Case Background
On May 15, 2023,
Duke Energy Florida, LLC (Duke or utility) filed a petition for approval of the
smart outdoor lighting services pilot program (pilot program). Specifically,
Duke is proposing to make modifications to Tariff Sheet Nos. 6.280 and 6.281 to
allow certain customers who take service under the existing LS-1 lighting
tariff to set their own personal lighting schedule and to dim the lights. Currently,
all lights offered under the tariff operate from dusk to dawn.
In Order No.
PSC-2023-0182-PCO-EI, the Commission suspended Duke’s proposed modifications to
Tariff Sheet Nos. 6.280 and 6.281 to allow staff time to gather additional
data. On June 26, 2023, staff issued its first
data request, to which Duke responded on July 17, 2023. Staff issued a second
data request on July 28, 2023, to which Duke responded on August 11, 2023. Staff
noticed a scrivener’s error in the tariff sheets filed with the petition, and
Duke included updated legislative and clean versions of the tariff sheets in
response to staff’s first data request. The proposed legislative tariffs are
included in this recommendation as Attachment A. This recommendation addresses
the proposed smart outdoor lighting services pilot program. The Commission has
jurisdiction over this matter pursuant to Sections 366.03, 366.04, 366.05, and
366.06, Florida Statutes (F.S.).
Discussion
of Issues
Issue 1:
Should the Commission approve Duke's smart outdoor lighting
services pilot program?
Recommendation:
Yes, the Commission should approve Duke’s smart outdoor
lighting services pilot program and the associated revised Tariff Sheet Nos.
6.280 and 6.281 effective on the date of the final Commission order approving
the pilot. The pilot program would allow Duke to gather data on energy usage
changes from participating customers so that it may develop a future program
that is appropriately priced. Participating customers would be able to
customize the operating and dimming schedule of their lights. (Ward)
Staff Analysis:
Rate Schedule LS-1
Rate schedule LS-1, Lighting Service, is available to any
customer for the sole purpose of lighting roadways or other land use areas. Currently,
the energy rates for the LS-1 tariff are set for all customers based on the
same lighting schedule (dusk to dawn), with no option to dim the lights.
Customers taking service under the LS-1 tariff pay a fixed monthly customer
charge, a non-fuel energy charge based on per kWh usage, cost recovery factors,
as well as per unit fixture and maintenance charges. Service is available to
both metered and unmetered customers.
Proposed Pilot Program
Under the proposed pilot program, Duke would offer certain
customers taking service under rate schedule LS-1 the option to set their own
lighting schedules and dim the lights. The rates offered under the current
tariff would remain the same. Customers would be able to schedule lighting
service during the time period from 30 minutes prior to dusk until 30 minutes
after dawn. The terms and conditions of the pilot program state that customers
would be able to request brightness between 50 and 100 percent of the standard
output of the fixture. Additionally, the terms and conditions state that
participating customers would be able to request changes to their lighting
schedules during the pilot program. The processing time for normal schedule
changes would be five business days and the processing time for “emergent
special events” would be three business days. Examples of these special events
given by Duke in response to staff’s first data request include turning off
desired lights for a fireworks show, community concerts, or outdoor movie
events.
If approved, the pilot would run for a period of 18 months
beginning on the date of the final Commission order approving the petition. In
response to staff’s first data request, the utility stated that customers would
be enrolled in the pilot program for a period of 12 consecutive months, with
enrollment ending after the sixth month of the pilot program. In its petition,
the utility stated that it would file an amendment to its LS-1 tariff to remove
references to the pilot program no less than sixty days before its expiration.
Pilot Program Participation and Availability
In its petition, Duke stated that customers would be able
to participate if they take service for at least five light-emitting diode (LED)
lights with company installed smart nodes. In response to staff’s first data
request, Duke stated that it has begun installing the smart nodes on all
compatible LEDs through its typical installation and maintenance work. In
response to staff’s second data request, Duke stated that there are no
incremental costs associated with the installation of a smart node. Additionally,
the utility asserted that, as of July 2023, 250 customers have LED light
fixtures with smart nodes installed. The utility estimates that approximately
25 to 50 customers would participate in the pilot program. Duke proposes to
limit participation in the pilot program to 10,000 lights, while also reserving
the right to allow additional participation.
The pilot program would be available to both metered and
unmetered customers. In response to staff’s first data request, Duke stated
that pilot program participants on LS-1 with metered accounts would be charged
based on their actual kWh usage, so their actual energy consumption would be
charged based on their energy usage (which may be higher or lower). In response to staff’s second data request,
the utility stated that it would measure the impact of the program on unmetered
customers by utilizing vendor provided software that tracks street light usage based
on being on/off or dimmed and compare that to data from a normal streetlight
that turns the light on from dusk to dawn.
In its petition, Duke stated that the purpose of the pilot
program is to gather data on energy usage changes from participating customers
so that it can develop a future permanent program that is appropriately priced.
Examples of customers who might participate in the pilot include a sporting
arena that may only need lights on until the late evening or a parking lot that
may need to light the lot for slightly longer than dusk to dawn.
Pilot Program Costs
In response to staff’s second data request, the utility
stated that the marketing cost of the pilot program is estimated to be between
$3,320 and $5,320. These costs include the one time cost for the development of
a customer website and the one time cost for 500 color printouts of a pilot
program factsheet. Duke stated that these costs are not included in rate base
and would be included in future rate cases if applicable.
Conclusion
Having reviewed the petition and staff data request
responses, staff recommends that the Commission approve Duke’s proposed smart outdoor
lighting services pilot program and associated revised Tariff Sheet Nos. 6.280
and 6.281 effective the date of the final Commission order approving the pilot.
The proposed pilot program would allow Duke to gather data on energy usage
changes from participating customers so that it may develop a permanent future
program that is appropriately priced. Participating customers would be able to
customize the operating and dimming schedules of their lights.
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 not go into effect pending
resolution of the protest. If no timely protest is filed, this docket should be
closed 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 tariff should not go into effect pending
resolution of the protest. If no timely protest is filed, this docket should be
closed upon the issuance of a consummating order.
