Recommendation

Issue 1:

Should EDF’s Request for Oral Argument be granted?

Recommendation:

No. Staff believes that the information in the Motion for Reconsideration is sufficient for the Commission to make an informed decision, and that the movant has not demonstrated with particularity a reason why oral argument would assist the Commission in understanding and evaluating the issues to be decided. However, if the Commission chooses to grant the Request for Oral Argument, then staff believes 5 minutes per side would be sufficient. (Marquez, Stiller)

Staff Analysis:

Legal Standard

Rule 25-22.0022(1), F.A.C., allows a party to request oral argument before the Commission on a motion for reconsideration. This request must be filed concurrently with the motion and must state with particularity why oral argument would aid the Commission in understanding and evaluating the issues to be decided. Granting or denying oral argument is within the Commission’s sole discretion pursuant to Rule 25-22.0022(3), F.A.C.

Positions of the Parties

EDF asserts that oral argument would aid the Commission in fully understanding the “nuances” of EDF’s positions regarding the Commission’s jurisdiction, as set forth in the Motion for Reconsideration.

FPL counters that the mere claim by EDF that its jurisdictional arguments are “inherently nuanced” is not a showing with particularity why oral argument would aid the Commission, but rather is a conclusion. FPL argues that if a party could satisfy Rule 25-22.0022(1), F.A.C., by simply labeling its position as “nuanced,” then the rule’s particularity requirement would have no practical meaning. Furthermore, FPL asserts that EDF’s failure to plead with particularity why oral argument would aid the Commissioners cannot be cured through the oral argument itself because the explanation must have been in the initial request. Thus, FPL concludes, EDF has not met its legal burden to affirmatively demonstrate why oral argument is warranted.

Analysis

The information in the Motion for Reconsideration is sufficient for the Commission to make an informed decision. EDF has not demonstrated with particularity a reason why oral argument would assist the Commission in understanding and evaluating the issues to be decided.

Conclusion

Staff recommends that the Request for Oral Argument be denied. However, if the Request for Oral Argument is granted, the Commission should allow no more than 5 minutes per side for oral argument.

Issue 2:

Should EDF’s Motion for Reconsideration be granted?

Recommendation:

No. EDF’s Motion for Reconsideration should be denied. (Marquez, Stiller)

Staff Analysis:

Legal Standard

A motion for reconsideration under Rule 25-22.060(1)(a), F.A.C., may be filed by “[a]ny party to a proceeding who is adversely affected by an order of the Commission.”[3] A party need not file a motion for reconsideration in every instance prior to taking appeal. A motion should only be filed where the final order under review on its face demonstrates that the Commission has overlooked or failed to consider a point of fact or law. See Diamond Cab Co. v. King, 146 So. 2d 889 (Fla. 1962); Pingree v. Quaintance, 394 So. 2d 162 (Fla. 1st DCA 1981). A motion for reconsideration must be based upon facts in the record and susceptible to review. Stewart Bonded Warehouse, Inc. v. Bevis, 294 So. 2d 315 (Fla. 1974). A motion for reconsideration is not a vehicle to reargue matters that have been considered. Sherwood v. State, 111 So. 2d 96 (Fla. 3d DCA 1959) (citing State ex. rel. Jaytex Realty Co. v. Green, 105 So. 2d 817 (Fla. 1st DCA 1958)).

The Motion for Reconsideration raises four main issues, each of which is addressed in turn below.

1. EDF’s Position Regarding the Grid Bill and FERC Order No. 1000

Positions of the Parties

EDF alleges the Commission inaccurately found that EDF argued Federal Energy Regulatory Commission (FERC) Order No. 1000 is within the Commission’s jurisdiction to consider “because of” the Commission’s jurisdiction under the Grid Bill. EDF asks the Commission to reconsider and either modify or delete language on pages 4 and 5 of the Final Order. Specifically, EDF takes issue with statements in the Final Order that EDF argued (1) that FERC Order No. 1000 is within the Commission’s jurisdiction “because of” the Commission’s jurisdiction over planning and the avoidance of uneconomic duplication of transmission facilities and (2) that Section 366.04(5), F.S., expands the Commission’s jurisdiction over the issues in this case to include FERC Order No. 1000.

