A Poem for the Florida Commission: Deny the Utilities’ Meager Goals

Guest Blog | October 6, 2014 | Energy Efficiency, Energy Policy, Solar, Utilities

In Florida, land of the sun

The utilities pulled a fast one.

No efficiency tools

Without swimming pools

Low Income? You’ll end up with none.


With the RIM test used as a shield

The utilities make a high yield

Cross-subsidy hollers

hide utility dollars

But their motives can’t be concealed.

For solar, they set the bar low

All pilots, they say must now go

They don’t see a flaw

In ignoring the law

The Commission should flatly say no

Poem by Alisa Coe

What’s better than a Monday morning poem? Last Tuesday, SACE filed its post-hearing brief in the Florida Energy Efficiency Conservation proceeding. As our Florida team has written in the past (here, and  here), the Florida utilities are advocating for weak goals that only benefit their bottom line. The poem lays out a few arguments in our brief, and without getting too wonky, here is the summary.

The Florida utilities are only proposing energy efficiency measures that creates neutral or positive financial impact on them, not all cost-effective energy efficiency reasonably achievable as required by statute, or efficiency that benefits all customer classes, such as low-income. One energy efficiency measure that is included in most of the utility portfolios are pool pumps – a measure that is only applicable to customers with pools.

All Florida utilities advocate for the use of the Ratepayer Impact Measure (RIM) test. This is a cost-benefit calculation, one of several that can be used for energy efficiency. Only one state in the country, Virginia, relies on this test because all it provides is a evaluation if utility revenues go up or down. A power plant would not pass this cost-benefit test, yet utilities are more than willing to make that investment.  The effect of relying on RIM is that the utility limits the amount of energy efficiency that can invest in by defining cost-effective in a very, very narrow way.

Finally, Florida law requires that the utilities, in this proceeding, set goals to increase the development of demand-side renewable energy. The utilities all turned a blind eye to this and suggested that their solar programs be eliminated (here is a blog on FPL’s weak solar proposal as an alternative). I’m not a lawyer, but zero doesn’t result in an increase, regardless of how many years you spread it across.

The ball is now in the Florida Public Service Commission’s court. Will they support consumers by setting higher energy efficiency goals that will result in a LOWER COST ELECTRICITY SYSTEM, as admitted by the utilities themselves, or will they simply line the utilities’ pockets? Let’s hope that history is not an indicator of the future.

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