HomeMy Public PortalAboutFPL Docket No 20200071-EI Review of 2020-2029 Storm Protection Plan.pdfChristopher T. Wright
Senior Attorney - Regulatory
Florida Power & Light Company
700 Universe Blvd
Juno Beach, FL 33408-0420
Phone: (561) 691-7144
E-mail : Christoper.Wright@fpl.com
Florida Authorized House Counsel;
Admitted in Pennsylvania
April10,2020
VA ELECTRONIC FILING
Mr. Adam Teitzman
Division of the Commission Clerk and Administrative Services
Florida Public Service Commission
2540 Shumard Oak Blvd.
Tallahassee, FL 32399 -0850
Re: Docket No. 2020007L-EI
Review of 2020-2029 Storm Protection PIan pursuant to Rule 25-6.030, F.A.C.,
Florida Power & Lisht Comnanv
Dear Mr. Teitzman
Enclosed for electronic filing in the above-referenced docket, please find Florida Power & Light
Company's Petition for Approval of the 2020-2029 Storm Protection Plan pursuant to Rule 25-
6.030, F.A.C., together with the Direct Testimony of FPL witness Michael Jano and Exhibit MJ-
1. Copies of this filing will be provided as indicated on the enclosed Certificate of Service.
If you or your staff have any question regarding this filing, please contact me at (561) 691-7144.
Respectfully submitted,
s/Christopher Wrisht
Christopher T. Wright
Authorized House Counsel No. 1007055
Enclosure
FPL,
Florida Power & Light Company
700 Universe Boulevard, Juno Beach, FL 33408
Page | 1
BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
Review of 2020-2029 Storm Protection Plan pursuant
to Rule 25-6.030, F.A.C., Florida Power & Light
Company
Docket No. 2020007L-EI
Filed: April 10,2020
PETITION OF FLORIDA POWER & LIGHT COMPANY
F'OR APPROVAL OF THE 9 STORM PROTECTION PLAN
I. INTRODUCTION
Florida Power & Light Company ("FPL" or the "Company") hereby files this petition (the
"Petition") requesting that the Florida Public Service Commission ("Commission") approve the
proposed Transmission and Distribution ("T&D") Storm Protection Plan for the years 2020-2029
(hereinafter, the "SPP") pursuant to Section 366.96, Florida Statutes ("F.S.") and Rule 25-6.030,
Florida Administrative Code ("F.A.C."). FPL's SPP is, in large part,acontinuation and expansion
of its previously approved and successful storm hardening and storm preparedness programs. FPL
submits that the storm hardening and storm preparedness programs included in its SPP are
appropriate and necessary to achieve the legislative objectives of Section366.96, F.S., to protect
and strengthen T&D infrastructure from extreme weather conditions, reduce outage times and
restoration costs, and improve overall service reliability to customers.l In support of this Petition,
FPL states as follows:
1. The name and address of the Petitioner is:
Florida Power & Light Company
700 Universe Blvd
Juno Beach, FL 33408
1 The recovery of costs associated with the SPP, as well as the actual and projected costs to be included in
FPL's Storm Protection Plan Cost Recovery Clause, will be addressed in subsequent and separate Storm
Protection Plan Cost Recovery Clause dockets pursuant to Rule 25-6.031, F.A.C. The Commission has
opened Docket No. 20200092-El to address Storm Protection Plan Cost Recovery Clause petitions to be
filed the third quarter of 2020.
1
2. FPL is a corporation organized and existing under the laws of the State of Florida
and is an electric utility as defined in Sections 366.02(2) and366.96,F.S. FPLprovides generation,
transmission, and distribution service to nearly five million retail customer accounts.
3. Any pleading, motion, notice, order or other document required to be served upon
the petitioner or filed by any party to this proceeding should be served upon all of the following
individuals:
John T. Burnett
Vice President and Deputy General Counsel
Christopher T. Wright
Senior Attorney
Florida Power & Light Company
700 Universe Boulevard
Juno Beach, FL 33408-0420
Phone: 561-691-7144
Fax:561-691-7135
Email: i ohn.t. burnett@fol. com
Email : christopher.wri ght@fpl.com
4. The Commission has jurisdiction pursuant to Section 366.96, F.S., and Rule 25-
6.030, F.A.C.
5. This Petition is being filed consistent with Rule 28-106.201, F.A.C. The agency
affected is the Commission, located at25 |Shumard Oak Boulevard, Tallahassee, Florid a32399.
This case does not involve reversal or modification of an agency decision or an agency's proposed
action. Therefore,subparagraph(c)andportionsofsubparagraphs(b),(e),(0and(g)ofsubsection
(2) of Rule 28-106.201, F.A.C., are not applicable to this Petition. ln compliance with
subparagraph (d) of Rule28-106.201, F.A.C., FPL states that it is not known which, if any, of the
issues of material fact set forth in the body of this Petition may be disputed by any others who may
plan to participate in this proceeding. The discussion below demonstrates how the petitioner's
substantial interests will be affected by the agency determination.
2
Kenneth A. Hoffinan
Vice President, Regulatory Affairs
Florida Power & Light Company
215 South Monroe Street, Suite 810
Tallahassee,FL 3230I
Phone: 850-521-3919
Fax: 850-521-3939
Email : ken.hoffman@,fpl.com
il. BACKGROUND OVERVIEW
6. On June 27,2019, the Governor of Florida signed CS/CS/CS/SB 796 addressing
Storm Protection Plan Cost Recovery, which was codified in Section 366.96, F.S. Therein, the
Florida Legislature found that it was in the State's interest to "strengthen electric utility
infrastructure to withstand extreme weather conditions by promoting the overhead hardening of
electrical distribution and transmission facilities, the undergrounding of certain electrical
distribution lines, and vegetation management," and for each electric utility to "mitigate restoration
costs and outage times to utility customers when developing transmission and distribution storm
protection plans." Section 366.96(I), F.S. The Florida Legislature directed the Commission to
adopt rules to specify the elements that must be included in each utility's SPP. Sectio n 366.96(l),
F.S.
7. Rule 25-6.030, F.A.C., requires each utility to file an updated SPP at least every
three years that covers the utility's immediate ten-year planning period. Rule 25-6.030, F.A.C.,
also specifies the information to be included in each utility's SPP. Consistent with these
requirements, FPL is herein submitting its SPP for the ten-year period of 2020-2029, which is
provided as Exhibit MJ-1.
8. FPL's SPP is largely a continuation and expansion of its existing storm hardening
and storm preparedness programs, which were most recently approved in FPL's 2019-2021Storm
Hardening Plan.2 These existing hardening and storm preparedness programs have already
demonstrated that they have and will continue to increase T&D infrastructure resiliency, reduce
restoration times, and reduce restoration costs when FPL's system is impacted by extreme weather
2 See In re: Petitionfor Approval of Florida Power & Light Company's 2019-2021 Storm Hardening Plan
pursuant to Rule 25-6.0342, F.A.C.,DocketNo.20180144-EI, OrderNo. PSC-2019-0364-CO-EI(F1a. PSC
Aug.27,2019) (making Order No. PSC-2019-0301-PAA-Ei issued on July 29,2019, effective and final).
aJ
events. FPL performed an analysis of Hurricanes Matthew and Irma that indicated the restoration
construction man-hours ("CMH"), days to restore, and storm restoration costs for these storms
would have been significantly higher without FPL's storm hardening programs.3
9. While FPL's nation-leading initiatives have made significant progress toward
strengthening FPL's infrastructure, FPL must continue its T&D storm hardening and storm
preparedness plans and initiatives. Storms remain a constant threat and Florida is the most
hurricane-prone state in the nation. With the significant coast-line exposure of FPL's system, and
the fact that the majority of FPL's customers live within twenty miles of the coast, a robust storm
protection plan is critical to maintaining and improving grid resiliency and storm restoration as
contemplated by the Legislature in Section 366.96.
10. As part of its SPP, FPL will continue the previously approved storm hardening and
storm preparedness programs to achieve the legislative objectives of promoting the overhead
hardening of T&D facilities, the undergrounding of distribution lines, and vegetation management
to reduce restoration costs and outage times to customers and improve the overall service reliability
for customers. In addition, FPL proposes to implement a new substation storm surge/flood
mitigation program. FPL submits that the SPP will continue and expand the benefits of hardening,
including improved day-to-day reliability, to all customers throughout FPL's system.
1 1. Submitted herewith and in support of FPL's SPP is the Direct Testimony of Michael
Jarro and Exhibit MJ-I, which includes FPL's SPP for the period of 2020-2029 and supporting
schedules.
3 ,See FPL's Third Supplemental Response to StafPs First Data Request No. 29 ("Third Supplemental
Amended") in Docket No. 20 17021 5-EI, which is provided as Appendix A to Exhibit MJ- 1 .
4
III. STORM PROTECTION PLAN
A. Description of the SPP Programs
12. FPL's SPP is largely a continuation and expansion of the following previously
approved storm hardening and storm preparedness programs:
Pole Inspections - Distribution Program
. Structures/Other Equipment Inspections - Transmission Program
Feeder Hardening (EWL) - Distribution Program
Lateral Hardening (Undergrounding) - Distribution Program
Wood Structures Hardening (Replacing) - Transmission Program
Vegetation Management - Distribution Program
Vegetation Management - Transmission Program
In addition, FPL proposes to implement a new Substation Storm Surge/Flood Mitigation -Program
to protect T&D substations and equipment that are susceptible to storm surge or flooding during
extreme weather events. These SPP programs are summarized below and a detailed description
of each SPP program, consistent with Rule 25-6.030(3Xd), F.A.C., is provided in Section IV of
Exhibit MJ-1.
13. The Pole Inspection - Distribution Program will continue FPL's existing
Commission-approved distribution pole inspection program, which is an eight-year pole
inspection cycle for all distribution poles that targets approximately 1/8 of the system annually
(the actual number of poles inspected can vary somewhat from year to year). With approximately
1.2 million distribution poles as of year-end 20i9, FPL expects to inspect approximately 150,000
poles annually. The estimated 2020-2029 annual average cost for the Pole lnspection -
Distribution Program is approximately $61 million per year, which is consistent with historical
5
costs for the existing distribution pole inspection program.a A detailed description of the Pole
Inspection - Distribution Program is provided in Section IV(A) of Exhibit MJ-1.
14. The Structures/Other Equipment Inspections - Transmission Program will continue
FPL's current Commission-approved transmission inspection program which requires: (a)
transmission circuits and substations and all associated hardware to be inspected on a six-year
cycle; (b) wood structures to be visually inspected from the ground on an annual basis and climbing
or bucket truck inspections to be conducted on a six-year cycle; and (c) steel and concrete
structures to be visually inspected on an annual basis and climbing or bucket truck inspections to
be conducted on a ten-year cycle. FPL expects to inspect approximately 68,000 transmission
structures annually. The estimated 2020-2029 annual average cost for the Structures/Other
Equipment Inspections - Transmission Program is approximately $50 million per year, which is
consistent with historical costs for the existing transmission inspection program.s A detailed
description of the Structures/Other Equipment Inspections - Transmission Program is provided in
Section IV(B) of Exhibit MJ-1.
15. The Feeder Hardening (EWL) - Distribution Program will continue FPL's existing
Commission-approved approach to harden existing feeders and certain critical distribution poles,
as well as FPL's initiative to design and construct new pole lines and major planned work to meet
the extreme wind loading ("EWL") criteria set forth in the National Electric Safety Code. FPL
a Note, the2020-2029 program costs shown above are projected costs estimated as of the time of this filing.
Subsequent projected and actual costs could vary by as much as 10%oto l|Yo. The annual projected costs,
actual/estimated costs, actuals costs, and true-up of actual costs to be included in FPL's Storm Protection
Plan Cost Recovery Clause will all be addressed in subsequent and separate Storm Protection Plan Cost
Recovery Clause filings pursuant to Rule 25-6.031, F.A.C. The Commission has opened Docket No.
20200092-EI to address Storm Protection Plan Cost Recovery Clause petitions to be filed the third quarter
of2020.
5 See footnote 4.
6
expects to harden approximately 280-350 feeders annually, with 100% of FPL's feeders expected
to be hardened or underground by year-end 2024 and with the final costs of the program to be
incurred in 2025. The estimated average annual cost for the Feeder Hardening (EWL) -
Distribution Program to be incuned over the period of 2020-2025 is approximately $534 million
per year, which is consistent with historical costs for the existing distribution feeder hardening
program.6 A detailed description of the Feeder Hardening (EWL) - Distribution Program is
provided in Section IV(C) of Exhibit MJ-1.
16. The Lateral Hardening (Undergrounding) - Distribution Program includes
completing FPL's existing three-year Storm Secure Underground Program Pilot ("SSUP Pilot") in
2020 andexpanding the application of the SSUP to the implementation of the system-wide Lateral
Hardening (Undergrounding) - Distribution Program forthe period of 2021-2029. The SSUP Pilot
is a program that targets certain overhead laterals that were impacted by recent storms and have a
history ofvegetation-related outages and other reliability issues for conversion from overhead to
underground. As part of its SPP, FPL will incorporate, continue, and expand the SSUP during the
ten-year SPP period to provide the benefits of underground lateral hardening throughout its system.
After completing the SSUP Pilot in 2020,FPL estimates that it will convert approximately 300-
700 laterals annually in202l-2023 and approximately 800-900 laterals annually in2024-2029.
The estimated 2020-2029 annual average cost for the Lateral Hardening (Undergrounding) -
Distribution Program is approximately $510 million per year.7 A detailed description of the
Lateral Hardening (Undergrounding) - Distribution Program is provided in Section IV(D) of
Exhibit MJ-1.
6,See footnote 4.
7 See footnote 4.
7
17. The Wood Structures Hardening (Replacing) - Transmission Program is a
continuation of FPL's existing transmission hardening program to replace all wood transmission
structures with steel or concrete structures. As of year-end 2019, 96yo of FPL's transmission
structures, system-wide, were steel or concrete, with less than 2,900 (or 4%) wood structures
remaining to be replaced. FPL expects to replace the 2,900 wood transmission structures
remaining on its system by year-end2022. The estimated2020-2022 annual average cost for the
Wood Structure Hardening (Replacing) - Transmission Program is approximately $39 million per
year, which is a decrease from the historical costs for the existing transmission hardening
program.8 A detailed description of the Wood Structure Hardening (Replacing) - Transmission
Program is provided in Section IV(E) of Exhibit MJ-1.
18. The Substation Storm Surge/Flood Mitigation Program is the only new storm
hardening program that FPL proposes to implement as part of its SPP. The Substation Storm
Surge/Flood Mitigation Program will implement measures to protect certain T&D substations and
equipment that are susceptible to storm surge or flooding due to extreme weather events.
Specifically, FPL will raise the equipment at certain substations above the flood level and construct
flood protection walls around other substations that are susceptible to storm surge or flooding
during extreme weather events. The Storm Surge/Flood Mitigation - Transmission and
Distribution Program will reduce customer outages due to flooding and the need to de-energize
substations that are impacted by storm surge or flooding, as well as reduce flood damage and
restoration costs at these targeted substations. At this time, FPL has identified between 8-10
substations where it initially plans to implement storm surge/flood mitigation measures over the
8
8,See footnote 4
next three years (2020-2022). The estimated 2020-2022 annual average cost for the new
Substation Storm Surge/Flood Mitigation Program is approximately $8 million per year.e A
detailed description of the Substation Storm Surge/Flood Mitigation Program is provided in
Section IV(F) of Exhibit MJ-1.
19. The Vegetation Management - Distribution Program is a continuation of FPL's
existing, Commission-approved distribution vegetation management program. FPL's currently
approved distribution vegetation program, includes the following system-wide vegetation
inspection and management activities: three-year cycle for feeders; mid-year cycle targeted
trimming for certain feeders; six-year cycle for laterals; and continued education of customers
through its Right Tree, Right Place initiative. FPL plans to inspect and maintain, on average,
approximately 15,200 miles annually, which is consistent with the historic miles inspected and
trimmed annually. The estimat ed2020-2029 averuge annual cost for the Vegetation Management
- Distribution Program is approximately $60 million per year, which is consistent with historical
costs for the existing distribution vegetation management program.l0 A detailed description of the
Vegetation Management - Distribution Program is provided in Section IV(G)of Exhibit MJ-1.
20. The Vegetation Management - Transmission Program is a continuation of FPL's
existing transmission vegetation management program, which includes visual and aerial
inspections of all transmission line conidors, LiDAR inspections of North American Electric
Reliability Corporation transmission line corridors, developing and executing annual work plans
to address identified vegetation conditions, and identifying and addressing priority and hazard tree
conditions prior to and during storm season. FPL plans to inspect and trim, on average,
e See footnote 4.
lo See footnote 4.
9
approximately 7,000 miles of transmission lines annually, which is consistent with the historic
miles inspected and trimmed annually. The estimated 2020-2029 average annual cost for the
Vegetation Management - Transmission Program is approximately $10 million per year, which is
consistent with historical costs for the existing transmission vegetation management program.l l A
detailed description of the Vegetation Management- Transmission Program is provided in Section
IV(H) of Exhibit MJ-l.
B. Additional Details for First Three Years of the SPP
21. The following additional project level information required by Rule 25-
6.030(3)(e)(1), F.A.C., for the first year of the SPP (2020) is provided in Appendix E to Exhibit
MJ-l: (a) the actual or estimated construction start and completion dates; (b) a description of the
affected existing facilities, including number and type(s) of customers served, historic service
reliability performance during extreme weather conditions, and how this data was used to prioritize
the storm protection project; and (c) a cost estimate including capital and operating expenses. A
description of the criteria used to select and prioritize storm protection projects is included in the
description of each SPP program provided in Section IV of Exhibit MJ-1.
