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State of Florida
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Public Service Commission
Capital Circle Office Center ● 2540 Shumard
Oak Boulevard
Tallahassee, Florida 32399-0850
-M-E-M-O-R-A-N-D-U-M-
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DATE:
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February 20, 2025
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TO:
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Office of Commission Clerk (Teitzman)
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FROM:
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Division of Engineering (Sanchez, Ellis,
Ramos)
Office of the General
Counsel (Sparks, Imig)
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RE:
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Docket No. 20240167-EG – Petition for
approval of demand-side management plan, by JEA.
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AGENDA:
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03/04/25 – Regular Agenda – Proposed Agency Action – Interested
Persons May Participate
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COMMISSIONERS ASSIGNED:
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All Commissioners
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PREHEARING OFFICER:
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Clark
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CRITICAL DATES:
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None
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SPECIAL INSTRUCTIONS:
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Staff recommends the
Commission simultaneously consider Docket Nos. 20240163-EG, 20240166-EG,
20240167-EG, 20240169-EG, and 20240170-EG.
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Case Background
Sections 366.80
through 366.83, and 403.519, Florida Statutes (F.S.), known collectively as the
Florida Energy Efficiency and Conservation Act (FEECA), require the Florida
Public Service Commission (Commission) to adopt conservation goals to increase
the efficiency of energy consumption. FEECA emphasizes reducing the growth
rates of weather-sensitive peak demand, reducing and controlling the growth
rates of electricity consumption, reducing the consumption of expensive
resources such as petroleum fuels, and encouraging demand-side renewable energy
resources. The Commission most recently established conservation goals for JEA
(JEA or Utility) by Order No. PSC-2024-0432-FOF-EG (2024 Goalsetting Order),
issued September 20, 2024, in Docket No. 20240016-EG. On December 19, 2024, JEA filed a petition
requesting approval of its DSM Plan and associated program standards.
The Commission
has jurisdiction over this matter pursuant to Sections 366.80 through 366.83
and 403.519, F.S.
Discussion
of Issues
Issue 1:
Should the Commission approve JEA’s DSM Plan and
program standards?
Recommendation:
Yes. JEA’s DSM Plan is consistent with the proposed
programs used to establish its DSM goals and is projected to meet the annual
numeric conservation goals approved by the Commission in the 2024 Goalsetting
Order. Staff has reviewed JEA’s program participation and administrative
standards and they appear to be consistent with JEA’s DSM Plan. Therefore,
staff recommends that JEA’s DSM plan and program standards be approved. JEA’s
local governing body will make its own determination as to whether expenditures
are reasonable and prudent. In addition, staff requests that JEA notify the
Commission prior to modifying its DSM Plan or program standards. (Sanchez)
Staff Analysis:
Section 366.82(7), F.S., requires that, following
the adoption of the annual conservation goals, the Commission shall also
require each utility subject to FEECA to develop a demand-side management (DSM)
plan to meet those conservation goals. Rule 25-17.0021(4), Florida
Administrative Code (F.A.C.), requires each electric utility subject to FEECA
to file its DSM plan, which consist of one or more DSM programs, and program
participation standards for Commission approval. The Commission has considered
the appropriateness of DSM programs by evaluating the following criteria, first
outlined in Order No. 22176: 1) whether the program advances the policy
objectives of FEECA and its implementing rules (such as reducing demand and
energy usage); 2) whether the program is directly monitorable and yields
measurable results; and 3) whether the program is cost-effective. Pursuant
to 366.82(7), F.S., the Commission may then elect to approve, modify, or deny
the utility’s DSM Plan.
JEA’s Proposed DSM Plan
Staff has reviewed JEA’s DSM Plan including its demand and
energy savings, cost-effectiveness, and rate impact. Overall, the programs
within the proposed DSM Plan are consistent with the proposed DSM programs
evaluated by the Commission in the 2024 DSM Goalsetting proceeding. A complete
list of the programs and a brief description of each can be found in Attachment
A. JEA also submitted its program participation and administrative standards,
which can be found in Attachment B, and they appear consistent with JEA’s DSM
Plan.
JEA’s DSM Plan consists of a total of four programs: three
residential programs and one commercial/industrial program. JEA has proposed to
continue its Residential Neighborhood Efficiency program and Commercial
Prescriptive Lighting program while adding two new programs.