EDF performed a word search of its post-hearing brief, prehearing statement, and witnesses’ testimonies and asserts that no reference to FERC Order No. 1000 appears in any paragraphs where EDF cited to Section 366.04(5), F.S., specifically or to the Grid Bill generally. EDF asserts that the 11 times it cited to those concepts in the post-hearing brief were generally to the fact that the Commission has express statutory jurisdiction over the planning, development, and maintenance of a coordinated grid and the avoidance of further uneconomic duplication of transmission facilities. Furthermore, EDF performed an additional word search of its post-hearing brief, prehearing statement, and witnesses’ testimonies and asserts that while 16 instances of the phrases “uneconomic duplication,” “duplication,” or “duplicative” appear in its post-hearing brief, no such references appear in any paragraph mentioning FERC Order No. 1000. Thus, EDF concludes that there is no evidence in the record to support the contested language in the Final Order. EDF maintains that its arguments with respect to Section 366.04(5), F.S., are standalone arguments grounded solely in those provisions of the Florida Statutes.

FPL responds that the purpose of reconsideration is to bring the Commission’s attention to a point of fact or law the Commission overlooked, but EDF’s argument does not identify an overlooked point of fact or law. Instead, according to FPL, EDF asks the Commission to revise or delete language because EDF believes the Final Order did not describe EDF’s position with sufficient precision or to EDF’s liking. Furthermore, FPL argues that reconsideration is not a vehicle to allow a disappointed party to revise the Commission’s written explanation so that it more closely tracks that party’s preferred framing of its position or argument. FPL asserts that a motion for reconsideration requires more than stylistic disagreement and the Commission was not required to adopt EDF’s preferred wording, accept EDF’s litigation characterizations, or recite EDF’s arguments in the manner EDF now prefers.

In addition, FPL argues that EDF’s attempt to prove error by conducting key word searches is not the reconsideration standard. FPL submits that the Commission was not required to parse EDF’s arguments through keyword searches or isolate individual paragraphs from the total litigation position EDF advanced. FPL states that EDF repeatedly invoked the Commission’s “planning” jurisdiction and the avoidance of uneconomic duplication as a basis to demand broader review of alternatives and regional planning issues. Thus, FPL concludes, whether EDF placed the words “FERC Order No. 1000” in the same paragraph as Section 366.04(5), F.S., is immaterial.

FPL goes on to state that even were one to assume arguendo that EDF’s Motion for Reconsideration satisfied the reconsideration standard (which FPL maintains it does not), EDF’s arguments fail on the merits. Finally, FPL argues that none of EDF’s requested revisions would materially change the Final Order’s findings, conclusions, or ultimate determination that the AOP is needed to resolve mandatory reliability violations and ensure continued safe, reliable, and low-cost electric service in Miami-Dade County.

Analysis

The purpose of reconsideration is to bring to the Commission’s attention a point of fact or law that the Commission overlooked or failed to consider. However, EDF’s argument does not identify an overlooked point of fact or law.

Staff does not believe the Commission inaccurately characterized EDF’s jurisdictional arguments in the Final Order. With respect to FERC Order No. 1000, EDF’s post-hearing brief position expressed that “[c]onsideration of the requirements of the FERC’s transmission planning rules is clearly within the overall jurisdiction of the Commission.” (EDF BR 70) EDF also points to its Prehearing Statement, but even there it similarly expressed, regarding FERC Order No. 1000, that “[t]he requirements of the [FERC’s] transmission planning rules are clearly within the overall jurisdiction of the Commission.”[4] A dictionary definition of the word “overall” shows it to mean “including everything” or “viewed as a whole.”[5] In this case, EDF’s arguments regarding the scope of the Commission’s jurisdiction revolved around Sections 403.537, 366.04, and 366.01, F.S., as well as the statutory language contained therein. (EDF BR 2, 8–10, 14–16) Thus, the Commission appropriately took those assertions into account when analyzing the question of whether a FERC order was or was not within the Commission’s jurisdiction.