22. Pursuant to Rule 25-6.030(3)(e)(2), F.A.C., FPL has also provided the estimated
number and costs of projects under each specific program for the second and third yearc (2021-
2022) of the SPP. This information is provided in Appendix C to Exhibit MJ-l.
23. The following additional information required by Rule 25-6.030(3)(f), F.A.C., for
the first three years (2020-2022) of the vegetation management activities under the SPP is provided
in Sections IV(G) and IV(H) of Exhibit MJ-1 and Appendix C to Exhibit MJ-1: (a) the projected
frequency (trim cycle); (b) the projected miles of affected transmission and distribution overhead
11 ,See footnote 4.
10
facilities; and (c) the estimated annual labor and equipment costs for both utility and contractor
personnel. Descriptions of how the vegetation management activities will reduce outage times
and restoration costs due to extreme weather conditions are provided in Sections IV(G) and IV(H)
of Exhibit MJ-1.
C. Estimated Revenue Requirements and Rate Impacts
24. Pursuant to Rule 25-6.030(3)(9), F.A.C., the estimated annual jurisdictional
revenue requirements of FPL's SPP for the ten-year period of 2020-2029 are provided in Section
VI of Exhibit MJ-l. While FPL has provided estimated costs by program as of the time of this
filing and associated total revenue requirements in its SPP, consistent with the requirements of
Rule 25-6.030, F.A.C., subsequent projected and actual program costs submitted for cost recovery
through the Storm Protection Plan Cost Recovery Clause (per Rule 25-6.031, F.A.C.,) could vary
by as much as l0-I5o/o, which variations would also impact the associated estimated revenue
requirements and rate impacts.
25. FPL anticipates the programs included in the SPP will have zero bill impacts on
customer bills during the first year of the SPP and only minimal bill increases for years two and
three of the SPP. An estimate of hypothetical overall rate impacts for the first three years of the
SPP (2020-2022) based on the total program costs reflected in this filing, without regard for the
fact that FPL remains under a general base rate freeze pursuant to a Commission-approved
settlement agreement through December 31,202I, are provided in Section VII of Exhibit MJ-1.
The annual jurisdictional revenue requirements and the estimated rate impacts are based on the
total estimated costs, as of the time of this filing, for all programs included in the SPP regardless
of whether those costs will be recovered in FPL's Storm Protection Plan Cost Recovery Clause or
through base rates. In addition, under FPL's Commission-approved rate case settlement
11
agreement, any incremental base rate adjustment may not take place until FPL's base rates are
established by the Commission in FPL's next base rate proceeding."
26. FPL is not seeking Commission approval, through this petition, to recover any of
the estimated costs associated with the SPP in this filing. The projected costs, actuallestimated
costs, actual costs, and true-up of actual costs to be included in FPL's Storm Protection Plan Cost
Recovery Clause, including whether these costs are included in current base rates, will all be
addressed in subsequent and separate Storm Protection Plan Cost Recovery Clause filings pursuant
to Rule 25-6.03I, F.A.C. The Commission has opened DocketNo. 20200092-EI to address Storm
Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
D. FPL's SPP is in the Public Interest and Should Be Approved
27. Sections 366.96(4)-(5), F.S., provide that the Commission shall review each
utility's SPP and, within 180 days from filing, determine whether the SPP is in the public interest.l3
28. As explained above, the programs included in the SPP are largely a continuation
and expansion ofFPL's already successful and ongoing storm hardening and storm preparedness
programs previously approved by the Commission, as well as a new storm hardening program to
tz See In re: Petitionfor rate inuease by Florida Power & Light Company, Docket No. 160021-EI, Order
No. PSC-16-0560-AS-EI (Fla. PSC Dec. 15, 2016).
13 In reaching this determination, the Florida Legislature has directed the Commission to consider the
following:
(a) The extent to which the plan is expected to reduce restoration costs and outage times associated with
extreme weather events and enhance reliability, including whether the plan prioritizes areas of lower
reliability performance.
(b) The extent to which storm protection of transmission and distribution infrastructure is feasible,
reasonable, or practical in certain areas of the utility's seruice territory, including, but not limited to,
flood zones and rural areas.
(c) The estimated costs and benefits to the utility and its customers of making the improvements
proposed in the plan.
(d) The estimated annual rate impact resulting from implementation of the plan during the first 3 years
addressed in the plan.
See Section 366.96(4), F.S.
12
protect T&D substations and equipment from storm surge and flooding due to extreme weather
events. These SPP programs will continue to provide increased T&D infrastructure resiliency,
reduced restoration times, and reduced restoration costs when FPL's system is impacted by
extreme weather events.
29. InDocketNo.20170215-EU,the Commissionreviewedthe electricutilities' storm
hardening and storm preparedness programs and found the following:
. Florida's aggressive storm hardening programs are working;
The length of outages was reduced markedly from the 2004-2005 storm
season;
Hardened overhead distribution facilities performed better than non-
hardened facilities;
Underground facilities performed much better compared to overhead
facilities; and
The primary causes ofpower outages came from outside the utilities' rights-
of-way including falling trees, displaced vegetation, and other debris.
See Review of Florida's Electric Utility Hurricane Preparedness and Restoration Actions 2018,
Docket No. 20170215-EU (Iuly 24,2018).14
30. The estimate of cumulative reductions in restoration costs and outage times
associated with the SPP will be directly affected by how frequently storms hit FPL's service
territory. Of course, no one is in a position to know for sure how frequently FPL's service territory
will be impacted by strong huricanes. However, consistent with historical results, FPL expects
that the storm hardening and storm preparedness programs included in its SPP will result in a
reduction in storm as well as non-storm (day-to-day) restoration costs. ,See FPL's Third
Supplemental Response to Staff s First Data Request No. 29 ("Third Supplemental Amended") in
ta Available ar http://www.psc.state.fl.us/library/filings/2018/04847-2018/04847-2018.pdf.
13
Docket No. 20170215-EI, which is provided as Appendix A to Exhibit MJ-1.
31. FPL's storm hardening and storm preparedness programs have also provided and
will continue to provide increased levels of day-to-day reliability. For example, FPL has
previously submitted reports to the Commission that show hardened feeders have performed
approximately 40%o better (i.e., fewer outages) on a day-to-day basis than non-hardened feeders.
32. A detailed summary of the benefits of FPL's SPP is provided in Section II of
Exhibit MJ-1, and the benefits and costs associated with each program is provided in Section IV
of Exhibit MJ-1.
33. FPL's SPP meets the objectives of Section366.96, F.S., satisfies the requirements
of Rule 25-6.030, F.A.C., is in the public interest, and should be approved.
IV. CONCLUSION
34. As explained above and in further detail in Exhibit MJ-l and the supporting Direct
Testimony of FPL witness Michael Jarro, FPL's SPP provides a systematic approach to achieve
the legislative objectives of reducing restoration costs and outage times associated with extreme
weather events and enhancing reliability. FPL's SPP appropriately and effectively maintains and
builds on FPL's commitment to provide safe and reliable electric service to customers, consistent
with our customers' needs and expectations .
14
WHEREFORE, FPL respectfully requests thatthe Commission find FPL's proposed SPP,
provided as Exhibit MJ-l, is in the public interest and approve the SPP for the years2020-2029.
Respectfully submitted this 1Oth day of April,2020,
John T. Bumett
Vice President and Deputy General Counsel
Christopher T. Wright
Senior Attorney
Florida Power & Light Company
700 Universe Boulevard
Juno Beach, FL 33408-0420
Phone: 561-691-7144
Fax: 561-691-7135
Email : j ohn.t.burnett@fpl.com
Email : christopher.wri ght@fpl.com
By:s/Christonher T. Wrisht
Christopher T. Wright
Fla. Auth. House Counsel No. 1007055
15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and corect copy of Florida Power & Light Company's
Petition for Approval of the 2020-2029 Storm Protection Plan in Docket No. 2020007L-EI, along
with the Direct Testimony of Michael Jamo and Exhibit MJ-l, has been furnished by Electronic
Mail to the following parties of record this 1Oth day of April,2020:
s/ Christopher T. Wrisht
Christopher T. Wright
Fla. Auth. House Counsel No. 1007055
Fla. Auth. House Counsel No. 1017875
Florida Power & Light Company
700 Universe Boulevard (JB/LAW)
Juno Beach, Florida 33408
Attorneyfor Florida Power & Light Company
Charles Murphy, Esquire
Rachael Dziechciarz, Esquire
Florida Public Service Commission
2540 Shumard Oak Boulevard
Tallahassee,FL 32399
rdziechc@psc. state.fl .us
cmurphy@psc.state.fl .us
Office of Public Counsel
J.R.Kelly
Patricia A. Christensen
c/o The Florida Legislature
111 West Madison Street, Room 812
Tallahassee, FL 32399 -l 400
kelly jr@le g.state.fl .us
christensen.patty@ le g. state.fl .us
BEF'ORE THE FLORIDA PUBLIC SERVICE COMMISSION
FLORIDA POWER & LIGHT COMPANY
2020.2029 STORM PROTECTION PLAN
DOCKET NO. 202000071-Er
DIRECT TESTIMONY OF
MICHAEL JARRO
APRrL 10,2020
1
TABLE OF CONTENTS
I. INTRODUCTION 3
II. ovERvIEW OF FPL'S SPP............ .....................4
IIL DESCRIPTION OF EACH SPPPROGRAM................ ....,.....7
IV. ADDITIONAL DETAILS F'OR F'IRST THREE YEARS OF THE SPP ....................16
v. CONCLUSrON........... ......................18
EXHIBIT MJ-l - FPL's 2020-2029 Storm Protection Plan
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A.
I. INTRODUCTION
Please state your name and business address.
My name is Michael Jarro. My business address is Florida Power & Lighl Company, 15430
Endeavor Drive, Jupiter, FL, 3347 8.
By whom are you employed and what is your position?
I am employed by Florida Power & Light Company ("FPL" or the "Company") as the Vice
President of Distribution Operations.
Please describe your duties and responsibilities in that position.
My current responsibilities include the operation and maintenance of FPL's approximately
68,000 miles of distribution infrastructure, including 42,000 miles of overhead and 26,000
miles of underground, that safely, reliably, and efficiently deliver electricity to more than five
million customers in FPL's service territory covering approximately 28,000 square miles. I am
responsible for the oversight of more than 1,600 employees in a control center and sixteen
management areas. The functions and operations within my area are quite diverse and include
distribution operations, major projects and construction services, power quality, meteorology,
and other operations that together help provide the highest level of service to FPL's customers.
Please describe your educational background and professional experience.
I graduated from the University of Miami with a Bachelor of Science Degree in Mechanical
Engineering and Florida International University with a Master of Business Administration. I
joined FPL in 199'7 and have held several leadership positions in distribution operations and
customer service, including serving as distribution reliability manager, manager of distribution
operations for south Miami-Dade area, control center general manager, director of network
operations, senior director of customer strategy and analytics, senior director of power delivery
central maintenance and construction, and vice-president of transmission and substations.
What is the purpose of your direct testimony?
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The purpose of my testimony is to present and provide an overview of FPL's proposed 2020-
2029 Storm Protection Plan ("SPP" or "the Plan"), which is attached to my direct testimony as
Exhibit MJ-1, and demonstrate that FPL's SPP is in compliance with Section 366.96, Florida
Statutes ("F.S.") and Rule 25-6.030, Florida Administrative Code ("F.A.C."). I will provide a
description of each storm protection program included in FPL's SPP and how it is expected to
reduce restoration costs and outage times. I will also describe the estimated start/completion
dates, estimated costs, and criteria used to select and prioritize the projects in each program.
Finally, I will describe the additional detail provided for the first three years of FPL's SPP
pursuant to Rule 25-6.030(3Xe)-(0, (h), and (i), F.A.C.
Are you sponsoring any exhibits in this case?
Yes. I am sponsoring Exhibit MJ-1 - FPL's Storm Protection Plan 2A20-2029.
U. OVERVIEW OF FPL'S SPP
What is the purpose of FPL's SPP?
On June 27,2019, the Governor of Florida signed into law the Storm Protection Plan Cost
Recovery legislation, which was codified in Section 366.96, F.S. As part of the new law, the
Florida Legislature expressly found that it is in the State's interest: (a) "to strengthen electric
utility infrastructure to withstand extreme weather conditions by promoting the overhead
hardening of electrical transmission and distribution facilities, the undergrounding of certain
electrical distribution lines, and vegetation management;" and (b) "for each electric utility to
mitigate restoration costs and outage times to utility customers when developing transmission
and distribution storm protection plans." ,See Sections 366.96(l)(c)-(d), F.S. Based on these
findings, the Florida Legislature directed each electric utility to file a SPP with the Florida
Public Service Commission ("Commission") covering the immediate ten (10) year planning
period. ,lee Section 366.96(3), F.S. Consistent with this legislative requirement, FPL is
submitting its SPP for the ten-year period of 2020-2029.
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FPL's SPP is a systematic approach to achieve the legislative objectives of reducing restoration
costs and outage times associated with extreme weather events and enhancing reliability. As
required by Rule 25-6.030, F.A.C., FPL's SPP includes, among other things, a description of
each proposed storm protection program, including: (a) how each program will enhance the
existing system to reduce restoration costs and outage times; (b) applicable start and completion
dates for each program; (c) a cost estimate for each program; (d) a comparison of the costs and
benefits for each program; and (e) a description ofhow each program is prioritized. The SPP
also provides an estimate of the annual jurisdictional revenue requirement for each year of the
SPP and additional details on each program for the first three years ofthe SPP (2020-2022),
including estimated rate impacts.
What programs are included in FPL's SPP?
FPL's SPP is, in large part, a continuation and expansion of its previously approved storm
hardening and storm preparedness programs, and includes the following SPP programs:
o Pole Inspections - Distribution Program
r Structures/Other Equipment Inspections - Transmission Program
r Feeder Hardening - Distribution Program
r Lateral Hardening (Undergrounding) - Distribution Program
o Wood Structures Hardening (Replacing) - Transmission Program
r Vegetation Management - Distribution Program
. Vegetation Management - Transmission Program
In addition, FPL proposes to implement a new Substation Storm Surge/Flood Mitigation
Program to protect T&D substations and equipment that are susceptible to storm surge or
flooding during extreme weather events.
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With the exception of the new storm surge/flood mitigation program, the majority of these
programs have been in place since 2007. As demonstrated by recent storm events, these
programs have been successful in reducing restoration costs and outage times following major
storrns, as well as improving day-to-day reliability. FPL submits that continuing these
previously approved storm hardening and storm preparedness programs in the SPP, together
with the new storm surge/flood mitigation program, is appropriate and necessary to meet the
requirements of Section 366.96, F.S., and Rule 25-6.030, F.A.C. These programs will address
the expectations of FPL's customers and other stakeholders for increased storm resiliency, and
will result in fewer outages, reduced restoration costs, and prompt service restoration. The SPP
will continue and expand the benefits of hardening, including improved day-to-day reliability,
to all customers throughout FPL's system.
Please provide an overview of the benefits of FPL's SPP.
The major benefit of FPL's SPP is to provide increased resiliency and faster restoration to the
electric infrastructure that FPL's five million customers and Florida's economy rely on for their
electricity needs. Safe and reliable electric service is essential to the life, health, and safety of
the public, and has become a critical component of modem life. Florida remains the most
hurricane-prone state in the nation and, with the significant coast-line exposure of FPL's system
and the fact that the vast majority of FPL's customers live within 20 miles of the coast, a robust
storm protection plan is critical to maintaining and improving grid resiliency and storm
restoration as contemplated by the Legislature in Section 366.96.
FPL's SPP programs have already demonstrated that they have provided and will continue to
provide increased Transmission and Distribution ("T&D") infrastructure resiliency, reduced
restoration time, and reduced restoration cost when FPL is impacted by extreme weather
events. FPL performed an analysis of Hurricanes Matthew and Irma that indicated the
restoration construction man-hours ("CMH"), days to restore, and storm restoration costs for
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these storms would have been significantly greater without FPL's storm hardening programs.
In the case of Hurricane Matthew, FPL estimated that without hardening, restoration would
have taken two additional days (50% longer), and resulted in additional restoration costs of
$105 million (36%higher than actual costs). Inthe case of Hurricane Irma, FPL estimated that
without hardening, restoration would have taken four additional days (40% longer), and
resulted in additional restoration costs of $496 million (4}%higher than actual costs). A copy
of FPL's analysis is provided in Appendix A to Exhibit MJ-l.
A detailed summary of the benefits of FPL's SPP is provided in Section II of the SPP, and the
benefits ofeach program are provided in Section IV ofthe SPP.
Does FPL's SPP address recovery of the costs associated with the SPP?
No. FPL anticipates the programs included in the SPP will have zero bill impacts on customer
bills during the first year of the SPP and only minimal bill increases for years two and three of
the SPP. However, the recovery of the actual costs associated with the SPP, as well as the costs
to be included in FPL's Storm Protection Plan Cost Recovery Clause, will be addressed in
subsequent and separate Storm Protection Plan Cost Recovery Clause dockets pursuant to Rule
25-6.031, F.A.C. The Commission has opened Docket No. 20200092-EI to address Storm
Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
UI. DESCRIPTION OF EACH SPP PROGRAM
Has FPL provided the information required by Rule 25-6.030(3Xd) for each program
included in its SPP?
