We can all agree that it makes sense to use energy smarter. Energy efficiency is the prime example: it’s the smartest way to meet our energy needs by cutting energy waste, saving money on power bills, creating local jobs, strengthening our economy, and protecting the air we breathe.
Yet, Floridians are missing out on many of these benefits due to badly outdated policies at the Florida Public Service Commission – the agency that sets energy-saving goals for the state’s largest power companies. Unfortunately, these outdated policies have landed Florida’s biggest utilities at the bottom of national rankings for helping Floridians save money on power bills. The culprits are outdated economic screens that depress energy efficiency potential. These economic screens allowed power companies to propose energy savings goals of zero in 2019. Zero is not a goal.
The Commission is currently revising its energy efficiency policies for setting efficiency goals, but there are troubling signs that it may not take the steps needed to finally modernize its economic screening practices. That would be tragic for customers. It would also be a missed opportunity for the Commission to provide certainty and predictability to the goal-setting process – which has historically been uncertain, volatile, and produced weak outcomes.
Time to hold Florida to a higher standard and lower bills for hard-working families
We at the Southern Alliance for Clean Energy (SACE) support modernizing the Commission’s policies now – in the current rulemaking process. And we are not alone, over 6,000 customer comments have been submitted directly to the Commission, as have comments from numerous organizations that represent:
- low-income customer advocates, including: the NAACP
- Small business owners
- Ten local governments, like the City of Coral Gables
- Local elected officials
- National efficiency policy experts
- Office of Public Counsel,
- and more.
After three decades, it’s time to modernize
It’s been three decades since the Commission’s efficiency rules have been updated, now is the time to modernize the archaic economic screening practices holding the state back from using energy smarter and limiting access to efficiency improvement programs that would lower bills for hard-working families. Yet, the Commission’s staff, and some stakeholders, don’t sense the urgency for immediate action.
For instance, the Commission staff’s draft rule – that kicked off the rulemaking process in December of last year – does not even address the outdated economic screens. Rather, it merely aims to streamline a process for setting efficiency goals and approving programs – that will invariably continue to produce weak outcomes. There is, of course, still time for the staff to incorporate the revisions proposed by a number of non-utility stakeholders into its draft rule. Inaction on these issues will only ensure continued uncertainty and volatility in the next goal-setting proceeding – which is expected to occur in the 2023/2024 timeframe.
Florida Power & Light’s (FPL) and Tampa Electric’s comments exhibit an unwillingness to seriously engage in the modernization conversation, although Tampa Electric did express a willingness to consider alternative cost-effectiveness tests.
Duke Energy Florida filed comments with some stakeholders that don’t propose any substantive changes to the Commission’s rule to address the outdated economic screens. We appreciate that Duke Energy is the first utility to comment in this docket in recognition of the many benefits of energy efficiency as a resource to the utility’s system and referencing the more expansive Utility Cost Test as the way to measure the benefits. Unfortunately, the comments kick the can years down the road to the next goal-setting cycle to an informal, uncertain, and historically unfriendly (Order Establishing Procedure) process. It must be noted that Duke Energy has had successful experience delivering meaningful energy savings in other states with rules – unlike Florida – that reflect standard industry practice. Let’s do the same here.
Florida can use energy smarter
We have the opportunity to make substantive changes to the rule now that will provide:
- Meaningful guidance to the state’s utilities for the next energy efficiency goal-setting cycle
- Clarity and certainty to the next goal-setting process
- Additional and helpful information to the commissioners on which to establish goals in the next goal-setting proceeding
We recommend the next step in the process be a commissioner-led workshop. The Commissioners themselves would greatly benefit from engaging in standard industry practices from around the country and exploring how they could be adopted for Florida.
We need bolder and faster action on using energy smarter in Florida. We filed comments on June 28, urging the Commission to take action to actually fix what is broken in the rules. Let’s not miss this opportunity to get the rule right – now is the time.