During the Prehearing Conference, EDF argued that the issues related to FERC Order Nos. 1000, 1920, 1920-A, and 1920-B were appropriate for inclusion because, “[a]s set forth in multiple places in what we filed with the Commission, we believe these considerations . . . . deal with appropriate planning for transmission, and that’s clearly within the Commission’s jurisdiction to consider.” (PH TR 14) One such referenced filing could be EDF’s Response in Opposition to FPL’s Motion in Limine and to Strike.[6] There, EDF asserted that the proposed evidence regarding, and including, FERC Order No. 1000 were “well within the jurisdictional purview of the Commission under the [Transmission Line Siting Act] and the Florida Grid Bill.”[7] Although the specific term “FERC Order No. 1000” does not appear in that particular paragraph, it does appear in the two preceding paragraphs under a discussion heading using that very term. Staff agrees with FPL that the Commission was not required to isolate individual paragraphs from EDF’s total litigation position.

The Final Order appropriately addressed the substance of EDF’s positions and arguments.[8] Given EDF’s repeated invocation of the Commission’s transmission planning jurisdiction and the avoidance of uneconomic duplication, staff believes the Commission reasonably concluded these concepts and the statutes discussed above were a part of the jurisdictional argument EDF advanced. Staff believes that EDF’s preference for the Final Order to use EDF’s chosen wording does not identify an overlooked point of fact or law. Therefore, staff recommends that reconsideration on this point should be denied.

Conclusion

Because EDF failed to identify a point of fact or law overlooked by the Commission in rendering the Final Order, staff recommends that reconsideration on this point should be denied.

2. EDF’s Position Regarding FPL’s Consideration of Alternatives

Positions of the Parties

EDF argues the Commission inaccurately characterized its position on whether technological alternatives could meet FPL’s customers’ needs more cost-effectively than the AOP. Specifically, EDF states that it did not argue that there are unspecified, “possible” technological alternatives that might meet the needs of FPL’s customers. Rather, EDF states it argued that FPL did not adequately evaluate specific, known technological options that could have either met the need more cost-effectively or reduced the need for additional transmission facilities, thereby benefiting FPL’s customers with a more cost-effective solution. EDF avers that the current language of the Final Order implies EDF’s proposed alternatives were more open-ended and thus mischaracterizes EDF’s position. Therefore, EDF asks the Commission to reconsider and revise language on page 5 of the Final Order to reflect EDF’s actual position: “FPL imprudently failed to consider specifically identified, available, known, and recognized technological alternatives to the high-voltage transmission facilities proposed by FPL.”

EDF reiterates that it proposed extending the schedule of this proceeding and offered to provide additional evidence regarding FPL’s needs and alternatives to meet those needs, but those requests were denied by procedural orders of the Commission.

FPL responds that EDFs argument constitutes re-argument dressed as a semantic objection and should be rejected. FPL argues that EDF has not identified an overlooked fact or law, but rather identifies language it dislikes which is not enough to warrant reconsideration. FPL asserts that the Commission was neither required to accept EDF’s characterization that its listed technologies were concrete, fully developed, technically viable alternatives, nor describe EDF’s position using EDF’s preferred adjectives. FPL argues the Commission was entitled to evaluate the record and conclude that EDF’s position, if accepted, would convert every transmission need determination into an open-ended inquiry into other possible technologies that might theoretically reduce or defer the need for a proposed project.

FPL adds that while EDF listed technologies, EDF did not present evidence that any of them were a technically supported, cost-effective alternative that would fully resolve the identified reliability violations by the required timeframe. FPL argues that such a list of technologies is not a major alternative and nothing in Rule 25-22.076(4), F.A.C., requires a utility to perform speculative evaluations of every technology an intervenor identifies. Finally, FPL argues that EDF’s argument improperly asks the Commission to reweigh evidence it already considered and rejected when it found the AOP was needed.