Yes. FPL's SPP provides the information required by the Rule 25-6.030(3Xd) for each
program. If applicable, each program description included in FPL's SPP includes: (1) a
description of how each program is designed to enhance FPL's existing transmission and
distribution facilities including an estimate of the resulting reduction in outage times and
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restoration costs due to extreme weather conditions; (2) identification ofthe actual or estimated
start and completion dates of the program; (3) a cost estimate including capital and operating
expenses; (4) a comparison of the costs and the benefits; and (5) a description of the criteria
used to select and prioritize proposed storm protection programs. Each of the above listed
descriptions is provided in Section IV of FPL's SPP. Below, I will provide a brief overview
of each program included in FPL's SPP.
Please provide a summary of FPL's Pole Inspection - Distribution Program included in
the SPP.
The Pole Inspection - Distribution Program included in the SPP is a continuation of FPL's
existing Commission-approved distribution pole inspection program. FPL's existing,
Commission-approved distribution pole inspection program is an eight-year pole inspection
cycle for all distribution poles that targets approximately 1/8 of the system annually (the actual
number of poles inspected can vary somewhat from year to year). To ensure inspection
coverage throughout its service territory, FPL established nine inspection zones (based on
FPL's management areas and pole population) and annually performs pole inspections of
approximately 1/8 of the distribution poles in each of these zones, as well as any necessary
remediation as a result of such inspections. As explained in the SPP, recent storm events
demonstrate that FPL's existing distribution pole inspection program has contributed to the
overall improvement in distribution pole performance during storms, resulting in reductions in
storm damage to poles, days to restore, and storm restoration costs.
With approximately 1.2 million distribution poles as of year-end 2019,FPL expects to inspect
approximately 150,000 poles annually (spread throughout its nine inspection zones) during the
2020-2029 SPP period. The total estimated costs for the Pole Inspection - Distribution
Program for the ten-year period of 2020-2029 is $605 million with an annual average cost of
approximately $61 million, which is consistent with historical costs for the existing distribution
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pole inspection program.l A detailed description of the Pole lnspection - Distribution Program
is provided in Section IV(A) of FPL's SPP.
Please provide a summary of FPL's Structures/Other Equipment Inspections -
Transmission Program included in the SPP.
The Structures/Other Equipment Inspections - Transmission Program included in the SPP is a
continuation of FPL's existing Commission-approved transmission inspection program. The
SPP will continue FPL's current, Commission-approved transmission inspection program
which requires: (a) transmission circuits and substations and all associated hardware to be
inspected on a six-year cycle; (b) wood structures to be inspected visually from the ground on
an annual basis and climbing or bucket truck inspections to be conducted on a six-year cycle;
and (c) steel and concrete structures to be inspected visually on an annual basis and climbing
or bucket truck inspections to be conducted on aten-year cycle. As explained in the SPP, the
performance of FPL's transmission facilities during recent storm events indicates FPL's
transmission inspection progfam has contributed to the overall storm resiliency of the
transmission system and provided savings in storm restoration costs.
FPL expects to inspect approximately 68,000 structures annually during the 2020-2029 SPP
period. The total estimated costs for the Structures/Other Equipment Inspections -
Transmission Program for the ten*year period of 2020-2029 is $500 million with an annual
average cost of approximately $50 million, which is consistent with historical costs for the
1 Note, the 2020-2029 program costs shown above are projected costs estimated as of the time of this filing.
Subsequent projected and actual costs could vary by as much as 10%o to 15%o. The annual projected costs,
actual/estimated costs, actuals costs, and true-up of actual costs to be included in FPL's Storm Protection Plan
Cost Recovery Clause will all be addressed in subsequent and separate Storm Protection Plan Cost Recovery
Clause filings pursuant to Rule 25-6.031, F.A.C. The Commission has opened Docket No. 20200092-EI to
address Storm Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
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existing transmission inspection program.2 A detailed description of the Structures/Other
Equipment Inspections - Transmission Program is provided in Section IV(B) of FPL's SPP.
Please provide a summary of FPL's Feeder Hardening (EWL) - Distribution Program
included in the SPP.
The Feeder Hardening (EW-) - Distribution Program included in the SPP is a continuation of
FPL's existing Commission-approved approach to harden existing feeders and certain critical
distribution poles, as well as FPL's initiative to design and construct new pole lines and major
planned work to meet the National Electrical Safety Code's ("NESC") extreme wind loading
criteria ("EWL"). During the period 2006-2019, FPL hardened over 1,300 existing feeders, the
vast majority being Critical Infrastructure Function ("CIF") feeders (i.e., feeders that serve
hospitals, 911 centers, police and fire stations, water treatment facilities, county emergency
operation centers) and Community Project feeders (1.e., feeders that serve other key community
needs like gas stations, grocery stores and pharmacies) throughout FPL's service territory.
Additional feeders were hardened as a result of FPL's Priority Feeder Initiative, a reliability
program that targeted feeders experiencing the highest number of interruptions and/or customers
interrupted. FPL also applied EWL to the design and construction of new pole lines and major
planned work, including pole line extensions and relocations and certain pole replacements.
As provided in previous FPL Annual Reliability Report filings and three-year Storm Hardening
Plan filings (per Rule 25-6.0342, F.A.C.), hardened feeders perform better than non-hardened
feeders, both in day-to-day reliability performance and during severe storms. Additionally, upon
review of the electric utilities' storm hardening and storm preparedness programs, the
Commission found that for Hurricane Irma, hardened feeders performed significantly better than
2 See footnote 1
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non-hardened feeders with respect to outage rates, pole failures, and CMH required to restore
power.3
FPL expects to harden approximately 250-350 feeders annually, with 100% of FPL's feeders
expected to be hardened or underground by year-end 2024 and with the final costs of the
program to be incurred in2025. The total estimated costs for the Feeder Hardening (EWL) -
Distribution Program for the period of 2020-2025 is $3,206 million with an annual average cost
of approximately $534 million, which is consistent with historical costs for the existing
distribution feeder hardening program.a A detailed description of the Feeder Hardening (EWI-)
- Distribution Program is provided in Section IV(C) of FPL's SPP.
Please provide a summary of FPL's Lateral Hardening (Undergrounding) - Distribution
Program included in the SPP.
The Lateral Hardening (Undergrounding) - Distribution Program included in the SPP is a
continuation and expansion ofFPL's existing three-year Storm Secure Underground Program
Pilot ("SSUP Pilot") implemented in 2018. The SSUP Pilot is a program that targets certain
overhead laterals that were impacted by recent storms and have a history of vegetation-related
outages and other reliability issues for conversion from overhead to underground. As part ofits
proposed SPP, FPL will complete its existing three-year SSIIP Pilot in 2020 and expand the
application of the SSUP during 2021-2029 to the implementation of the system-wide Lateral
Hardening (Undergrounding) - Distribution Program to provide the benefits of underground
lateral hardening throughout its system. As explained in the SPP, the proposal to continue and
expand the application of the SSUP under the SPP is based on the performance of the
3 See Review of Florida's Electric Utility Hurricane Preparedness and Restoration Actions 2018, Docket No.
20170215-EU (July 24, 2018).
a See footnote 1.
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underground facilities as compared to overhead facilities and the extensive damage to the
overhead facilities caused by vegetation during Hurricanes Matthew and Irma.
By the end of 2020, the third and final year of the SSUP Pilot, FPL expects to have converted
a total of 220-230laterals from overhead to underground, which is consistent with the SSLIP
Pilot plan most recently approved in July 2019 in FPL's most recent storm hardening plan
docket, Docket No. 20180144-EI. After completing the SSUP Pilot in 2020,FPL estimates
that it will convert approximately 300-700 laterals annually in202I-2023 and approximately
800-900 laterals annually in2024-2029. The total estimated costs for the Lateral Hardening
(Undergrounding) - Distribution Program for the ten-year period of 2020-2029 is $5,101
million with an annual average cost of approximately $510 million.s A detailed description of
the Lateral Hardening (Undergrounding) - Distribution Program is provided in Section IV(D)
of FPL's SPP.
Please provide a summary of FPL's Wood Structures Hardening (Replacing) -
Transmission Program included in the SPP.
The Wood Structure Hardening (Replacing) - Transmission Program included in the SPP is a
continuation of FPL's existing transmission hardening program to replace all wood transmission
structures with steel or concrete structures. As explained in the SPP, the performance of FPL's
transmission facilities during recent storm events indicates FPL's transmission hardening
program has contributed to the overall storm resiliency ofthe transmission system and provided
savings in storm restoration costs.
As of year-end 2019, 96yo of FPL's transmission structures, system-wide, were steel or
concrete, with less than2,900 (or 4%) wood structures remaining to be replaced. FPL expects
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to replace the 2,900 wood transmission structures remaining on its system by year-end 2022.
The total estimated costs for the Wood Structure Hardening (Replacing) - Transmission
Program for the period of 2020-2022 is $118 million with an annual average cost of
approximately $39 million, which is a decrease from the historical costs for the existing
transmission hardening program.6 A detailed description of the Wood Structure Hardening
(Replacing) - Transmission Program is provided in Section IV(E) of FPL's SPP.
a. Please provide a summary of FPL's Substation Storm Surge/Flood Mitigation Program.
A. The Substation Storm Surge/Flood Mitigation Program is the only new storm hardening
program that FPL proposes to implement as part of its SPP. The Storm Surge/Flood Mitigation
- Transmission and Distribution Program will implement measures to protect T&D substations
and equipment that are susceptible to storm surge or flooding due to extreme weather events.
Historically, several FPL distribution and transmission substations have been impacted by
storm surge andlor flooding as a result of extreme weather conditions. While proactively de-
energizing those substations impacted by storm surge andlor flooding helps reduce damage to
substation equipment, FPL is still required to implement both temporary flood mitigation
efforts and repairs to substation facilities and equipment that become flooded as a result of
extreme weather conditions. Further, flooding and the need to proactively de-energize
substations located in areas susceptible to storm surge and flooding can result in significant
customer outages. To prevent/mitigate future substation equipment damage and customer
outages due to storm surge and flooding, FPL's new Storm Surge/Flood Mitigation Program
will raise the equipment at certain substations above the flood level and construct flood
protection walls around other substations to prevent/mitigate future damage due to storm surge
and flooding.
6 See footnote I
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At this time, FPL has identified between 8-10 substations where it initially plans to implement
storm surge/flood mitigation measures over the next three yearc (2020-2022). The total
estimated costs for the new Substation Storm Surge/Flood Mitigation over this three-year
period is approximately $23 million with an annual average cost of approximately $8 million
per year.1 A detailed description of the Storm Surge/Flood Mitigation - Transmission and
Distribution Program is provided in Section IV(F) of FPL's SPP.
Please provide a summary of FPL's Vegetation Management - Distribution Prdgram
included in the SPP.
The Vegetation Management - Distribution Program included in the SPP is a continuation of
FPL's existing, Commission-approved distribution vegetation management program. FPL's
currently-approved distribution vegetation program, includes the following system-wide
vegetation management activities: three-year cycle for feeders; mid-year cycle targeted
trimming for certain feeders; six-year cycle for laterals; and continued education of customers
through its Right Tree, Right Place initiative. In approving FPL's current distribution vegetation
management cycles, the Commission indicated that FPL's distribution vegetation management
cycles were cost-effective and would provide savings to customers. Additionally, as explained
in the SPP, recent storm events demonstrate that FPL's existing distribution vegetation
management program has contributed to the overall improvement in the resiliency of
distribution system during storms, resulting in reduclions in storm damage to poles, days to
restore, and storm restoration costs.
Under the SPP, FPL plans to trim, on average, approximately 15,200 miles annually, including
approximately 11,400 miles for feeders (cycle and mid-cycle) and 3,800 miles for laterals,
which is consistent with the historic miles trimmed annually. The total estimated costs for the
7 See footnote 1
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Vegetation Management - Distribution Program for the ten-year period of 2020-2029 is $596
million with an annual average cost of approximately $60 million, which is consistent with
historical costs for the existing distribution vegetation management program.8 A detailed
description of the Vegetation Management- Distribution Program is provided in Section IV(G)
of FPL's SPP.
Please provide a summary of FPL's Vegetation Management - Transmission Program
included in the SPP.
The Vegetation Management - Transmission Program included in the SPP is a continuation of
FPL's existing transmission vegetation management program. The key elements of FPL's
transmission vegetation management program are to inspect the transmission right-of-ways,
document vegetation inspection results and findings, prescribe a work plan, and execute the
work plan. In its SPP, FPL will continue its current transmission vegetation management plan,
which includes visual and aerial inspections of all transmission line corridors, Light Detection
and Ranging ("LiDAR") inspections of North American Electric Reliability Corporation's
("NERC") transmission line corridors, developing and executing annual work plans to address
identified vegetation conditions, and identifuing and addressing priority and hazard tree
conditions prior to and during storm season. As explained in the SPP, the execution of FPL's
transmission vegetation management plan has been and is a significant factor in mitigating
damage to transmission facilities and avoiding transmission-related outages.
Under the SPP, FPL plans to inspect and maintain, on average, approximately 7,000 miles of
transmission lines annually, including approximately 4,300 miles for NERC transmission line
corridors and2,700 miles for non-NERC transmission line corridors. This is comparable to
the approximately 7,000 miles inspected and maintained annually, on average for 2017-2019.
8 See footnote I
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The total estimated costs for the Vegetation Management - Transmission Program for the ten-
year period of 2020-2029 is $96 million with an annual average cost of approximately $10
million, which is consistent with historical costs for the existing transmission vegetation
management program.e A detailed description of the Vegetation Management - Transmission
Program is provided in Section IV(H) of FPL's SPP.
IV. ADDITIONALDETAILS FORFIRST THREE YEARS OF THE SPP
Has FPL provided additional project-level details and information for the first year
(2020) of the SPP?
Yes. The following additional information required by Rule 25-6.030(3Xe)(1), F.A.C., for the
first year (2020) of the SPP is provided in Appendix E to FPL's SPP: (t) the actual or estimated
construction start and completion dates; (2) a description of the affected existing facilities,
including number and type(s) of customers served, historic service reliability performance
during extreme weather conditions, and how this data was used to priorilize the proposed storm
protection project; and (3) a cost estimate including capital and operating expenses.
Additionally, a description ofthe criteria used to select and prioritize proposed storm protection
projects is included in the description ofeach proposed SPP program provided in Section IV
ofthe SPP.
Does FPL's SPP provide sufficient detail to develop preliminary estimates of the rate
impacts for the second and third years (2021-2022) of the SPP?
Yes. As required by Rule 25-6.030(3Xe)(2), F.A.C., FPL has provided the estimated number
and costs of projects under each specific SPP program, which information was used to develop
the estimated rate impacts for 2021-2022. This information is provided in Appendix C to FPL's
SPP.
e See footnote I
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a. Did FPL provide a description of its vegetation management activities under the SPP for
the first three years (2020-2022) of the SPP?
A. Yes. The following additional information required by Rule 25-6.030(3)(0, F.A.C., for the
first three years (2020-2022) of the vegetation management activities under the SPP is provided
in Sections IV(G) and IV(H) of FPL's SPP and Appendix C to FPL's SPP: the projected
frequency (trim cycle); the projected miles of affected transmission and distribution overhead
facilities; and the estimated annual labor and equipment costs for both utility and contractor
personnel. Additionally, descriptions of how the vegetation management activities will reduce
outage times and restoration costs due to extreme weather conditions are provided in Sections
IV(G) and IV(H) of FPL's SPP.
a. Has FPL provided the annual jurisdictional revenue requirements for the 2020-2029
SPP?
A. Yes. Pursuant to Rule 25-6.030(3)(9), F.A.C., FPL has provided the estimated annual
jurisdictional revenue requirements in Section VI of the SPP. While FPL has provided
estimated costs by program as of the time of this filing and associated total revenue
requirements in its SPP, consistent with the requirements of Rule 25-6.030, F.A.C., subsequent
projected and actual program costs submitted for cost recovery through the Storm Protection
Plan Cost Recovery Clause (per Rule 25-6.037, F.A.C.) could vary by as much as 70-75o/o,
which variations would also impact the associated estimated revenue requirements and rate
impacts. The projected costs, actuaU estimated costs, actuals costs, and true-up ofactual costs
to be included in FPL's Storm Protection Plan Cost Recovery Clause will all be addressed in
subsequent filings in separate Storm Protection Plan Cost Recovery Clause dockets pursuant
to Rule 25-6.031, F.A.C.to
a. Has FPL estimated the rate impacts for each of the first three years of the SPP?
r0 The Commission has opened Docket No. 20200092'EI to address Storm Protection Plan Cost Recovery Clause
petitions to be filed the third quarter of 2020 .
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FPL anticipates the programs included in the SPP will have zero bill impacts on customer bills
during the first year of the SPP and only minimal bill increases for years two and three of the
SPP. An estimate of the hypothetical overall rate impacts for the first three years of the SPP
(2020-2022) based on the total program costs reflected in this filing, without regard for the fact
that FPL remains under a general base rate freeze pursuant to a Commission-approved
settlement agreement through December 31,2021, are provided in Section VII ofthe SPP. The
projected costs, actual/estimated costs, actuals costs, and true-up ofactual costs to be included
in FPL's Storm Protection PIan Cost Recovery Clause will all be addressed in subsequent
filings in separate storm protection plan cost recovery clause dockets pursuant to Rule 25-
6.031, F.A.C.rr
V. CONCLUSION
Does FPL believe that its SPP will achieve the legislative objectives of Section 366.96, F.S.,
to reduce costs and outage times associated with extreme weather events by promoting
the overhead hardening of electrical transmission and distribution facilities, the
undergrounding of certain electrical distribution lines, and vegetation management?