The projected program demand and energy savings meet the
goals established by the Commission in the 2024 Goalsetting Order, and the
programs included in JEA’s DSM Plan are directly monitorable and measurable. As
required by Rule 25-17.008, F.A.C., JEA provided cost-effectiveness analyses
for the programs included in its DSM Plan using the Rate Impact Measure (RIM),
the Total Resource Cost (TRC), and the Participants tests. All of the DSM
programs passed the Participants test, all but one passed the TRC test, and all
programs failed the RIM test. Staff notes that the cost-effectiveness of the
DSM programs is consistent with what was provided in the 2024 Goalsetting
proceeding. Overall, staff recommends that JEA’s DSM plan and program standards
be approved.
JEA is responsible for continuing to monitor actual
participation in its programs and requesting modifications to its DSM plan
and/or program standards as necessary to meet the annual conservation goals. If
JEA is unable to meet the annual conservation goals established by the
Commission the Utility may be subject to appropriate action by the Commission. The
costs to implement the programs within JEA’s DSM Plan will be established by
the municipal utility’s governing body if the plan is approved. Table 1-1 shows
an estimate of the monthly rate impact on the typical residential customer over
the 2025 through 2034 period.
Table 1-1
JEA’s DSM Plan Estimated
Monthly Rate Impact
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Year
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Residential
Customer Rate Impact
($/1,200 kWh-mo)
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2025
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0.26
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2026
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0.28
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2027
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0.30
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2028
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0.31
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2029
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0.33
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2030
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0.35
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2031
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0.36
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2032
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0.37
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2033
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0.37
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2034
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0.36
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Source: JEA’s Response to
Staff’s First Data Request
Conclusion
JEA’s DSM Plan is consistent with the proposed programs
used to establish its DSM goals and is projected to meet the annual numeric
conservation goals approved by the Commission in the 2024 Goalsetting Order.
Staff has reviewed JEA’s program participation and administrative standards and
they appear to be consistent with JEA’s DSM Plan. Therefore, staff recommends
that JEA’s DSM plan and program standards be approved. JEA’s local governing
body will make its own determination as to whether expenditures are reasonable
and prudent. In addition, staff requests that JEA notify the Commission prior
to modifying its DSM Plan or program standards.
Issue 2:
Should this docket be closed?
Recommendation:
Yes. If no person whose substantial interests are
affected by the proposed agency action files a protest within 21 days of the
issuance of the Order, this docket should be closed upon the issuance of a
Consummating Order. (Sparks)
Staff Analysis:
If no person whose substantial interests are
affected by the proposed agency action files a protest within 21 days of the
issuance of the Order, this docket should be closed upon the issuance of a
Consummating Order.
JEA
Program Descriptions
RESIDENTIAL PROGRAMS
Residential Home Efficiency Upgrades
Rebates Program
JEA has been offering its
Residential Home Efficiency Upgrades Rebates Program since 2007 and will
continue offering it as part of JEA’s 2025 DSM Plan. The Program consists of incentives
(rebates) for customers to improve the efficiency of their homes through the
installation of qualifying heat pump water heaters, improvements to the
heating, ventilation, and air conditioning (HVAC) systems, or ceiling
insulation. This Program is offered to all Residential customers in JEA’s
service territory.
Residential Energy Efficient Products
Rebates Program
JEA has been offering its
Residential Energy Efficient Products Rebates Program since 2007 and will
continue offering it as part of JEA’s 2025 DSM Plan. The Program consists of
incentives (rebates) for customers to improve the efficiency of their homes
through the installation of ENERGY STAR clothes washers, room air conditioners,
and smart thermostats. This Program is offered to all Residential customers in
JEA’s service territory through select home improvement stores and retailers.
Residential Neighborhood Energy
Efficiency (NEE) Program
JEA has been offering its
Residential NEE Program since 2008 and will continue offering it as part of
JEA’s 2025 DSM Plan. The Program is available to low-income customers in
disadvantaged neighborhoods as designated by the U.S. Census Bureau. Through
the Residential NEE Program, JEA installs various energy (and water) efficiency
products at no cost to the participating customers, which helps to lower the
customers’ utility bills. JEA also provides tips on how customers may be able
to manage their electric and water usage.
COMMERCIAL/INDUSTRIAL PROGRAMS
Commercial/Industrial Prescriptive
Lighting Rebates Program
JEA has been offering its
Commercial/Industrial Prescriptive Lighting Rebates Program since 2009 and will
continue offering it as part of JEA’s 2025 DSM Plan. The Program consists of
incentives (rebates) for customers to install energy efficient lighting and
occupancy sensors.