Analysis

Staff does not believe the Commission inaccurately characterized EDF’s position on technological alternatives in the Final Order. EDF is concerned that the Final Order implies that the advanced technologies it raised were unspecified, open-ended, or hypothetical. However, staff believes these concerns are misplaced.

In its post-hearing brief, EDF pointed to a number of advanced technology options that it felt FPL had not meaningfully considered. (EDF BR 55–60) The Commission was aware of the existence of these advanced technologies but found that they “either did not fully address cost, need, or would not be available within the required timeframe.”[9]

For example, FPL witness Yanes testified that FPL considers advanced transmission technologies and grid-enhancing technologies as part of the design and engineering of major transmission projects. (TR 156–158) The evidence confirmed that FPL took these things into account as part of its analysis, including conductors which FPL views as falling within those technology groupings. (EXH 41, E87–E88; EXH 46, E174–E178) The record further demonstrated that advanced power flow controllers would not resolve the load need identified as part of FPL’s transmission assessment studies. (EXH 41, E87) Likewise, topology optimizations would not create new transmission capacity. (EXH 41, E87) Reconductoring facilities would not resolve the identified reliability need either because it would not sufficiently remedy the voltage and bulk power delivery limitations to the extent required. (EXH 41, E88) Finally, battery storage could potentially exacerbate the reliability problem by serving as an added load on FPL’s system in Miami-Dade County during its charging cycle. (EXH 37, E13).

Nowhere did the Commission describe the advanced technologies themselves as being non-existent, unknown, unspecified, or as stemming from the realms of fantasy or science-fiction. Rather, the Commission reviewed the competing evidence before it and was not persuaded that the use/application of those possible advanced technologies would resolve the reliability need in this particular case. (SCC TR 17–18)[10] EDF’s attempt to reframe its list of technologies as major alternatives that would resolve the reliability need for purposes of Rule 25-22.076(4), F.A.C., does not change the evidentiary record or the weight the Commission assigned to the testimony and evidence before it.

Conclusion

EDF raises a semantic issue with the Final Order’s choice of words. However, the Final Order appropriately addressed the substance of EDF’s positions and arguments. EDF also does not articulate how the requested wording changes would have altered the Commission’s analysis, findings, or conclusions. Although EDF identifies language it dislikes, EDF fails to identify any overlooked point of fact or law. Therefore, staff recommends that reconsideration on this point should be denied.

3. EDF’s Position Regarding Applicable State Planning Requirements

Positions of the Parties

EDF asks the Commission to reconsider statements on page 7 of the Final Order concerning EDF’s position on state planning requirements relative to FERC’s jurisdiction. Specifically, EDF takes issue with language that “EDF would have [the Commission] impose non-existent state planning requirements” in transmission line need proceedings and that “EDF would have [the Commission] overstep and preemptively decide the adequacy of regional transmission planning in FERC’s place.” EDF argues that these statements are inaccurate characterizations of EDF’s positions that have no evidentiary basis.

EDF states that, regarding state planning, EDF’s requests are grounded in the Commission’s express jurisdiction over the planning and development of the grid and mandate to avoid uneconomic duplication of transmission facilities as well as the Commission’s broader authority to ensure prudent utility management and decision-making. Thus, EDF states it was advocating for the application of existing state planning requirements as opposed to non-existent requirements.