Yes. While no electrical system can be made completely resistant to the impacts of hurricanes
and other extreme weather conditions, FPL's SPP provides a systematic approach to achieve
the legislative objectives of reducing restoration costs and outage times associated with extreme
weather events and enhancing reliability. As explained above and in further detail in the SPP,
FPL's SPP programs are largely a continuation and expansion of FPL's already successful and
ongoing storm hardening and storm preparedness programs previously approved by the
Commission, as well as a new storm hardening program to protect T&D substations and
equipment from storm surge and flooding due to extreme weather events. These SPP programs
llSee footnote 10.
18
2
aJ
4
5
6
7
a.
A.
will continue to provide increased T&D infrastructure resiliency, reduced restoration time, and
reduced restoration costs when FPL's system is impacted by extreme weather events. FPL's
SPP appropriately and effectively maintains and builds on FPL's commitment to provide safe
and reliable electric service to customers, and to meet the needs and expectations of our
customers, today and for many years to come.
Does this conclude your direct testimony?
Yes.
l9
Docket No. 202O0071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page '1 of 48
Florida Power & Light Gompany
Storm Protection Plan
2020-2029
(Rule 25-6.030, F.A.C.)
Docket No. 20200071-El
April 10, 2020
TABLE OF CONTENTS
Executive Summary.
The 2020-2029 SPP will Strengthen FPL's lnfrastructure to
Withstand Extreme Weather Conditions and will Reduce
Restoration Costs and Outage Times....
Description of Service Area and T&D Facilities ..........
2020-2029 SPP Programs..........
A. Pole lnspections-Distribution Program.....................
1. Description of the Program and Benefits..........
2 ActualiEstimated Stad and Completion Dates
3. Cost Estimates...
4. Comparison of Costs and 8enefits.............
5. Criteria used to Select and Prioritize the Program
B. Structures/OtherEquipmentlnspections-Transmission
Program
1. Description of the Program and 8enefits.............
2. Actual/Estimated Start and Completion Dates
3. Cost Estimates.......... ......i..........
4. Comparison of Costs and Benefits.............
5. Criteria used to Select and Prioritize the Program
Feeder Hardening (EWL) - Distribution Program .............
1. Description of the Program and 8enefits.............
2. Actual/Estimated Start and Completion Dates
3. CostEstimates.........
4. Comparison of Costs and 8enefits.............
5. Criteria used to Select and Prioritize the Program
Lateral Hardening (U ndergrounding) - Distribution Program.............
Description of the Program and Benefits........
Actual/Estimated Start and Completion Dates
Cost Estimates .........
Comparison of Costs and Benefits.................
Docket No. 2O20O071-El
FPL's 2O2O-2029 Storm Proteciion Plan
Exhibit MJ-l , Page 2 of 48
.........3
.........6
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.........7
.......10
.......10
.......11
.......11
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......12
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......14
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......26
I
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IV
c
D
1.
2.
3.
4.
5. Criteria used to Select and Prioritize the Program ....
E
F
G
H
3.
4-
Docket No. 202OO071-E\
FPL'i 2020-2029 Storm Protection Plan
Exhibit MJ-'l , Page 3 of 48
Wood Structures Hardening (Replacing) - Transmission
Program
1. Description of the Program and Benefits............. .........26
2. Actual/Estimated Start and Completion Dates ........
3. CostEstimates.........
4. Comparison of Costs and Benefits.............
5. Criteria used to Select and Prioritize the Program ..
Substation Storm Surge/Flood Mitigation Program
1. Description of the Program and Benefits............. .........30
2. Actual/Estimated Start and Completion Dates .............31
3. CostEstimates.........
4. Comparison of Costs and Benefits.................
5. Criteria used to Select and Prioritize Projects
Vegetation Management - Distribution Program ......
1. Description of the Program and Benefits........
2. Actual/Estimated Start and Completion Dates
.26
...28
...28
...29
...29
...30
...31
...31
...32
...32
32
35
35
36
Cost Estimates .....,.,.
Comparison of Costs and Benefits.............
5. Criteria Used to Select and Prioritize the Program
Vegetation Management - Transmission Program
1. Description of the Program and Benefits.............
2. Actual/Estimated Start and Completion Dates
3. CostEstimates.........
4. Comparison of Costs and 8enefits.............
....36
....37
....37
....39
....39
....40
'.,,40
V
5. Criteria used to Select and Prioritize the Programs..
Detailed lnformation on the First Three Years of the SPP (2020-
2022)
A. Detailed Description for the First Year of the SPP (2020)...
B. Detailed Description of the Second and Third Years of the
sPP (2021-2022)
C. Detailed Description of the Vegetation Management
Activities for the First Three Years of the SPP (2020-2022)
Estimate of Annual Jurisdictional Revenue Requirements for the
2020-2029 SPP .........
41
41
...41
41
VI
42
Vll. Estimated Rate lmpacts for First Three Years of the SPP (2020-
2022)
vill Conclusion
Appendices
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 4 of 4B
43
44
Appendix A -
Appendix B -
Appendix C -
Appendix D -
Appendix E -
FPL's Third Supplemental Response to Staff's First Data
Request No. 29 ('Third Supplemental Amended") in Docket No.
2017021s-El
FPL Management Areas and Customers Serued
FPL 2020-2029 SPP Estimated Annual Costs and Estimated
Number and Costs of Projects
FPL Distribution Design Guidelines
Project Level Detail for First Year of the SPP (2020)
Docket No. 20200071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 5 of 48
Florida Power & Light Gompany
2020-2029 Storm Protection Plan
l. Executive Summary
Pursuant to Section 366.96, Florida Statutes ("F.S."), and Rule 25-6.030, Florida
Administrative Code ("F.A.C."), Florida Power & Light Company ('FPL') submits its Storm
Protection Plan for the ten (10) year period 2020-2029 (hereinafter, the "SPP'). As
explained herein, the SPP is largely a continuation of FPL's successful storm hardening
and storm preparedness programs previously approved by the Florida Public Service
Commission ("Commission") over the last fourteen years. FPL anticipates the programs
included in the SPP will have zero bill impacts on customer bills during the first year of
the SPP and only minimal bill increases for years two and three of the SPP.1
Since 2006, FPL has been implementing Commission-approved programs to strengthen
its transmission and distribution ("T&D") infrastructure. These programs include multiple
storm hardening and storm preparedness programs, such as feeder hardening, replacing
wood transmission structures, vegetation management, and pole inspections. As
demonstrated by recent storm events, these ongoing storm hardening and storm
preparedness programs have resulted in FPL's T&D electricalgrid becoming more storm
resilient, experiencing less infrastructure damage and reduced restoration times, as
compared to non-hardened facilities. These programs have also provided significant
improvements in dayto-day reliability.
The success of FPL's storm hardening and storm preparedness programs has been
achieved through the development and implementation of FPL's forward-looking storm
hardening, grid modernization, and reliability initiatives and investments, combined with
the use of cutting-edge technology and strong employee commitment. Under the SPP,
FPL remains committed to continue these successful and industry-leading programs to
1 The recovery of the costs associated with the SPP, as well as the actual and projected costs io
be included in FPL's Storm Protection Plan Cost Recovery Clause, will be addressed in a
subsequent and separate Storm Protection Plan Cost Recovery Clause docket pursuant to Rule
25-6.031, F.A.C.
1
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 6 of 48
further strengthen its T&D infrastructure, mitigate restoration costs and outage times,
continue to provide safe and reliable electric service to customers, and meet future
increasing needs and expectations.
As stated previously, FPL's SPP is, in large part, a continuation and expansion of its
previously approved storm hardening and storm preparedness programs, and includes
the following SPP programs:
. Pole lnspections - Distribution Program
. Structures/Other Equipment lnspections - Transmission Program
. Feeder Hardening (EWL)- Distribution Program
. Lateral Hardening (Undergrounding) - Distribution Program
r Wood Structures Hardening (Replacing) - Transmission Program
. Vegetation Management - Distribution Program
. Vegetation Management - Transmission Program
ln addition, FPL will implement a new Substation Storm Surge/Flood Mitigation Program
to harden certain targeted substations that, based on prior experience, are susceptible to
storm surge or flooding during extreme weather events.
With the exception of the new storm surge/flood mitigation program, the majority of the
programs included in the SPP have been in place since 2007. As demonstrated by recent
storm events, these programs have been successful in reducing restoration costs and
outage times following major storms, as well as improving day-to-day reliability. FPL
submits that continuing these previously approved storm hardening and storm
preparedness programs in the SPP, together with the new storm surge/flood mitigation
substation program, is appropriate and necessary to address the mandates set forth in
Section 366.96, F.S., and Rule 25-6.030, F.A.C., as well as the expectations of FPL's
customers and other stakeholders for increased storm resiliency and will result in fewer
2
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 7 of 48
outages, reduced restoration costs, and prompt service restoration.2 The SPP will
continue and expand the benefits of hardening, including improved day-to-day reliability,
to all customers throughout FPL's system.
The following sections provide information and details on FPL's SPP as required by and
in compliance with Rule 25-6.030, F.A.C. For the reasons explained below, FPL submits
that implementing the SPP is necessary and appropriate to achieve the goals and
requirements expressed by the Florida Legislature in Section 366.96, F.S., to reduce
restoration costs and outage times associated with extreme weather events and improve
overall service reliability to customers and the State of Florida by promoting the overhead
hardening of electrical transmission and distribution facilities, the undergrounding of
certain electrical distribution lines, and vegetation management.
ll. The 2020-2029 SPP will Strenqthen FPL's lnfrastructure
to Withstand Extreme Weather Conditions and will
Reduce Restoration Costs and Outaqe Times
Pursuant to Rule 25-6.030(3)(a), F.A.C., this section provides an overview of how the
SPP will strengthen FPL's electric utility infrastructure to withstand extreme weather
conditions by promoting the overhead hardening of electricaltransmission and distribution
facilities, the undergrounding of certain electrical distribution lines, and vegetation
management. Consistent with Rule 25-6.030(3Xb), F.A.C., this section also provides a
summary of how the SPP is expected to further reduce restoration costs and outage times
associated with extreme weather conditions and, therefore, improve overall service
reliability.
To date, significant progress has been made toward strengthening FPL's infrastructure.
For example, at year-end 2019, approximalely 54o/o of FPL's distribution feeders have
been either hardened or placed underground, and approximately 96% of FPL's
transmission structures are either steel or concrete. AIso, since 2006, FPL has completed
multiple system-wide cycles of distribution and transmission pole inspections and
2 As explained below, a couple of the programs included in the SPP are expected to be completed
within the next several years.
3
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 8 of 48
vegetation management. Within the next few years several significant milestones are
also expected to be reached, including replacement of all wood transmission structures
with steel or concrete structures by year-end 2022 and for allfeeders to be hardened or
placed underground by year-end 2024.
FPL also implemented a three-year Storm Secure Underground Program Pilot in 2018
('SSUP Pilot") that converts certain targeted overhead laterals - laterals that have been
impacted by recent storms and have a history of vegetation-related outages and other
reliability issues - to underground laterals. At year-en d 2020, the final year of the SSUP
Pilot, FPL expects 220-230 of these targeted laterals to be converted from overhead to
underground. In addition, FPL's Design Guidelines incorporate and apply extreme wind
loading ("EWL") criteria to the design and construction of all new overhead pole lines and
major planned work, including pole line extensions, relocations, and certain pole
replacements.
FPL's SPP programs have already demonstrated that they have and will continue to
provide increased T&D infrastructure resiliency, reduced restoration time, and reduced
restoration costs when FPL's system is impacted by severe weather events. ln FPL's
Third Supplemental Response to Staff's First Data Request No. 29 ('Third Supplemental
Amended") in Docket No. 20170215-E1,3 FPL prepared and submitted an analysis of
Hurricanes Matthew and lrma that indicated the restoration construction man-hours
("CMH'), days to restore, and storm restoration costs for these storms would have been
significantly higher without FPL's storm hardening programs. Below is a summary of the
results of FPL's analysis:
Without Hardeni Hurricane Matthew Hurricane lrma
3 The Commission opened Docket No. 20170215-El to review electric utility preparedness and
restoration actions and to identify potential areas where infrastructure damage, outages, and
recovery time for customers could be minimized in the future.
4
93,000 (36%)483,000 @0o/o)Additional CMH (%)
2 (50o/o)4 (40%)Additionaldays to restore (%)
$4e6 (40%)Additional restoration costs
($millions) (%)
$105 (36%)
Docket No. 2O20O071-E\
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-'l, Page I of 48
A copy of FPL's Third Supplemental Amended Response in Docket No.20170215-El,
including the analysis referenced above, is provided in Appendix A. Based on a 40-year
net present value analysis, the savings achieved from storm hardening would equate to
$653 million (for a storm occurring once every three years) and $406 million (for a storm
occurring once every five years) for a storm similar to Hurricane Matthew and $3.'l billion
(for a storm occurring once every three years) and $1.9 billion (for a storm occurring once
every five years) for a storm similar to Hurricane lrma.
These programs have also provided increased levels of day{o-day reliability. For
example, FPL has previously submitted reports to the Commission that show hardened
feeders have performed approximately 40% better (i.e., fewer outages) on a day{o-day
basis than non-hardened feeders.a Further details on the benefits of the SPP programs
are provided throughout the remaining sections of this SPP.
Although FPL's storm preparedness and hardening programs to date have produced a
more storm resilient and reliable T&D electrical grid, FPL must continue its efforts to
storm-harden its T&D electrical grid consistent with the findings, conclusions, and
objectives of the Florida Legislature in Section 366.96, F.S. lndeed, Florida remains the
most hurricane-prone state in the nation and, with the significant coast-line exposure of
FPL's system and the fact that the vast majority of FPL's customers live within 20 miles
of the coast, a robust storm protection plan is critical to maintaining and improving grid
resiliency and storm restoration.
Safe and reliable electric service is essential to the life, health, and safety of the public,
and has become a critical component of modern life. lmportantly, as evidenced by the
significant numbers of Florida's workforce that are working remotely during the COVID-
19 pandemic, today's digital society, economy, national security, and daily life are more
dependent on reliable electric service than ever before. While no electrical system can
be made completely resistant to the impacts of hurricanes and other extreme weather
conditions, the programs included in FPL's SPP have already demonstrated that they
5
a See Appendix A.
Docket No. 2O2OO071-E\
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 10 of 48
mitigate and will continue to mitigate the impacts of future storms.s While FPL's nation-
leading initiatives have made significant progress toward strengthening FPL's
infrastructure, continuing these previously approved storm hardening and storm
preparedness programs in the SPP, together with the new storm surge/flood mitigation
substation program, is appropriate and crucial to further mitigate restoration costs and
outage times, continue to provide safe and reliable electric service to customers, and
meet current and future needs and expectations of customers, today and for many years
to come.
lll. Descriotion of Service Area a nd T&D Facilities
Pursuant to Rule 25-6.030(3)(c), F.A.C., this section provides a description of FPL's
service area, including areas prioritized for enhancement, if any, and any areas where
FPL has determined that enhancement of its existing T&D facilities would not be feasible,
reasonable, or practical at this time.
Today, FPL's service territory consists of approximately 28,000 square miles. To serve
its more than 5 million customers, FPL has constructed a T&D electric grid that contains
approximately 75,000 miles of electrical lines, including:
. Approximately 42,000 miles of overhead distribution lines;
. Approximately 26,000 miles of underground distribution lines;
. Approximately 7,000 miles of high-voltage transmission lines;
. Approximately 1.2 million distribution poles; and
. Approximately 68,000 transmission structures.
FPL's service territory is divided into sixteen (16) distribution management areas. A map
depicting FPL's service territory and distribution management areas (with the number of
customers served within each management area) is provided in Appendix B.
At this time, FPL has not identified any areas of its service territory where its SPP
programs would not be feasible, reasonable, or practical. While all of FPL's SPP
5 lt is important to note that despite the implementation of these storm hardening and storm
preparedness programs, outages will still occur when severe weather events impact Florida.
6
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page '1'1 of 48
programs are currently system-wide initiatives, annual activities are prioritized based on
ceftain factors such as last inspection date, last trim date, reliability performance, and
efficient resource utilization.o At this time, there is no area specifically targeted or
prioritized for enhanced performance based on its geographical location.
lV. 2020-2029 SPP Proqrams
Pursuant to Rule 25-6.030(3XcXd), F.A.C., this section provides a description of each
program included in FPL's SPP. lf applicable, each program description below includes:
(1) a description of how each program is designed to enhance FPL's existing transmission
and distribution facilities including an estimate of the resulting reduction in outage times
and restoration costs due to extreme weather conditions; (2) identification of the actual or
estimated start and completion dates of the program; (3) a cost estimate including capital
and operating expenses; (4) a comparison of the costs and the benefits; and (5) a
description of the criteria used to select and prioritize storm protection programs.
