calculated
the 2019 fuel savings to be $85,000, resulting in a positive net impact to all
customers of $646,000.
As discussed in the 2014 order, FPL sizes the VSP pilot program’s
solar projects based on the level of participation. As of August 31, 2019, FPL
has installed 145 solar structures at 63 locations for a total of 2,325 direct
current kilowatts (kW) of solar capacity. An additional 15 solar structures are
under construction. FPL stated that the completed and planned
solar structures comprise a diverse set of assets, including ground-mount
structures, rooftop installations, covered walkways, parking canopies, and
tree-like structures. These projects are located in public areas, such as
parks, zoos, schools, museums, and transportation hubs. The installation size of
the structures ranges from two kW to 250 kW. In response to staff’s first data
request, No. 7, FPL stated it will not pursue any additional construction until
after the Commission has reached a decision regarding SolarTogether, aside from
the 15 solar structures already in-construction or ready for construction.
Table 1-1 shows the total number of customers
participating in the VSP pilot program for the period May 2015 through May
2019. As of May 2019, there are 54,846 total participants, a 58 percent increase
from May 2018.
Table 1-1
VSP Participants
|
|
Residential
|
Commercial
|
Total Participants
|
|
May 2015
|
155
|
1
|
156
|
|
May 2016
|
3,043
|
27
|
3,070
|
|
May 2017
|
19,226
|
83
|
19,309
|
|
May 2018
|
31,177
|
638
|
34,646
|
|
May 2019
|
54,221
|
625
|
54,846
|
Source: FPL response to staff’s first data request, No. 4.
Proposed FPL SolarTogether Program in Docket No.
20190061-EI
In March 2019, FPL petitioned the Commission for approval
of the proposed SolarTogether program and associated tariff. The matter was
originally set for an administrative hearing on October 15-16, 2019. However,
in response to a motion for continuance, the matter is now set for a hearing on
January 14-16, 2020.
FPL states that until the Commission issues a ruling on
the proposed SolarTogether program, it cannot complete an assessment regarding
the VSP pilot program and SolarTogether. Therefore, FPL states that until it
can complete an assessment regarding the two programs, providing any
recommendation regarding the future of the VSP pilot program would be premature.
In response to staff’s first data request, FPL stated it had three tasks for a
comprehensive assessment of the two programs: (1) gather information about
those interested in SolarTogether; (2) determine if there is an overlap in
those interested in the two programs; and (3) determine if the overlap will
have an impact on the VSP pilot program. Among other things, the proposed SolarTogether
program differs from the VSP pilot program in that it would provide
participants with direct credits on their electric bill associated with energy
generated by the subscribed blocks of solar capacity.
Conclusion
Staff agrees that, pending a Commission decision regarding
SolarTogether, a one-year extension will allow FPL to evaluate the two programs
and any potential overlaps in customer interest. Therefore, staff recommends
approval of the one-year extension of the VSP pilot program and tariff. The
revised tariff, as shown in Attachment A, should be effective January 1 to
December 31, 2020. FPL should petition the Commission regarding the future status
of the VSP pilot program, prior to its expiration.
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 tariff should remain in effect, with
any revenues held subject to refund, pending resolution of the protest. If no
timely protest is filed, this docket should be closed upon the issuance of a
consummating order. (Simmons)
Staff Analysis:
If Issue 1 is approved and a protest is filed within
21 days of the issuance of the order, the tariff should remain in effect, with
any revenues held subject to refund, pending resolution of the protest. If no
timely protest is filed, this docket should be closed upon the issuance of a
consummating order.