Furthermore, EDF argues that nowhere did it ask the Commission to issue any order that would displace, supplant, or otherwise conflict with FERC’s jurisdiction. EDF further asks the Commission to reconsider that EDF would potentially have the Commission overstep its jurisdiction and preemptively decide the adequacy of regional planning in light of the state authority previously referenced. In addition, EDF indicates the Commission may have overlooked record evidence in FPL’s FERC Open Access Transmission Tariff (OATT) stating: “The Florida Public Service Commission . . . is an integral part of the planning process by providing input, guidance, and regulatory oversight under this process.” (EXH 138, F3-11579)

FPL counters that EDF’s argument is another request for the Commission to rephrase the Final Order and does not identify a controlling statute, rule, case, or record fact that the Commission overlooked. FPL argues that the Commission was neither required to describe EDF’s position in EDF’s preferred terms or to accept EDF’s attempt to recast its broad planning challenge as merely an ordinary request to apply state planning law. FPL further states that the Commission did not overlook Section 366.04(5), F.S., or Rule 25-22.076(4), F.A.C., because the Final Order discussed them. According to FPL, Section 366.04(5), F.S., does not create a specific state-law obligation to conduct the type of regional transmission planning analysis EDF advocated for.

FPL also asserts that its FERC-approved OATT cannot expand the Commission’s statutory jurisdiction beyond what the Florida Legislature has conferred. At most, FPL concludes, the OATT language recognizes that the Commission has an important role in Florida utility planning within the scope of its lawful authority.

Finally, FPL argues that despite EDF’s claim to the contrary, the testimony and evidence EDF presented demonstrates it was asking the Commission to decide the adequacy of regional planning in FERC’s place. For example, EDF’s witnesses criticized Florida Reliability Coordinating Council (FRCC) governance, attacked the efficacy of the FERC Order No. 1000 regional planning process, argued that FRCC’s process has produced no regional projects, invoked future FERC Order No. 1920 planning obligations, and urged the Commission to deny the AOP and require further regional planning and stakeholder processes. FPL concludes that EDF’s position would push the Commission toward precisely the kind of federal regional planning adjudication that belongs elsewhere.

Analysis

Staff does not believe the Commission inaccurately characterized EDF’s position on state planning requirements relative to FERC’s jurisdiction.[11] The Commission did not portray EDF’s argument as one pointing to non-existent statutes. The Commission discussed both Sections 403.537 and 366.04(5), F.S., within the Final Order, but then went on to discuss the implications of EDF’s argument if accepted. Namely the Commission’s view that Section 366.04(5), F.S., does not create a specific state-law obligation to conduct in this proceeding the type of regional transmission planning contemplated by the FERC orders.

EDF also argues that “[n]owhere has EDF asked the Commission to issue any order that would displace, supplant, or otherwise conflict with FERC’s jurisdiction.”[12] But the Commission was not required to accept EDF’s attempt to recast its regional planning challenge as an ordinary request to apply state planning law. The Commission noted that the testimonies of EDF witnesses Cranston and Thomas sought to call into question the efficacy of the FRCC as a regional planning entity.[13] (TR 52–53, 93, 96–98, 100) The Commission noted how it could not grant the relief requested by EDF’s witnesses as it related to forcing FPL to conduct FERC regional transmission planning analyses with full and timely opportunities for stakeholder involvement in that process.[14] Nor did the Commission feel it could adjudicate EDF’s allegation that FPL violated its OATT.[15] (EDF BR 29–30, 32) Furthermore, staff does not believe the Commission overlooked evidence in FERC’s OATT regarding the Commission’s role (recognized by FPL and FERC) in transmission planning. Staff agrees with FPL that the language therein stating the Commission is “an integral part of the planning process by providing input, guidance, and regulatory oversight” does not translate into expanding the Commission’s jurisdiction over FERC’s regional transmission planning process.

The substance of EDF’s arguments was addressed by the Commission in the Final Order. EDF fails to articulate how the requested wording changes would have altered the Commission’s analysis, findings, or conclusions. Staff believes that EDF’s preference for the Final Order to use EDF’s chosen wording does not identify an overlooked point of fact or law and thus reconsideration on this point should be denied.

Conclusion

Staff believes the Final Order appropriately addressed the substance of EDF’s positions and arguments. EDF also does not articulate how the requested wording changes would have altered the Commission’s analysis, findings, or conclusions. Although EDF identifies language it dislikes, it fails to identify a point of fact or law overlooked by the Commission. Therefore, staff recommends that reconsideration on this point should be denied.