JEA
Program Standards
RESIDENTIAL PROGRAMS
Residential Home Efficiency Upgrades
Rebates Program
JEA offers a direct incentive
(rebate) to customers that install a qualifying heat pump water heater. The
program is promoted to all customers in the JEA service territory via email and
other social media avenues. Additionally, store signage and paper applications
are made available in select home improvement stores and retailers. After
purchase, the customer provides supporting purchase and installation
information to acquire the incentive payment (rebate).
JEA has a pre-qualified
contractor (PQC) program that allows JEA customers to select a contractor to
perform the installation of the HVAC and/or ceiling insulation. After the
installation is complete, the PQC provides the customer with an invoice with a
line item showing the discounted amount (reflective of the rebates) from JEA.
The PQC then submits the application to JEA for reimbursement for the
discounted amount (rebate). All customer proposals and invoices must clearly
show the full price of the system, the JEA incentive (rebate), and the resulting
net price to the customer. The customer pays the net price of the system to the
PQC. JEA will only provide incentive payments for systems accepted by the
customer as complete, in accordance with what they purchased from the PQC, and
in compliance with the requirements of the incentive program.
Residential Energy Efficient Products
Rebates Program
For the mail-in rebate provided
with clothes washers and smart thermostats the customer provides supporting
purchase and installation information to acquire the incentive payment
(rebate). The program is promoted to all customers in the JEA service territory
via email and other social media avenues. Additionally, store signage and paper
applications are made available in select home improvement stores and retailers.
JEA offers an instant discount
taken at the register at select stores with which there is an agreement to
showcase the JEA discount and provide a $25 incentive off the purchase price of
qualifying room air conditioners.
Residential Neighborhood Energy
Efficiency (NEE) Program
The Residential NEE Program is
available to low-income customers in disadvantaged neighborhoods. JEA
identifies qualifying neighborhoods as having 50 percent or more of the
residents living at or below 150 percent of the Federal Poverty guidelines
within the U.S. Census Bureau Tract. Once a neighborhood has been identified,
all residents will receive postcards explaining the NEE program and when to
expect NEE crews in the neighborhood. All installed measures and behavioral
education under the Residential NEE Program are provided by JEA at no cost to
participating customers.
COMMERCIAL/INDUSTRIAL
PROGRAMS
Commercial/Industrial Prescriptive
Lighting Rebates Program
JEA offers rebates for lighting
equipment installed as part of a retrofit project. Lighting retrofit project
applicants must submit a lighting workbook and be pre-approved prior to
equipment purchase and installation. Lighting equipment that results in
verifiable installed wattage reduction is eligible for rebates, provided that
the following criteria are met:
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LED light fixtures and retrofit kits must be
qualified as Design Light Consortium (DLC) or Energy Star
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Type A tube LEDs that use existing ballast are
not eligible for rebates. Type B tube LEDs that use line voltage via lamp
holders should install new lamp holders as part of retrofit. Type C tube LEDs
that use a dedicated external driver shall submit technical specifications for
the power supply/driver being used
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Rebates are currently capped at 50% net customer
cost and $100,000 per customer per program year
The following exclusions apply to
the Commercial/Industrial Prescriptive Lighting
Rebates Program:
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Measures with energy savings due solely to
behavioral changes
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T12 fluorescent lighting
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Incandescent and screw-in compact fluorescent
lamps (CFLs)
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Screw-in LED lamps
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Standard metal halide, mercury vapor, or any
high-pressure sodium lighting
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De-lamping without upgrading to qualifying
lighting equipment
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Pin based LED replacing compact fluorescent
using fluorescent ballasts
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Exit sign replacement
JEA offers rebates for the
installation of occupancy sensors, subject to meeting the following criteria:
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Retrofit installations, where not required by
ASHRAE 90.1-2004, are eligible
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Sensors must be new and installed in a manner
that meets or exceeds code regulations
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Sensors or control must be hard-wired and
permanently installed (no plug-based sensors)
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Installations must comply with manufacturer’s
guidelines on coverage and maximum controlled watts
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Sensors can be passive infrared, ultrasonic, or
dual technology
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Wall or fixture mounted sensors must control a
minimum of 200 watts
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Ceiling mounted sensors must control a minimum
of 400 watts
Occupancy sensors or
installations with the ability to disable sensor functions (other than for
maintenance) are not eligible for rebates under this Program.