A. Pole lnspections - Distribution Program
1. Description of the Proqram and Benefits
The Pole lnspection - Distribution Program included in the SPP is a continuation of FPL's
existing Commission-approved distribution pole inspection program. Below is an
overview of FPL's existing distribution inspection program and its associated benefits.
a. Overview of the Distribution Pole lnspection Proqram
ln response to the 2004-2005 storm seasons and, in particular, the "large number of poles
throughout Florida that required replacement," the Commission required investor-owned
utilities ("lOUs") to implement an eight-year pole inspection cycle for all wood distribution
poles.T FPL's plan was approved in September 20068 and modified in January 2007.e
6 The criteria and factors used to select and prioritize projects within each SPP program are
described below.
7 See Order No. PSC-06-0144-PAA-El.
I See Order No. PSC-06-0778-PAA-EU.
e See Order No. PSC-07-0078-EU.
7
Docket No. 20200071-El
FPL'S 2o2o-2o29 Storm Protection Plan
Exhibit MJ-1, Page 12 ol 48
Subsequently, FPL expanded its distribution pole inspection plan to also include concrete
poles.
FPL's eight-year pole inspection cycle for all distribution poles targets approximately 1/8
of the system annually (the actual number of poles inspected can vary somewhat from
year to year). To ensure inspection coverage throughout its service territory, FPL
established nine (9) inspection zones (based on FPL's management areas and pole
population)and annually performs pole inspections of approximately'1/8 of the distribution
poles in each of these zones, as well as any necessary remediation as a result of such
inspections. FPL utilizes Osmose Utilities Services, lnc. ("Osmose"), an industry-leading
pole inspection contractor, to perform the system-wide inspection of its distribution poles.
FPL's strength and loading calculations for its distribution poles and pole inspections are
based on the National Electrical Safety Code's ('NESC") Grade B construction standard,
as outlined by Table 261-1A section 26 of the NESC. Osmose utilizes mobile computing
technology to record inspection data and to calculate strength and loading. The loading
calculation, span lengths, attachment heights, and wire sizes are recorded in the mobile
computer to determine whether the remaining pole strength capacity meets or exceeds
NESC requirements. This data is then transferred to FPL's Geographic lnformation
System ("GlS'). Pole locations inspected by Osmose are also randomly audited by FPL
to verify that inspections are completed and meet inspection standards.
lnspections include a visual inspection of all distribution poles from the ground-line to the
top of the pole to identify visual defects (e.9., woodpecker holes, split tops, decayed tops,
cracks, etc.). lf, due to the severity of the defects, the poles are not suitable for continued
service, the poles are designated for replacement.
Wood poles that pass the above-ground visual inspection are excavated to a depth of 18"
(where applicable), and sounded and bored to determine the internal condition of the
pole. Poles encased in concrete or asphalt are not excavated, but are sounded and bored
to determine their internal condition using a standard industry-accepted inspection
process called "Shell Boring." All suitable wood poles receive external and/or internal
preservative treatment or, if not suitable, are replaced. Strength calculations are also
8
Docket No. 2O2OO071-E\
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1 , Page '13 of 48
performed on wood poles to determine compliance with NESC requirements. The poles
that are not suitable for continued service are designated for replacement or remediation.
ln 2014, FPL obtained Commission approval to: (1) exempt the loading assessment
during the second eight-year cycle for any pole that had less than 80% of full load during
FPL's initial eight-year cycle; and (2) excavate Chromium Copper Arsenate ("CCA') poles
every 28 years (extended from 16 years originally approved by the Commission).1o To
ensure that these exceptions to the standard eight-year inspection cycle do not
compromise existing safety and storm hardening programs, FPL conducts annual testing
on 1o/o of the exempted poles.
b. Benefits of the Distribution Pole Inspection Proqram
The Commission has previously found that "efforts to maintain system components can
reduce the impact of hurricanes and tropical storms upon utilities' transmission and
distribution systems," and noted that an "obvious key component in electric infrastructure
is the transmission and distribution poles.'11 The Commission has also previously
identified multiple benefits of and reasons for justifying pole inspections cycles for electric
utilities, including, but no limited to: the likelihood of increased hurricane activity in the
future; the high probability for equipment damage if a pole fails during a storm; the
Iikelihood that failure of one pole often causes other poles to fail; the fact that deteriorated
poles are more prone to fail when exposed to high winds; the fact that Florida electric
utilities replaced nearly 32,000 poles during the 2004 storm restoration efforts; and the
fact that restoration times increase significantly when a large number of poles fail, which
limits the electric utilities' ability to respond quickly to widespread outages.12
ln addition to the benefits discussed above that underlie the creation of the Commission's
mandated pole inspection requirements, recent storm events indicate that FPL's
distribution pole inspection program has contributed to the overall improvement in
distribution pole performance during storms, resulting in reductions in storm damage to
poles, days to restore, and storm restoration costs. The table below compares distribution
10 See Order No. PSC-14-0594-PAA-El
11 See Order No. PSC-06-0144-PAA*E.
12 See id.
I
Docket No. 2020O071-El
FPL's 2O2O-2029 Storm Protection Plan
Exhibit MJ-1, Page 14 of 4B
pole performance for Hurricane Wilma, which occurred in 2005 before FPL implemented
its current distribution pole inspection program, and Hurricane lrma, which occurred in
2017 after FPL implemented its current distribution pole inspection program:
Hurricane Wilma Hurricane lrma
Hurricane Strength (Category)3 4
Customer Outages (Millions)3.2 4.4
Distribution Poles Replaced >12,400 <2,90013
Total Days to Restore 18 10
Average Days to Restore 5.4 2.1
FPL's Commission-approved distribution pole inspection program has facilitated the
replacement and/or strengthening of over 140,000 distribution poles since it was first
implemented in 2006 and has directly improved and will continue to improve the overall
health and storm resiliency of its distribution pole population.
2. Actual/Estimated Start and Completion Dates
The SPP will continue FPL's ongoing Commission-approved distribution pole inspection
program described above. With approximately 1.2 million distribution poles as of year-
end 2019, FPL expects to inspect approximately 150,000 poles annually (spread
throughout its nine inspection zones) during the 2020-2029 SPP period.
3. Cost Estimates
Estimated/actual annual distribution pole inspection costs are a function of the number of
inspections estimated to be/actually completed and the number of poles estimated to
be/actually remediated/replaced as a result of the annual inspections. Although costs to
inspect the poles are operating expenses, the vast majority of pole inspection program
costs are capital costs resulting from remediation/replacement of poles that fail
inspection.
13 Approximately 99% of distribution poles replaced after Hurricane lrma were non-hardened
poles.
'10
Docket No. 2O200071-El
FPL'i 2020-2029 Storm Protection PIan
Exhibit MJ-1 , Page 15 of 48
The table below provides a comparison of the 2017-2019 total actual distribution pole
inspection costs with the 2020-2022 (first three years of the SPP) total estimated
distribution pole inspection costs and lhe 2020-2029 total estimated distribution pole
inspection costs:
Total Program Costs Annual Average Program
millions Costs millions
Further details regarding SPP estimated distribution pole inspection costs, including
estimated annual capital expenditures and operating expenses, are provided in Appendix
c.14
4. Comparison of Costs and Benefits
As provided in Section (|VXAX3) above, during 2020-2029, total costs for FPL's Pole
lnspection - Distribution Program are expected to average approximately $61 million per
year. Benefits associated with FPL's Pole lnspection - Distribution Program, discussed
in Sections ll and |V(AX1)(b) above, include a more storm resilient pole population that
will result in reductions in pole failures and poles needing to be replaced during storms,
fewer storm-related outages and reductions in storm restoration costs.
5. Criteria used to Select and Prioritize the Prooram
Poles to be inspected annually are selected/prioritized within each of the nine (9)
inspection zones established throughout FPL's service territory based on the last cycle's
inspection dates, to ensure that poles are in compliance with FPL's established eight-year
14 Note, the 2020-2029 program costs shown above are projected costs estimated as of the time
of this filing. Subsequent projected and actual costs could vary by as much as 10% to 15%. The
annual projected costs, actual/estimated costs, actuals costs, and true-up of actual costs to be
included in FPL's Storm Protection Plan Cost Recovery Clause will all be addressed in
subsequent and separate Storm Protection Plan Cost Recovery Clause filings pursuant to Rule
25-6.031, F.A.C. The Commission has opened Docket No.20200092-El to address Storm
Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
2017-2019 $1 52 $st
2020-2022 $1 70 $sz
2020-2029 $605 $61
11
Docket No. 2020007l-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 16 of 48
cycle. As such, approximately 1/8 of the distribution poles in each inspection zone are
inspected annually.
At this time, FPL has not identified any areas where the Pole lnspection - Distribution
Program would not be feasible, reasonable or practical.
Structures/Other Equipment lnspections Transmission
Program
1. Description of thef roqram and Benefits
The Structures/Other lnspections - Transmission Program included in the SPP is a
continuation of FPL's existing Commission-approved transmission inspection program.
Below is an overview of FPL's existing transmission inspection program and the
associated benefits.
a. Overview of the Transmission lnspection Proqram
ln 2006, as part of its Storm Preparedness lnitiative No. 3, the Commission required
electric utilities to develop and implement plans to fully inspect alltransmission structures,
substations, and all hardware associated with these facilities on a six-year cycle.
Consistent therewith, FPL implemented a Commission-approved transmission inspection
plan in 2006 and has continued that plan to date.
Under its Commission-approved transmission inspection plan, FPL inspects its
transmission circuits, substations, and other equipment on a six-year cycle. Additionally,
all of FPL's transmission structures are visually inspected from the ground each year.
Finally, FPL performs climbing or bucket truck inspections on all wood transmission
structures on a six-year cycle and all steel and concrete structures on a ten-year cycle.
lnspections for wood structures include an overall assessment of the condition of the
structures, as well as other pole/structure components including the foundation, all
attachments, insulators, guys, cross-braces, cross-arms, and bolts. lf a wood
transmission structure does not pass visual inspection, it is designated for replacement
with a concrete or steel transmission structure.
B
12
Docket No. 2O2O0071-E\
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 17 ol 48
For steel and concrete structures, the visual inspection includes an overall assessment
of the structure condition (e.9., cracks, chips, exposed rebar, and rust) as well as other
pole/structure components including the foundation, all attachments, insulators, guys,
cross-braces, cross-arms, and bolts. lf a concrete or steel pole/structure fails the
inspection, it is designated for repair or replacement.
The SPP will continue FPL's current transmission inspection program which requires: (a)
transmission circuits and substations and all associated hardware to be inspected on a
six-year cycle; (b) wood structures to be inspected visually from the ground each year
and climbing or bucket truck inspections to be conducted on a six-year cycle; and (c) steel
and concrete structures to be inspected visually each year and climbing or bucket truck
inspections to be conducted on a ten-year cycle.
b. Benefits of the Transmission lnspection Proqram
As noted in Section |V(AX1Xb) above, the Commission has found numerous benefits and
reasons justifying inspections of electrical utility facilities, including transmission facilities.
lmportantly, the transmission system is the backbone of the electric grid. While outages
associated with distribution facilities (e.9., a transformer, lateral orfeeder) can result in
an outage affecting anywhere from a few customers up to several thousands of
customers, a transmission related outage can affect tens of thousands of customers.
Additionally, an outage on a transmission facility could cause cascading (a loss of power
at one transmission facility can trigger the loss of power on another interconnected
transmission facility, which in turn can trigger the loss of power on another interconnected
transmission facility, and so on) and result in the loss of service for hundreds of thousands
of customers. As such, it is imperative that transmission facilities be properly inspected
using appropriate cycles and standards to help ensure they are prepared for storms.
Further, the performance of FPL's transmission facilities during recent storm events
indicates FPL's transmission inspection program has contributed to the overall storm
resiliency of the transmission system and provided savings in storm restoration costs.
The table below compares the performance of FPL's transmission system for Hurricane
Wilma, which occurred in 2005 before FPL implemented its current transmission
13
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , Page 1B of 48
inspection program, and Hurricane lrma, which occurred in 2017 after FPL implemented
its current transmission inspection program:
Transmission Facilities Hurricane Wilma Hurricane lrma I rovement
As shown above, the impacts on FPL's transmission facilities associated with Hurricane
lrma were significantly reduced from those experienced with Hurricane Wilma, even
though Hurricane lrma's winds were stronger and its path impacted substantially more of
FPL's facilities. As reflected in the Commission's reasoning for mandating transmission
facility inspections, FPL submits that its systematic transmission inspection program is a
key factor for this improved performance.
2. Actual/Esti mated Start and Comoletion Dates
The SPP will continue FPL's ongoing Commission-approved transmission inspection
program described above. This requires FPL to inspect: (a) transmission circuits and
substations and all associated hardware on a six-year cycle; (b) wood structures to be
visually inspected from the ground each year and conduct climbing or bucket truck
inspections on a six-year cycle; and (c) steel and concrete structures visually each year
and conduct climbing or bucket truck inspections on a ten-year cycle.
3. Cost Estimates
Estimated/actual annual transmission inspection costs are a function of the number of
inspections estimated to be/actually completed and the transmission facilities estimated
to be/actually remediated/replaced as a result of those annual inspections. Although the
inspection costs are operating expenses, the vast majority of the transmission inspection
program costs are capital costs resulting from remediation/replacement of facilities that
fail inspection.
The table below provides a comparison of the 2017-2019 total actual transmission
inspection costs with the 2020-2022 (first three years of the SPP) total estimated
38%Line Section Outages 345 215
241 92 620/oSubstation Outages
5 95o/oStructures Failed 100
14
Docket No. 2O2OO071-E\
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 19 of 4B
transmission inspection costs and the 2020-2029 totalestimated transmission inspection
costs:
Total Program Costs Annual Average Program
illions Costs illions
Further details regarding the SPP estimated transmission inspection costs, including
estimated annual capitalexpenditures and operating expenses, are provided in Appendix
c.15
4 Comn arison of Costs and Benefits
As provided in Section |V(BX3) above, during 2020-2029, total costs for FPL's
Structures/Other lnspections - Transmission Program are expected to average
approximately $50 million per year. Benefits associated with the Structures/Other
lnspections - Transmission Program discussed in Sections ll and IV(BX1)(b) above,
include avoiding outages that can affect tens of thousands of customers and, in particular,
cascading outages where the loss of service can affect hundreds of thousands of
customers.
5. Criteria used to Select and Prioritize the Proqram
As explained above, FPL visually inspects from the ground alltransmission structures on
an annual basis. For the inspection of transmission circuits and substations and all
associated hardware, the facilities are selected/prioritized throughout FPL's service
territory based on the last cycle's inspection dates, to ensure that facilities are inspected
in compliance with the established six-year inspection cycle. Similarly, for bucket truck
or climbing inspections, structures are selected/prioritized throughout FPL's service
territory based on the last cycle's inspection dates, to ensure that structures are inspected
2017-2019 $128 $43
2020-2022 $e7 $32
2020-2029 $500 $50
15 See footnote 14.
15
Docket No. 2O2OO071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1, Page 20 of 48
in compliance with the established six-year (wood) and ten-year (steel and concrete)
cycles.
At this time, FPL has not identified any areas where the Structures/Other lnspections -
Transmission Program would not be feasible, reasonable or practical.
c. Feeder Hardening (EWL) - Distribution Program
1. Description of the Program and Benefits
The Feeder Hardening (EWL) - Distribution Program included in the SPP is a
continuation of FPL's existing Commission-approved approach (most recently approved
in Docket No.20180144-EI) to harden existing feeders and certain critical distribution
poles, as well as FPL's initiative to design and construct new pole lines and major planned
work to meet the NESC's extreme wind loading criteria ("EWL'). FPL will continue the
distribution feeder hardening program until2024, when FPL expects 100% of its feeders
to be hardened or underground. Below is an overview of FPL's existing distribution feeder
hardening program and the associated benefits.
a. Overview of the Distribution Feeder Hardening Proqram
The foundation for FPL's distribution feeder hardening program was the extensive
forensic and other analyses that FPL conducted after Hurricane Wilma.16 These analyses
concluded that "wind only" (as opposed to, for example, trees or other flying debris) was
the predominant root cause of distribution pole breakage. This data, together with the
overall pefformance of FPL's transmission poles thatwere already built to the NESC EWL
standards and the performance of hardened feeders during Hurricanes Matthew and
lrma, formed the basis for FPL's feeder hardening strategy.
The SPP will continue FPL's previously approved approach to apply EWL criteria to
harden existing distribution feeders and certain critical poles. The NESC extreme wind
map for Florida will continue to be applied to FPL's system by dividing the application of
16 These analyses were conducted either directly by FPL or with the aid of external resources
(e.9., KEMA, lnc.).
16
Docket No. 2O2OOO7|-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 21 o'f 48
EWL into three wind regions, corresponding to expected extreme winds of 105, 130 and
145 mph, as shown below.
Wind tons - m h meter/sec
so(sc)105 mph
130 mph
145 mph
r40{G3)
By evaluating each of the counties served by FPL, including each county's applicable
wind zones, FPL determined that utilizing three extreme wind regions of 105, 130 and
145 mph for its service territory was appropriate for the following reasons:
A smaller number of wind regions generate advantages through efficiency of
work methods, training, engineering and administrative aspects (e.9.,
standards development and deployment); and
t
n
I
lo(ca
a
a Using 105, 130 and 145 mph wind zones is a well balanced approach that
recognizes differences in the EWL requirements in the counties within each
region.