4. EDF’s Position Regarding Facts Potentially Overlooked by the Commission

Positions of the Parties

EDF asks the Commission to reconsider the Final Order to the extent the Final Order did not specifically address three issues raised by EDF in its post-hearing brief: (1) FPL’s allocation of large loads, likely from data centers, to Miami-Dade County in its load projections that formed the basis for FPL’s projected capacity need upon which its decision to pursue the AOP was based; (2) the combined effect of this allocation of large loads with the use of a P80 load factor; and (3) the use of transmission line capacity ratings that are inconsistent with the operating standards for the contingency events assessed in the NERC TPL-001-5.1 reliability assessment. Because the Final Order did not address these issues, EDF states that the Commission may have overlooked relevant facts in reaching its decision and requests the Commission to reconsider its decision and modify the Final Order accordingly.

FPL responds that when the Commission made its affirmative determination of need, it had available to it EDF’s brief, FPL’s brief, party positions, an evidentiary record, a summary of issues from staff, and staff’s oral recommendation on the issues. The Commission issued a Final Order after considering the record before it, including EDF’s brief raising these specific factual issues. FPL argues that no rule requires a Commission final order to catalogue and reject every evidentiary contention in a party’s post-hearing brief. FPL argues that the Commission was required to make findings and explain its decision based on the statutory need criteria and the Commission did so.

First, FPL states that EDF’s large-load/data-center argument should fail on the merits because FPL presented competent evidence supporting the Miami-Dade County load forecast and reliability need. Meanwhile, EDF did not rebut that evidence with a competent alternative load forecast and thus EDF’s argument here is a critique, not evidence. Second, FPL states that EDF’s P80 argument should also fail because EDF neither offered a competent reliability analysis showing that a different load forecast assumption would eliminate the mandatory reliability violations, eliminate the need for all four lines, or materially change the Commission’s decision, nor did EDF show the AOP would be unnecessary under a different load forecast assumption. FPL alleges that EDF’s argument attempts to have the Commission reweigh the evidence based on conjecture, which is not an appropriate basis for reconsideration. Third, FPL states that EDF’s transmission line ratings argument also fails because EDF raised the argument already in its post-hearing brief so that it is not an overlooked fact. Furthermore, FPL adds EDF cannot convert an alleged federal tariff-compliance dispute into a basis for reconsideration of a state need determination.

FPL adds that while EDF cites to Citizens of State v. Clark, 373 So. 3d 1128 (Fla. 2023), that case does not authorize parties to file reconsideration motions that merely repeat rejected factual arguments.

Analysis

Staff does not believe that EDF has identified any facts the Commission overlooked in rendering the Final Order. “It is not necessary for the lower tribunal to address every claim or subclaim with particularity in its final order.” Scott v. State, 73 So. 3d 320, 320 (Fla. 1st DCA 2011). The Final Order confirmed that the Commission had the benefit of the parties’ post-hearing briefs when reaching its decision.[16] And the facts that EDF indicates the Commission potentially or may have overlooked were mentioned in EDF’s post-hearing brief. (EDF BR 40–44, 47–50) Thus the Commission was aware of EDF’s assertions and characterizations of the evidentiary record on these points.

All three facts raised by EDF are associated with the transmission modeling conducted by FPL. The Commission explicitly mentioned the P80 load forecast in the Final Order.[17] FPL’s large load projections were an input variable of the P80 load forecast. FPL utilized the 2025 Ten-Year Site Plan forecast (which incorporated 732 MW of large load), adjusted from the P50 used in the Ten-Year Site Plan to the P80, and then ultimately allocated the system values on a substation level for the transmission modeling. (EXH 48, E248; EXH 39, E46; EXH 39, E55–E57) The discussion of the P80 forecast within the Final Order is inclusive of these forecasts as a whole and was a conservative approach.[18] Therefore, staff believes FPL’s large load allocation and the P80 load forecast were not overlooked by the Commission.

Finally, staff believes the emergency transmission line ratings were not specifically discussed in the Final Order because they had no impact on the Commission’s reliability and integrity findings. The requirement that EDF refers to regarding FPL’s OATT transmission line ratings had a July 2025 implementation date, whereas the transmission modeling conducted for the 2025 transmission system assessments were completed between March and May 2025. (EXH 138, F3-12081; EXH 37, E2) Furthermore, as noted in FERC Order No. 881, the emergency ratings are safe for only a limited period of time, whereas the normal ratings are continuous and not time-limited. (EXH 83, F3-5404–F3-5405) In addition, staff believes EDF’s reliance on FERC Order No. 881 for transmission planning is misplaced because FERC found that transmission planning and development were outside the scope of the transmission line rating requirements being addressed in that proceeding. (EXH 83, F3-5465)

The Commission ultimately weighed the evidence before it differently than EDF wishes had been done. However, this does not mean that the Commission overlooked any facts. No rule requires a Commission final order to catalogue and reject every single evidentiary contention raised in a party’s post-hearing brief.

Conclusion

Because EDF failed to identify a point of fact overlooked by the Commission in rendering the Final Order, staff recommends that reconsideration on this point should be denied.

Issue 3:

Should this docket be closed?

Recommendation:

No. Staff recommends that this docket should remain open while the appeal filed by EDF is processed by the Florida Supreme Court. (Marquez, Stiller)

Staff Analysis:

On June 29, 2026, EDF filed a notice of appeal of the Commission’s Final Order. This docket should remain open while the appeal is processed by the Florida Supreme Court.

[1] The parties to this proceeding are FPL, the Office of Public Counsel, and the Environmental Defense Fund, Inc.

[2] Order No. PSC-2026-0179-FOF-EI, issued June 1, 2026, in Docket No. 20260020-EI, In re: Petition for determination of need for Andytown-Oasis transmission lines project in Broward and Miami-Dade Counties, by Florida Power & Light Company.

[3] For transmission line need determinations, Rule 25-22.075(1), F.A.C., requires that motions for reconsideration be filed within five days of the Commission’s decision. Other than this shorter filing timeframe superseding the general timeframe, Rule 25-22.060(1)(a), F.A.C., applies.

[4] Document No. 01910-2026, filed on March 31, 2026, p. 9.

[5] Overall, Merriam Webster, https://www.merriam-webster.com/dictionary/overall#dictionary-entry-3 (last visited July 21, 2026).

[6] Document No. 02071-2026, filed on April 7, 2026.

[8] Indeed, EDF’s requested relief includes the option of merely deleting the identified language. This implies that even in the absence of such language, the Commission nonetheless adequately addressed EDF’s underlying arguments.

[9] Order No. PSC-2026-0179-FOF-EI, issued June 1, 2026, in Docket No. 20260020-EI, p. 9.

[10] Document No. 03190-2026, filed May 29, 2026.

[11] EDF’s challenged language can be found under the jurisdictional subheading in the Final Order related to FERC Order Nos. 1920, 1920-A, and 1920-B. Order No. PSC-2026-0179-FOF-EI, p. 6–7.

[12] Document No. 03383-2026, filed on June 8, 2026, p. 13 (emphasis removed).

State of Florida		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-
DATE:	August 27, 2026
TO:	Office of Commission Clerk (Teitzman)
FROM:	Office of the General Counsel (Marquez, Stiller) SS Division of Engineering (Davis, Willis, Ellis, Ramos, King) LK
RE:	Docket No. 20260020-EI – Petition for determination of need for Andytown-Oasis transmission lines project in Broward and Miami-Dade Counties, by Florida Power & Light Company.
AGENDA:	09/10/26 – Regular Agenda – Motion for Reconsideration – Oral Argument Requested – Participation is at the Discretion of the Commission
COMMISSIONERS ASSIGNED:			Clark, Payne, Ortega
PREHEARING OFFICER:			Payne
CRITICAL DATES:			None
SPECIAL INSTRUCTIONS:			None