The SPP will also continue to utilize FPL's Design Guidelines and processes that apply
EWL criteria to the design and construction of new pole lines and major planned work,
including pole line extensions and relocations and certain pole replacements. Depending
on the scope of the work that is performed in a particular project, this could result in the
EWL hardening of an entire circuit (in the case of large-scale projects) or in EWL
hardening of one or more poles (in the case of small projects) so that the affected circuit
will be in a position to be fully EWL hardened in the future. The Design Guidelines are
17
Docket No. 2O2OO071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1, Page 22 of 48
primarily associated with changes in pole class, pole type, and desired span lengths to
be utilized. The Design Guidelines standardize the design and construction of new pole
lines and major planned work to ensure that these projects align with FPL's hardening
strategy.
FPL's current pole sizing guidelines provide for a minimum installation of: Class 2 wood
poles for all new feeder and three-phase lateral work; Class 3 wood pole for two-phase
and single-phase lateral work; and Class 3 wood pole for service and secondary work.
For critical poles, FPL's current pole sizing guidelines provide for the installation of
concrete poles at accessible locations. These guidelines significantly increase the wind
ratings (up to nearly 50 percent) from the Design Guidelines in place prior to 2007. FPL's
current Distribution Design Guidelines are provided in Appendix D.
To determine how an existing overhead circuit or critical pole will be hardened, a field
survey of the circuit facilities is performed. By capturing detailed information at each pole
location, such as pole type, class, span distance, attachments, wire size, and framing, a
comprehensive wind-loading analysis can be performed to determine the current wind
rating of each pole, and ultimately the circuit itself. This data is then used to identify
specific pole locations on the circuit that do not meet the desired wind rating. For all poles
that do not meet the applicable EWL, FPL develops recommendations to increase the
allowable wind rating of the pole.
FPL plans to continue to utilize its "design toolkit" that focuses on evaluating and using
cost-effective hardening options for each location, including:
Storm Guying - lnstalling a guy wire in each direction perpendicular to the line,
which is a very cost-effective option but is dependent on proper field conditions;
Equipment Relocation - Moving equipment on a pole to a stronger pole near-
by;
lntermediate Pole - lnstalling an additional single pole within long span lengths,
which reduce the span length and increases the wind rating of both adjacent
poles;
a
a
a
18
Docket No. 2O2OO071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 23 of 48
Upgrading Pole Class - Replacing the existing pole with a higher class pole to
increase the pole's wind rating; and;
Undergrounding Facilities - Evaluated on a case-by-case basis using site-
specific factors and conditions.
These options are not mutually exclusive and, when used in combination with sound
engineering practices, provide cost-effective methods to harden a circuit. FPL's design
recommendations also take into consideration issues such as hardening, mitigation
(minimizing damage), and restoration (improving the efficiency of restoration in the event
of failure). Since multiple factors can contribute to losing power after a storm, utilizing
this multi-faceted approach to pole design helps to reduce the amount of work required
to restore power to a damaged circuit.
b. Benefits of the Distribution Feeder Hardeninq Proqram
Distribution feeders are the backbone of the distribution system and are critical
component to providing safe and reliable electric service to FPL's customers. Thus,
improving the storm resiliency of distribution feeders logically provides substantial
benefits for customers. Therefore, hardening distribution feeders has been and continues
to be one of FPL's highest storm hardening priorities.
During the period 2006-2019, FPL hardened over 1,300 existing feeders, the vast majority
being Critical lnfrastructure Function ("ClF") feeders (i.e., feeders that serve hospitals,
911 centers, police and fire stations, water treatment facilities, county emergency
operation centers) and Community Project feeders (r.e., feeders that serve other key
community needs like gas stations, grocery stores, and pharmacies) throughout FPL's
service territory. Additional feeders were hardened as a result of FPL's Priority Feeder
lnitiative, a reliability program that targeted feeders experiencing the highest number of
interruptions and/or customers interrupted. As of year-end 2019, approximalely 54o/o of
FPL's feeders were either hardened or placed underground. Additionally, FPL has
hardened 125 highway crossings and over 300 "01" switches (first pole out of a substation
with a feeder switch). FPL also applied EWL to the design and construction of new pole
a
a
19
Docket No. 2O200071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1 , Page 24 of 48
lines and major planned work, including pole line extensions and relocations and certain
pole replacements.
As provided in previous FPL Annual Reliability Report filings and three-year Storm
Hardening Plan filings (per Rule 25-6.0342, F.A.C.) hardened feeders perform better than
non-hardened feeders. This has been demonstrated in-day-to-day reliability peformance
and during severe storms. For example, when comparing dayto-day reliability
peformance, hardened feeders have performed 40% better than non-hardened feeders.
Also, during Hurricanes Matthew and lrma, hardened feeders performed betterthan non-
hardened feeders.
Additionally, in Docket No. 20170215-EU, the Commission reviewed the electric utilities'
storm hardening and storm preparedness programs and found for Hurricane lrma that:
(1) outage rates were nearly 20% less for hardened feeders than non-hardened feeders;
(2) CMH to restore hardened feeders were 50% less than non-hardened feeders
(primarily due to hardened feeders experiencing less damage than non-hardened
hardened feeders); and (3) hardened feeders had significantly less pole failures as
compared to non-hardened feeders.lT
2. Actual/Estimated Start and Completion Dates
FPL initiated its feeder hardening initiative in 2006. As of year-end 2019, there are
approximately 1,600 feeders remaining to be hardened or placed underground. FPL
expects to harden approximately 250-350 feeders annually, with 100% of FPL's feeders
expected to be hardened or underground by year-end 2024 and with the final costs of the
program to be incurred in 2025.
17 See Review of Florida's Electric Utility Hurricane Prepared ness and Restoration Actions 2018,
Docket No. 20170215-EU (July 24, 2018), available at
http://www.psc.state.fl.us/librarvffilinqs/2018/04847-2018/04847-2018.pdf.
20
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 25 of 48
3. Cost Estimates
Estimated distribution feeder hardening costs are determined utilizing the length of each
feeder, the average historical feeder hardening cost per mile, and updated cost
assumptions (e.9., labor and materials).
The table below provides a comparison of the 2017-2019 total actual distribution feeder
hardening costs with the 2020-2022 (first three years of the SPP) total estimated
distribution feeder hardening costs and the total estimated distribution feeder hardening
costs to be incurred over the period of 2020-202518.
Total Program Gosts Annual Average Program
illions Gosts millions
Further details regarding the SPP distribution feeder hardening costs, including estimated
annual capital expenditures are provided in Appendix C.ls
4. Comparison of Costs and Benefits
As provided in Section lV(C)(3) above, during 2020-2025, total costs for FPL's Feeder
Hardening (EWL) - Distribution Program average approximately $534 million per year
through 2425. Benefits associated with the Feeder Hardening (EWL) - Distribution
Program discussed in Sections ll and |V(CX1)(b) above, include improved storm
resiliency as well as improved dayto-day reliability.
5. Criteria used to Select and Prioritize the Proqram
As explained above, there are approximately 1,600 feeders remaining to be hardened or
placed underground. FPL attempts to spread its annual projects throughout its service
territory. ln prioritizing the remaining existing feeders to be hardened each year,
18 lt is currently estimated that 100% of FPL's feeders will be hardened or underground by year-
end 2024, with the final costs to be incurred in 2025.
1e See footnote 14.
2017-2019 $1,492 $497
2020-2022 $1,958 $653
2020-2025 $3,206 $534
21
Docket No" 2O200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , Page 26 of 48
considerations include the feeder's historical reliability performance, restoration
difficulties (e.9., environmentally sensitive areas, islands with no vehicle access, river
crossings, etc.), on-going or upcoming internal/external projects (e.9., FPL maintenance
or system expansion projects, municipal overhead/underground conversion project or
municipal road project) and geographic location.
At this time, FPL has not identified any areas where the Feeder Hardening (EWL) -
Distribution Program would not be feasible, reasonable or practical.
D. Lateral Hardening (Undergrounding) - Distribution Program
1. Description of the Proqram and Benefits
ln 2018, FPL implemented a three-year Commission-approved SSUP Pilot. The SSUP
Pilot is a program that targets certain overhead laterals for conversion from overhead to
underground. As part of its SPP, FPL will expand undergrounding laterals in 2021-2029.
Below is an overview of FPL's Lateral Hardening (Undergrounding) '- Distribution
Program and the associated benefits.
a Overuiew of the Distribution Lateral Hardenino Prooram
As part of the SPP, FPL will complete its existing approved three-year SSUP Pilot (in
2020) and expand the application of the SSUP during 2021-2029 to the implementation
of the system-wide Lateral Hardening (Undergrounding) - Distribution Program. The
SSUP Pilot targeted certain overhead laterals that were impacted by recent storms and
that have a history of vegetation-related outages and other reliability issues for conversion
from overhead to underground. Key objectives of the SSUP Pilot included validating
conversion costs and identifying cost savings opportunities, testing different design
philosophies, better understanding customer impacts and sentiments, and identifying
barriers (e.9., obtaining easements, placement of transformers, and attaching entities'
issues).
Two design options are being utilized when FPL converts overhead laterals to
underground, referred to as the North American and the European designs. The North
American design currently is the predominant design, but both undergrounding designs
eliminate all overhead lateral and service wire. The North American design generally
22
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 27 of 48
utilizes more primary conductor and a greater number of smaller-sized transformers, with
less customers per transformer, and is better suited for front lot construction and service.
The European design utilizes more secondary conductor, and a smaller number of larger-
sized transformers, with more customers per transformer, and is better suited for rear lot
construction and service. Where practical, FPL attempts to relocate existing facilities from
the rear of to the front of customers' premises; however, there are instances where that
option is not available (e.9., FPL is unable to obtain easements in front of customers'
premises). FPL's standard design is the North American design (front lot construction),
but FPL is gaining important experience and knowledge from its utilization of the
European design (rear lot construction), which it can then better utilize for future projects
as appropriate.
As part of the conversion process, FPL is also installing meter base adaptors that allow
underground service to be provided to the customer by utilizing the existing meter and
meter enclosure. The meter base adaptors minimize the impact on customer-owned
equipment and facilities. For example, in certain situations, overhead to underground
conversions of electric service can trigger a local electrical code requirement that
necessitates a customer upgrade of the home's electric service panel. This can cost the
customer thousands of dollars. However, by utilizing a meter base adaptor, overall costs
are reduced and customers are able to avoid the need and expense to convert their
electrical service panels.
b. Benefits of the Distribution Lateral Hardeninq Proqram
Laterals make up the majority of FPL's distribution system. For example, system-wide,
there are over 180,000 laterals (including laterals with multi-stage fusing), in contrast to
approximately 3,300 feeders, and there are 1.8 times as many miles of overhead laterals
as there are overhead feeders (approximately 23,000 miles vs. 13,000 miles,
respectively). Additionally, while feeders are predominately located in the front of
customers' premises, many laterals are "rear of' or behind customers' premises. This is
especially the case in older neighborhoods located throughout FPL's service territory.
Generally, facilities in the rear of customers' premises take longer to restore than facilities
in front of customers' premises because rear-located facilities are more difficult to access
23
Docket No. 2O2OO071-E\
FPL'I 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 28 of 48
and are more likely to be near vegetation. This results in a greater amount of CMH being
devoted to laterals during storm restoration.
The basis for FPL's SSUP Pilot and the proposal to expand upon the Pilot under the SPP
is the performance of the underground facilities as compared to overh.ead facilities and
the extensive damage to the overhead facilities caused by vegetation during Hurricanes
Matthew and lrma. This performance was demonstrated by the results of FPL's analysis
referenced above in Section IV(AX1Xb) and contained in the Commission's Review of
Florida's Electric lJtitity Hurricane Preparedness and Restoration Actions in 2018,20 which
is summarized in the table below:
Storm and Faci Laterals Out Total Laterals % Out
Finally, it is important to note that underground facilities also perform better than overhead
facilities on a day-to-day basis.. For example, based on the reliability performance metrics
for overhead and underground facilities provided to the Commission in FPL's February
28,2020 Annual Reliability Report filing, the System Average lnterruption Duration lndex
("SAlDl") for underground facilities is significantly better than hybrid facilities (combination
of overhead and underground) or overhead facilities as shown in the table below:
Year
SAIDI2l
UG OH
20 See footnote 17.
21 See pages 93-97 of FPL's February 28, 2020 Annual Reliability Report filing for more details
on day-to-day reliability performance - overhead vs. underground.
24
rid
82,729 4o/oMatthew OH 3,473
O.2o/oMatthew UG 238 101 ,892
20,341 84,574 24%lrma OH
103,384 4o/olrma UG 3,767
2015 21.4 102.4 60.0
80.4 57.6201617.2
2017 17.7 89.6 55.5
21.2 89.0 54.22018
87.4 49.4201930.3
Docket No. 202OO07|-El
FPL'' 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 29 of 48
2. ActualiEstimated Start and Completion Dates
FPL's SSUP Pilot was initiated in 2018. By the end of 2020, the third and final year of
the SSUP Pilot, FPL expects to have converted a total of 220-230laterals from overhead
to underground, which is consistent with the SSUP Pilot's plan most recently approved in
Docket No. 20180144-El. As part of its SPP, FPL will incorporate, continue, and expand
the SSUP to provide the benefits of underground lateral hardening throughout its system.
After completing the SSUP Pilot in 2020, FPL estimates it will convert 300-700 laterals
annually. ln 2024-2029 FPL estimates it will convert 800-900 laterals annually.
3. Cost Estimates
Estimated lateral undergrounding costs are determined utilizing the length of each lateral,
the average historical lateral undergrounding cost per mile, and updated cost
assumptions (e.9., labor and materials). The table below provides a comparison of the
2018-2019 total actual costs for the SSUP Pilot with lhe 2020-2022 (first three years of
the SPP) total estimated distribution lateral hardening program costs and the 2020-2029
total estimated distribution lateral hardening program costs:
Total Annual Average
ram Gosts millions P m Gosts millions
Fufther details regarding the SPP estimated distribution lateral hardening program costs,
including estimated annual capital expenditures are provided in AppendixC.23
4. Comoarison of Costs and Benefits
As provided in Section IV(DX3) above, during 2020-2029, total costs for FPL's Lateral
Hardening (Undergrounding) - Distribution Program average approximately $510 million
peryear. Benefits associated with the Lateral Hardening (Undergrounding) - Distribution
22The Storm Secure Underground Program Pilotwas initiated in 2018
23 See footnote 14.
2018-201922 $76 $38
2020-2022 $676 $225
2020-2029 $5,101 $51 0
25
Docket No. 2O2O0071-EI
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , Page 30 of 48
Program discussed in Sections ll AND IV(DX1)(b) above, include improved storm
resiliency as well as improved day-to-day reliability
5. Criteria used to Select a d Prioritize the Prooram
FPL will select/prioritize future laterals for conversion to undergrounding based on an
overall feeder pedormance methodology. Rather than selecting individual "stand-alone"
laterals, FPL will underground all the laterals on a feeder such that when a hardened
feeder that has experienced an outage is restored, all associated underground laterals
would also be restored (unless the underground lateralwas damaged).
On average, there are currently 20-30 overhead laterals on a feeder. The selection and
prioritization of the laterals to be converted will be based on a methodology that considers:
(a) all of the overhead laterals on each feeder; (b) outage experience during the recent
Hurricanes Matthew and lrma; (c) the number of vegetation-related outages experienced
over the most recent 10 years; and (d) the total number of lateral and transformer outages
experienced over the most recent 10 years. These overhead lateral factors are totaled
for each feeder, and the feeders are ranked based on these totals. All laterals on the
feeders will then be hardened according to the ranking of each feeder.
ln order to optimize resources and provide lateral hardening throughout FPL's system,
lateral hardening projects will be performed annually in all sixteen (16) of FPL's
management areas. At this time, FPL has not identified any areas where the Lateral
Hardening (Undergrounding) - Distribution Program would not be feasible, reasonable,
or practical. However, in areas that are more prone to flooding or storm surge, FPL will
consider alternative construction methods (e.9., elevating transformer pads).
E. Wood Structures Hardening (Replacing) - Transmission
Program
1 n P ram and Benefi
The Wood Structure Hardening (Replacing) - Transmission Program included in the SPP
is a continuation of FPL's existing transmission hardening program through the end of
2022,when FPL expects that 100% of its transmission structures will be steel or concrete.
26
Docket No. 202O0071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 31 of 4B
Below is an overview of FPL's existing transmission wood structure hardening program
and the associated benefits.
a. Overview of the Transmission Hardeninq Proqram
While FPL's transmission facilities were affected by the 2004 and 2005 storms, the
damage experienced was significantly less than the damage sustained by distribution
facilities. A primary reason for this resulted from the fact that transmission structures were,
at that time, already constructed to meet EWL consistent with Florida Statute 366.04 and
the National Electrical Safety Code, Rule 250 C.
Based on the forensic data collected from the 2004 and 2005 storms, FPL implemented a
Commission-approved transmission storm hardening initiative to replace all wood
transmission structures, which accounted for nearly 70 percent of all transmission
structures replaced during the2004-2005 storm seasons, with steelor concrete structures.
As explained below, this initiative is ongoing and expected to be completed by the end of
2022. As part of its SPP, FPL will continue its initiative to replace allwood transmission
structures with steel or concrete structures.
b. Benefits of the Transmission Hardeninq Proqram
While an outage associated with distribution facilities (e.9., a transformer, lateral, or
feeder) can impact up to several thousands of customers, a transmission-related outage
can result in an outage affecting tens of thousands of customers. Additionally, an outage
on a transmission facility could cause cascading (a loss of power at one transmission
facility can trigger the loss of power on another interconnected transmission facility, which
in turn can trigger the loss of power on another interconnected transmission facility, and
so on) and result in the loss of service for hundreds of thousands of customers. As a
result, the prevention of transmission-related outages is essential. As discussed earlier,
while transmission facilities performed significantly better than distribution facilities during
lhe 2004 and 2005 storms, there were several opportunities for improvement identified,
including the replacement of wood transmission structures. As a result of its transmission
inspection programs and its replacement of wood transmission structures, FPL's
transmission facilities have demonstrated to be more storm resilient.
27
Docket No. 202O0071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-'l, Page 32 of 48
The table below compares the performance of FPL's transmission system for Hurricane
Wilma, which occurred in 2005 before FPL implemented its current transmission
hardening program, and Hurricane lrma, which occurred in 2017 afler FPL implemented
its current transmission hardening program:
Hurricane Wilma Hurricane
lrma
% Line Section Outages 37o/o 17%
Transmission Structure Failures 100 5
(all non-hardened)
Transmission Substations De-energized 241 92
Days to Restore Substation Outages 5 1
As shown above, the impacts on FPL's transmission facilities associated with Hurricane
lrma were significantly reduced from those experienced with Hurricane Wilma, even
though Hurricane lrma's winds were stronger and its path impacted substantially more of
FPL's facilities.
2. Actual/Estimated Start and Completion Dates
FPL implemented its transmission hardening program in 2007. As of year-end 2019,960/o
of FPL's transmission structures, system-wide, were steel or concrete, with less than
2,900 (or 4o/o) wood structures remaining to be replaced. FPL expects to replace the
2,900 wood transmission structures remaining on its system by year-end 2022.
3. Cost Estimates
Estimated/actual annual transmission hardening costs are a function of the number of
poles to be replaced, actual historical replacement costs, and updated cost assumptions
(e.9., labor and materials). The vast majority of the transmission hardening program costs
are capital costs resulting from replacement of the wood transmission structures.
28
Docket No. 20200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 33 of 48
The table below provides a comparison of lhe 2017-2019 total actual transmission
hardening costs with the 2020-2022 (first three years of the SPP) total estimated
transmission hardening costs:24
Total Annual Average
Pro ram Gosts illions P ram Costs millions
Further details regarding the SPP estimated transmission hardening costs, including
estimated annual capitalexpenditures and operating expenses, are provided in Appendix
c.25
4. Comparison of Costs and Benefits
As provided in Section lV(E)(3) above, during 2020-2022, total costs for FPL's Wood
Structure Hardening (Replacing) - Transmission Program average approximately $39
million per year. Benefits associated with the Wood Structure Hardening (Replacing) -
Transmission Program discussed in Sections ll and |V(EX1)(b) above, include improved
storm resiliency.
5. Criteria used to Select and Prioritize the Program
The annual prioritization/selection criteria for the remaining wood structures to be
replaced includes proximity to high wind areas, system importance, customer counts, and
coordination with other storm initiatives (e.9., distribution feeder hardening). Other
economic efficiencies, such as opportunities to perform work on multiple transmission line
sections within the same transmission corridor, are also considered.
At this time, FPL has not identified any areas where the replacement of the remaining
wood transmission structures under the Wood Structure Hardening (Replacing) -
Transmission Program would not be feasible, reasonable or practical.
24 FPL expects that 100% of the remaining wood transmission structures in its system will be
replaced by year-end 2022.
25 See footnote 14.
2017-2019 $162 $54
2020-2022 $1 18 $3e
29
Docket No. 20200071-El
FPL'9 2O2O-2O29 Storm Protection Plan
Exhibit MJ-1, Page 34 of 4B
F. Substation Storm Surge/FIood Mitigation Program
1. Description of the Proqram and Benefits
The Substation Storm Surge/Flood Mitigation Program is the only new program included
in FPL's SPP. As explained below, Substation Storm Surge/Flood Mitigation Program is
a new program to mitigate damage at several targeted distribution and transmission
substations that are susceptible to storm surge and flooding during extreme weather
events.
Historically, several FPL distribution and transmission substations have been impacted
by storm surge and/or flooding as a result of extreme weather conditions. For example,
as a result of flooding caused by Hurricanes Matthew and lrma, FPL's St. Augustine
substation was required to be proactively de-energized (i.e., shut down before water
reached levels that would cause significant damage to powered substation equipment).
Another example is FPL's South Daytona substation that was proactively de-energized
during Hurricane lrma as a result of flooding. While proactively de-energizing those
substations impacted by storm surge and/or flooding helps reduce damage to substation
equipment, FPL is still required to implement both temporary flood mitigation efforts and
repairs to substation facilities and equipment that become flooded as a result of extreme
weather conditions.
An outage associated with distribution substations can impact up to several thousands of
customers, and an outage associated with a transmission substation can result in an
outage affecting tens of thousands of customers. Flooding and the need to proactively
de-energize substations located in areas susceptible to storm surge and flooding can
result in significant customer outages. For example, the flooding and de-energization of
St. Augustine and South Daytona during Hurricane lrma resulted in more than 8,000
customer outages. Therefore, the prevention of outages at transmission and distribution
substations due to storm surge or flooding is essential.
To prevent/mitigate future substation equipment damage and customer outages due to
storm surge and flooding, FPL's new Substation Storm Surge/Flood Mitigation Program
will target and harden certain substations located in areas throughout FPL's service
30
Docket No. 202OO071-E\
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 35 of 48
territory that are susceptible to storm surge or flooding during extreme weather events.
Specifically, FPL plans to raise the equipment at certain substations above the flood level
and construct flood protection walls around other substations to prevent/mitigate future
damage due to storm surge and flooding.
2. Actual/Estimated Start and Completion Dates
At this time, FPL has identified between 8-10 substations where it initially plans to
implement storm surge/flood mitigation measures over the next three years (2020-2022).
FPL plans to initiate construction in late summer/early fall 20201o raise the equipment at
the St. Augustine substation, which is expected to be completed in 2O21. ln 2021 and
early 2022, FPL also plans to begin construction on flood protection walls for the other 7-
9 substations identified for mitigation, which is expected to be completed by 2022.
3. Cost Estimates
The storm surge/flood mitigation costs associated with St. Augustine substation (raising
substation equipment) are estimated to be approximately $10 million in total (2020 and
2021). Estimated storm surge/flood mitigation costs for the remaining 7-9 substations
identified at this time (constructing surrounding flood walls) are estimated to be
approximately $13 million in total (2021 and2022). See the table below the estimated
annual program costs:
Total Annual Average
P m Gosts millions m Costs illions
Further details regarding the SPP estimated storm surge/flood mitigation costs, including
estimated annualcapitalexpenditures and operating expenses, are provided in Appendix
c.26
4. Comparison of Costs and Benefits
As provided in Section lV(F)(3) above, during 2020-2022, total costs for FPL's Substation
Storm Surge/Flood Mitigation Program average approximately $8 million per year.
2020-2022 $23 $a
26 See footnote 14
31
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , Page 36 of 48
Benefits associated with this program discussed in Section |V(FX1) above, include
improved storm resiliency (avoiding storm surge/flood damage), reduced customer
outages and storm restoration costs.
5. Criteria used to Select and Prioritize Proiects
The annual prioritization/selection criteria for the targeted substations is based on FPL's
historical storm surge/flood experience, in particular, Hurricanes Matthew and lrma. At
this time, for the targeted substations, FPL has not identified any areas where the
upgrades would not be feasible, reasonable or practical.
Lr,Vegetation Management - Distribution Program
1. Descriotion of the P ram and Benefits
The Vegetation Management - Distribution Program included in the SPP is a continuation
of FPL's existing Commission-approved Vegetation Management - Distribution Program.
Below is an overview of FPL's existing Vegetation Management - Distribution Program
and the associated benefits.
a Overview of the Veoetation Alanaoemenf - Disfribufion
Proqram
Prior to 2006, FPL's Vegetation Management - Distribution Program consisted of
inspecting and maintaining its feeders on a three-year average trim cycle and performing
targeted trimming on ceftain feeders more frequently (e.9., targeting vegetation with faster
growth rates and palm trees) through its "mid-cycle" program. Lateral trimming was
prioritized based on reliability performance. Another important component of this program
was FPL's "Right Tree Right Place" initiative, which provided information to educate
customers on FPL's vegetation management program and practices, safety issues, and
the importance of placing trees in the proper location.
After the 2004-2005 storm seasons, the Commission determined that the "vegetation
management practices of the investor-owned electric utilities do not provide adequate
assurance that tree clearances for overhead distribution facilities are being maintained in
a manner that is likely to reduce vegetation related storm damage. We believe that
32
Docket No. 2020O071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 37 of 4B
utilities should develop more stringent distribution vegetation management programs."27
As result, FPL proposed and the Commission approved the continuation of FPL's system-
wide three-year average trim cycle for feeders, mid-cycle targeted trimming for certain
feeders, and its Right Tree Right Place initiative, as well as the implementation of a new
six-year average trim cycle for laterals.28 These same initiatives, which have provided
storm and day{o-day reliability benefits, remain in place today.
Tree limbs and branches, especially palm fronds, are among the most common causes
of power outages and momentary interruptions during both dayto-day operations and
storm events. The primary objective of FPL's Vegetation Management - Distribution
Program is to clear vegetation in areas where FPL is permitted to trim from the vicinity of
distribution facilities and equipment in order to provide safe, reliable, and cost-effective
electric service to its customers. The program is comprised of multiple initiatives
designed to reduce the average time customers are without electricity as a result of
vegetation-related interruptions. These include preventive maintenance initiatives
(planned cycle and mid-cycle maintenance), corrective maintenance (trouble work and
service restoration efforts), customer trim requests, and support of system improvement
and expansion projects, which focus on long{erm reliability by addressing vegetation that
will impact new or upgraded overhead distribution facilities.
FPL's Vegetation Management Distribution Program's practices follow the NESC, the
American National Standards lnstitute ("ANSl") A-300, and all other applicable standards,
while considering tree species, growth rates, and the location of trees in proximity to FPL's
facilities. Danger or hazard trees (leaning, structurally damaged, or diseased/dead that
have a high likelihood to fail and impact FPL's facilities) located outside of right-of-way
("ROW"), which cannot be trimmed without approval from the property owner, are
identified as candidates for customer-approved removal.
Finally, a very important component of FPL's vegetation program is providing information
to customers to educate them on the company's trimming program and practices, safety
issues, and the importance of placing trees in the proper location - FPL's "Right Tree,
27 See Order No. PSC-06-0351-PAA-El
28 See Order No. PSC-07-0468-FOF-El
33
Docket No. 2020007l-El
FPL'S 2O2O-2O29 Storm Protection Plan
Exhibit MJ-1 , Page 38 of 4B
Right Place" initiative. Right Tree, Right Place is a public education program based on
FPL's core belief that providing reliable electric service and sustaining the natural
environment can go hand-in-hand and is a win-win partnership between the utility and its
customers.
The SPP will continue FPL's currently-approved distribution vegetation program, which
includes the following system-wide vegetation management activities: three-year cycle
for feeders; mid-cycle targeted trimming for certain feeders; six-year cycle for laterals;
and continued education of customers through its Right Tree, Right Place initiative.
b. Benefits of the Veqetation Manaoement Distribution
Proqram
ln Order No. PSC-07-0468-FOF-EI, the Commission confirmed that FPL should continue
to implement three-year and six-year average cycles for its feeders and laterals because
the cycles complied with the Commission's storm preparedness objectives to increase
the level of trimming over historical levels, promote system reliability and reduce storm
restoration costs.2e Additionally, Commission's orders indicated that FPL's proposed
cycles: were cost-effective; would improve dayto-day "tree SAlFl" from 0.22to 0.16 in
ten years;so and would provide savings when comparing savings on a customers
interrupted ("C1") per storm basis. Further, day-to-day distribution tree SAIFI has
significantly improved as a result of FPL implementing its approved distribution vegetation
management program (from 0.20 prior to the 2004-2005 storm seasons to 0.08 at year-
end 2019).
Finally, another indication that the current program is providing benefits is that, while
forensic analysis indicated vegetation was the ovenryhelming primary cause for pole and
wire failures and a significant cause of outages during Hurricanes Matthew and lrma, the
vast majority of damage resulted from uprooted trees, broken trunks, and broken limbs
2e FPL's proposed three-year and six-year cycles were initially approved in Order No. PSC-06-
O7B1-PAA-EI.
30 The tree-related SAIFI has averaged less than 0.09 over the last few years.
34
Docket No. 20200071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1, Page 39 of 48
thatfell into distribution facilities from outside of right-of-way, i.e., beyond where FPL is
currently allowed trim without approvalfrom the property owner.
2. ActualiEstimated Start and Completion Dates
FPL's ongoing vegetation management plan was originally approved in 2007, and
remains in place today. Under the SPP, FPL plans to inspect and maintain, on average,
approximately 15,200 miles annually, including approximately 11,400 miles for feeders
(cycle and mid-cycle) and 3,800 miles for laterals. This is comparable to the
approximately 15,200 miles inspected and maintained annually, on average, for 2017-
2019.
3. Cost Estimates
The vast majority of vegetation management costs are associated with cycle and mid-
cycle trimming, which is performed by several FPl-approved contractors throughout
FPL's system. Other vegetation management costs include costs associated with day-
to-day restoration activities (e.9., summer afternoon thunderstorms), removals, debris
cleanup, and support (e.g., arborists, supervision, back office support). Costs associated
with vegetation management are generally operating expenses.
The table below provides a comparison of the 2017-2019 total actual distribution
vegetation management costs with the 2020-2022 (first three years of the SPP) total
estimated distribution vegetation management costs and the 2020-2029 total estimated
distribution vegetation management costs:31
Total Annual Average
Pro ram Costs millions P ram Costs illions
Further details regarding the SPP estimated distribution vegetation management costs,
31 The vegetation management costs shown in the table below exclude storm-related vegetation
management costs.
2017-2019 $1 89 $63
2020-2022 $1 83 $61
2020-2029 $5e6 $60
35
Docket No. 20200071-El
FPL'i 2020-2029 Storm Protection Plan
Exhibit MJ- 1 , Page 40 of 48
including estimated annualcapital expenditures and operating expenses, are provided in
Appendix C.32
4. Comparison of C osts and Benefits
As provided in Section |V(GX3) above, during 2020-2029, totalcosts for FPL's Vegetation
Management - Distribution Program average approximately $60 million per year.
Benefits associated with the Vegetation Management - Distribution Program discussed
in Sections ll and |V(GX1Xb) above, include increased storm resiliency.
5. Criteria Used to Select and Prioritize the Proqram
The primary reason for maintaining feeders on a three-year average cycle, as opposed
to a six-year average cycle for laterals, is that a feeder outage can affect, on average,
approximately 1,500 customers as compared to an outage on a lateral line that can affect,
on average, approximately 35 customers. FPL enhances its approved feeder inspection
and trimming plan through its mid-cycle trimming program, which encompasses patrolling
and trimming feeders between planned maintenance cycles to address tree conditions
that may cause an interruption prior to the next planned cycle trim. Mid-cycle work units
typically have a trim age of 12to 18 months and usually involve certain fast-growing trees
(e.g., palm trees) that need to be addressed before the next scheduled cycle trim date.
Additionally, customers often contact FPL with requests to trim trees around distribution
lines in their neighborhoods and near their homes. As a result of these discussions with
customers and/or a follow-up investigation, FPL either performs the necessary trimming
or determines that the requested trimming can be addressed more efficiently by
completing it through the normal scheduled cycle trimming.
Cycle trimming is prioritized annually to ensure compliance with cycle schedules. At this
time, FPL has not identified any areas where the Vegetation Management - Distribution
Program would not be feasible, reasonable or practical.
32 See footnote 14
36
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 41 of 4B
H. Vegetation Management - Transmission Program
1. Description of the Proqram and Benefits
The Vegetation Management - Transmission Program included in the SPP is a
continuation of FPL's existing transmission vegetation management program. Below is
an overview of FPL's existing transmission vegetation management program and the
associated benefits.
a. Overview of the Veqetation Manaqement - Transmission
Proeram
The North American Electric Reliability Corporation's (NERC) vegetation management
standards/requirements serve as the basis for FPL's transmission vegetation
management program. The reliability objective of these standards/requirements is to
prevent vegetation-related outages that could lead to cascading by utilizing effective
vegetation maintenance while recognizing that ceftain outages such as those due to
vandalism, human errors, and acts of nature are not preventable. Transmission lines that
must conform with these standards/requirements include lines operated at or above 200
kV or any line that is either an element of the lnterconnection Reliability Operating Limit
(IROL) or the Western Electricity Coordinating Council (WECC).
For FPL, just over 4,300 miles of its transmission system (or nearly twothirds of all of
FPL's total transmission system) are subject to NERC's vegetation management
standards/requirements. NERC's vegetation management standardsirequirements
include annual inspection requirements, executing 100% of a utility's annual vegetation
work plan, and to prevent any encroachment into established minimum vegetation
clearance distances ("MVCD').
The key elements of FPL's transmission vegetation management program are to inspect
the transmission right-of-ways, document vegetation inspection results and findings,
prescribe a work plan, and execute the work plan.
FPL conducts ground inspections of all transmission corridors annually for work planning
purposes. During these inspections, FPL identifies vegetation capable of approaching
the defined Vegetation Action Threshold ('VAT'). VAT is a calculated distance from the
37
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , Page 42 o'f 48
transmission line that factors in MVCD, conductor sag/sway potential, and a buffer. The
identified vegetation is given a work prescription and then prioritized and organized into
batches of work, which collectively become the annual work plan.
For transmission lines that are subject to NERC's vegetation management
standards/requirements, FPL also uses a technology called 'LiDAR," shott for light
detection and ranging. L|DAR is a remote sensing technology that uses light in the form
of a pulsed laser to measure ranges (distances) to a target. For vegetation management
purposes, L|DAR is used to measure distance between vegetation and transmission lines.
L|DAR patrols are conducted annually for all NERC transmission corridors. Data
collected by the L|DAR patrols is then used to develop annual preventative and reactive
work plans.
ln its SPP, FPL will continue its current transmission vegetation management plan, which
includes visual and aerial inspections of all transmission line corridors, LiDAR inspections
of NERC transmission line corridors, developing and executing annual work plans to
address identified vegetation conditions, and identifying and addressing priority and
hazard tree conditions prior to and during storm season.
b. Benefits of the Veqetation oement Transmission
Program
The benefits of a Vegetation Management - Transmission Program are self-evident and
the consequences of not having a reasonable transmission vegetation management plan
can be extreme. As discussed previously, the transmission system is the backbone of
the electric grid. While outages associated with distribution facilities (e.9., a transformer,
lateral, or feeder) can result in an outage affecting anywhere from a few customers up to
several thousands of customers, a transmission related outage can affect tens of
thousands of customers. Additionally, an outage on a transmission facility could cause
cascading and result in the loss of service for hundreds of thousands of customers. As
such, it is imperative that vegetation impacting transmission facilities be properly
maintained using reasonable and appropriate cycles and standards to help ensure they
are prepared for storms. For these reasons, it is no surprise that NERC has developed
38
Docket No. 2O2O0071-EI
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 43 of 48
prescriptive vegetation management requirements for transmission facilities to help
prevent such damage from occurring.
FPL also notes that while vegetation-related damage and transmission line outages
occurred during Hurricanes Matthew and lrma, the vast majority of such
damages/outages were caused by vegetation located outside of the right-of-way, i.e.,
beyond where FPL is currently allowed to trim without approval from the property owner,
which further demonstrates that FPL's historical efforts in this area have been beneficial.
2. Actual/Estimated Start and Completion Dates
FPL's Vegetation Management - Transmission Program is an ongoing program, initiated
decades ago. Under the SPP, FPL plans to inspect and maintain, on average,
approximately 7,000 miles annually, including approximately 4,300 miles for NERC
transmission line corridors and 2,70O miles for non-NERC transmission line corridors.
This is comparable to the approximately 7,000 miles inspected and maintained annually,
on average, for 2017-2019.
3. Cost Estimates
The vast majority of vegetation management costs are associated with annual inspections
and the execution of planned work to address identified conditions, which is performed
by several FPL approved contractors throughout FPL's system. Other vegetation
management costs include costs associated with day-to-day restoration activities (e.9.,
summer afternoon thunderstorms), removals, debris cleanup, and support (e.9., arborists,
supervision, back office support). Costs associated with vegetation management are
generally operating expenses.
The table below provides a comparison of the 2017-2019 total actual transmission
vegetation management costs with the 2020-2A22 (first three years of the SPP) total
estimated transmission vegetation management costs and the 2020-2029 totalestimated
transmission vegetation management costs:33
33 The vegetation management costs shown in the table below exclude storm-related vegetation
management costs.
39
$27 $g2017-2019
$g2020-2022 $zt
2020-2029 $e6 $10
Docket No. 202O0071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 44 ol 48
Annual Average
illions Gosts illions
Further details regarding the SPP estimated transmission vegetation management costs,
including estimated annualcapital expenditures and operating expenses, are provided in
Appendix C.3a
4. Comparison of Costs and Benefits
As provided in Section |V(HX3) above, during 2020-2029, totalcosts for FPL's Vegetation
Management - Transmission Program average approximately $10 million per year.
Benefits associated with the Vegetation Management - Transmission Program discussed
in Sections ll and |V(HX1Xb) above, include increased storm resiliency. The execution
of FPL's Vegetation Management - Transmission Program is a significant factor in
mitigating damage to transmission facilities and avoiding transmission-related outages.
5. Criteria used to Select and Prioritize the Proqrams
Priority vegetation conditions and hazard tree conditions are completed annually prior to
storm season. Additionally, prior to and during the storm season, FPL conducts aerial
inspections of transmission corridors to identify hazard trees and any priority vegetation
Iocations. Priority vegetation conditions and hazard tree conditions identified through
aerial inspections are addressed as soon as possible.
At this time, FPL has not identified any areas where the Vegetation Management -
Transmission Program would not be feasible, reasonable or practical.
Total
ram Costs
3a See footnote 14.
40
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 45 of 4B
V. Detailed lnformation on the First Three Years of the SPP
2020-2022
A. Detailed Description for the First Year of the SPP (20201
The following additional information required by Rule 25-6.030(3XeX1), F.A.C., for the
first year of the SPP (2020) is provided in Appendix E. (1) the actual or estimated
construction start and completion dates; (2) a description of the affected existing facilities,
including number and type(s) of customers served, historic service reliability performance
during extreme weather conditions, and how this data was used to prioritize the storm
protection projects; (3) a cost estimate including capital and operating expenses. A
description of the criteria used to select and prioritize the storm protection programs is
included in the description of each SPP program provided in Section IV.
Detailed Description of the Second and Third Years of the
sPP (2021-20221
Additional details required by Rule 25-6.030(3XeX2), F.A.C., for the second and third
years of the SPP (2021-2022), including the estimated number and costs of projects
under every program, is provided in in Appendix C.
Detailed Description of the Vegetation Management
Activities for the First Three Years of the SPP (2020-20221
The following additional information required by Rule 25-6.030(3Xf), F.A.C., for the first
three years of the vegetation management activities under the SPP (2020-2022) is
provided in n Sections IV(G) and lV(H) above and Appendix C: the projected frequency
(trim cycle); the projected miles of affected transmission and distribution overhead
facilities; the estimated annual labor and equipment costs for both utility and contractor
personnel. A description of how the vegetation management activities will reduce outage
times and restoration costs due to extreme weather conditions is provided in Sections
lV(G) and lV(H) above.
B
c
41
Docket No. 20200071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , Page 46 of 48
Vl. Estimate of Annual Jurisd ictional Revenue Reouirements
for the 2020-2029 SPP
Pursuant to Rule 25-6.030(3X0, F.A.C., the table below provides the estimated annual
jurisdictional revenue requirements for each year of the SPP.
Estimated Annual
Revenue
Requirements
illions
While FPL has provided estimated costs by program as of the time of this filing and
associated total revenue requirements in its SPP, consistent with the requirements of
Rule 25-6.030, F.A.C., subsequent projected and actual program costs submitted for cost
recovery through the Storm Protection Plan Cost Recovery Clause (per Rule 25-6.031,
F.A.C.,) could vary by as much as 10-15%, which would then also impact associated
estimated revenue requirements and rate impacts. The projected costs, actual/ estimated
costs, actuals costs, and true-up of actual costs to be included in FPL's Storm Protection
$257.62020
2021 $369.1
$494.32022
$625.52023
2024 $760.9
2025 $878.1
2026 $963.7
2027 $1,037.1
2028 $1,110.9
2029 $1 ,185.2
42
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1, Page 47 of 48
Plan Cost Recovery Clause will all be addressed in subsequent filings in separate storm
protection plan cost recovery clause dockets pursuant to Rule 25-6.031, F.A.C.35
Vll. Estimated Rate lmoacts for Fi rst Three Years of the SPP
(2020-20221
FPL anticipates the programs included in the SPP will have zero bill impacts on customer
bills during the first year of the SPP and only minimal bill increases for years two and
three of the SPP. An estimate of hypothetical overall rate impacts for the first three years
of the SPP (2020-2022), without regard for the fact that FPL remains under a general
base rate freeze pursuant to a Commission-approved settlement agreement through
December 31 ,2021, as stated in footnote 36 below are based on the total program costs
reflected in this filing.36 The projected costs, actual/estimated costs, actuals costs, and
true-up of actual costs to be included in FPL's Storm Protection Plan Cost Recovery
Clause willall be addressed in subsequent filings in Storm Protection Plan Cost Recovery
Clause dockets pursuant to Rule 25-6.031, F.A.C.37
Pursuant to Rule 25-6.031, F.A.C., FPL has not identified any reasonable implementation
alternatives that could mitigate the resulting rate impact for each of the first three years
of the SPP. As explained above, FPL's SPP is largely a continuation of existing
Commission-approved storm hardening programs and initiatives, which have already
demonstrated that they have and will continue to provide increased T&D infrastructure
resiliency, reduced restoration time, and reduced restoration costs when FPL's system is
impacted by severe weather events. Further, as explained above, the estimated costs
35 The Commission has opened Docket No. 20200092-El to address Storm Protection Plan Cost
Recovery Clause petitions to be filed the third quarter of 2020.
36 Pursuant to Rule 25-6.030(3)(h), F.A.C., the hypothetical rate impacts for FPL's typical
residential, commercial, and industrial customers for the first three years of the SPP (2020-2022)
without regard for the fact that FPL remains under a general base rate freeze pursuant to a
Commission-approved settlement agreement through December 31,2021, are as follows for
2020, 2021, and 2022, respectively: Residential (RS-1) $0.00251/kwh, $0.00357/kwh, and
$0.00478/kWh; Commercial (GSD-1) $0.81/kW, $1.1s/kw, and $1.54/kW; and Industrial
(GSLDT-3) $0.05/kW, $0.08/kW and $0.10/kW. These rate impacts are for all programs included
in the SPP and are based on the total estimated costs as of the time of this filing, which could
vary by as much as 10% to 15o/o, regardless of whetherthose costs will be recovered in FPL's
Storm Protection Plan Cost Recovery Clause or through base rates.
37 See footnote 34.
43
Docket No. 2O2O0071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , Page 48 of 48
for the programs included in FPL's SPP are consistent with the historical costs incurred
for the existing storm hardening and storm preparedness programs, which were most
recently approved in FPL's 2019-2021Storm Hardening Plan.
Vlll. Conclusion
The Florida Legislature has determined that it is in the State's interest to "strengthen
electric utility infrastructure to withstand extreme weather conditions by promoting the
overhead hardening of distribution and transmission facilities, undergrounding of certain
distribution lines, and vegetation management," and for each electric utility to "mitigate
restoration costs and outage times to utility customers when developing transmission and
distribution storm protection plans." Section 366.96(1), F.S. Based on these findings, the
Florida Legislature concluded that it is in the State's interest for each electdc utility to
develop and file a SPP for the overhead hardening and increased resilience of electric
T&D facilities, undergrounding of electric distribution facilities, and vegetation
management. See Sections 366.96(1)-(3).
FPL's SPP is a systematic approach to achieve the legislative objectives of reducing
restoration costs and outage times associated with extreme weather events and
enhancing reliability. As explained above, FPL's SPP is largely a continuation and
expansion of its existing and already successful storm hardening and storm preparedness
programs previously approved by the Commission, as well as a new storm hardening
program to harden certain targeted substations that are susceptible to storm surge or
flooding during extreme weather events. Based on the recent experiences of Hurricanes
Matthew and lrma, the existing storm hardening programs have a demonstrated and
proven track record of mitigating and reducing restoration CMH, outage times, and storm
restoration costs, as well as improving day-to-day reliability. FPL's SPP will continue and
expand these important benefits to customers and the State.
44
Docket No. 2O2OOO71-E\
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 1 of 18)
APPENDIXA
(FPL's 3rd Supplemental Amended Response to
Staffs lst Data Request)
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 2 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 1 of9
OUESTION:
Please complete the table below summarizing hardened facilities that required repair or
replacement as a result of Hurricanes Matthew, Hermine, Irma, Maria, and Nate.
RESPONSE:
FPL does not maintain its accounting records at the level of detail required to provide the
requested information as they do not differentiate hardened facilities from non-hardened
facilities, nor do they track which assets were repaired. However, FPL does track certain assets,
at the total system level, that were requested and replaced during each hurricane as reflected in
the tables below. Note, FPL did not track storm repairs/replacements for Hurricanes Maria and
Nate as Hurricane Maria did not impact FPL's service territory and Nate had limited impact.
Also, Hunicanes Matthew and Irma capital details associated with follow-up work are not yet
available by plant account as these costs have not yet been unitized from account 106 to account
l0l by plant account.
Hurricane Matthew Number of Facilities Requiring
Repair Replacement
Transmission
Structures N/A 0
Substations N/A 0
Total N/A 0
Distribution
Poles N/A 656
Substation N/A 0
Feeder OH N/A 0
Feeder UG N/A 0
Feeder Combined N/A 0
Lateral OH N/A N/A
Lateral UG N/A N/A
Lateral Combined N/A N/A
Total N/A N/A
Service
Service OH N/A N/A
Service UG N/A N/A
Service Combined N/A N/A
Total N/A N/A
Docket No. 202O0071-El
FPL'i 2020-2029 Storm Protection Plan
Exhibit MJ-'l, APPENDIX A (Page 3 of 1B)
Florida Power & Light Company
Docket No. 20170215'EU
Staff s First Data Request
Request No. 29 - Third Supplemental Amended
Page2 of9
Hurricane Hermine Number of Facilities Requiring
Repair Replacement
Transmission
Structures N/A 0
Substations N/A 0
Total N/A 0
Distribution
Poles N/A 19
Substation N/A 0
Feeder OH N/A 0
Feeder UG N/A 0
Feeder Combined N/A 0
Lateral OH N/A N/A
LateralUG N/A N/A
Lateral Combined N/A N/A
Total N/A N/A
Service
Service OH N/A N/A
Service UG N/A N/A
Service Combined N/A N/A
Total N/A N/A
Docket No. 2020O071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 4 of 1B)
Florida Power & Light Company
Docket No.20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 3 of9
Hurricane Irma Number of Facilities Requiring
Repair Replacement
Transmission
Structures N/A 0
Substations N/A 0
Total N/A 0
Distribution
Poles N/A 3,562
Substation N/A 0
Feeder OH N/A 0
Feeder UG N/A 0
Feeder Combined N/A 0
Lateral OH N/A N/A
Lateral UG N/A N/A
Lateral Combined N/A N/A
Total N/A N/A
Service
Service OH N/A N/A
Service UG N/A N/A
Service Combined N/A N/A
Total N/A N/A
Notes:
For Huricane Matthew, there is a difference of 248 poles between what is provided in this
discovery response for total poles replaced (656 poles) and what is provided in FPL's post-storm
forensic review report for Hurricane Matthew (provided in FPL's response to Staff s Second
Data Request No. 2 in this same docket) for poles that failed and needed to be replaced to restore
seruice (408 poles). The difference is associated with poles replaced during "follow-up" - i.e.,
poles that were damaged (e.g., a cracked pole) as a result of the storm and needed to be replaced
to restore the pole to its pre-storm condition - but did not fail during the storm and, thus, did not
need to be replaced to restore service. As mentioned above in FPL's response to this data
request, FPL's accounting records do not differentiate hardened facilities from non-hardened
facilities and FPL did not track or maintain forensic information on the 248 distribution poles
replaced as a result of follow-up work. As a result, FPL does not have a hardened vs. non-
hardened breakdown for the 248 distribution poles replaced during follow-up work.
Docket No. 20200071-El
FPL'I 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 5 of 18)
tr'lorida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 4 of9
The distribution pole and transmission structure counts provided above represent the amount of
pole/structure replacements FPL has recorded on its books and records associated with Hurricane
IrmaasofDecember3l,20lT. Theseamountsshouldbeconsideredpreliminaryatthistimeas
they are subject to change (e.g., the counts do not reflect poles that will be replaced during
follow-up work, which has yet to be completed).
N/A - Information is not available at this level of detail in FPL's accounting records.
For substations and feeders, FPL has stated 0 since no entire substation or feeder was replaced.
However, these facilities consist of many pieces of equipment (e.g., wire, cable, breakers,
transformers, cross arms and arrestors) some of which may have been replaced.
20 1 6/20 1 7 Hu rricanes - FPL Restoration/Infrastructu re Perform ance
FPL's infrastructure/restoration performance for Huricanes Matthew (2016) and Irma (2017)
demonstrates that the implementation and execution of its FPSC-approved (1) ten storm
preparedness initiatives (which includes vegetation management): (2) pole inspection programs;
(3) storm hardening plans; and (4) tariffs to incent municipal overhead to underground
conversions have provided great benefits to FPL's customers and to the State of Florida.
During 2016 and 2017, FPL's service territory was threatened with massive Category 4 and 5
storms. The size and scale of these storms impacted FPL's infrastructure throughout its entire
service territory (which encompasses 35 counties in the State of Florida). For both Matthew and
Irma, FPL's infrastructure storm resiliency and smart grid investments resulted in improved
infrastructure resiliency performance and reduced restoration times.
201 612017 ffrrrricanes -Performance
FPL saw significant improvements in overall restoration results. As can be seen in the table
below, restoration results for Hurricanes Matthew and Irma show significant improvement vs.
Hunicane Wilma. FPL attributes these significant improvements in restoration to the investments
made to make its system smarter and more storm-resilient as well as its well-tested restoration
processes. This includes FPL's distribution and transmission storm hardening and storm
preparedness initiatives, pole inspection programs, smart grid initiatives, vegetation management
programs and continuous efforts to improve its restoration processes.
Customer Outases 3.2M 1.2M 4.4M
% Restored / davs s0%/s 99%/2 so% h
All restored / davs 18 4 10
Avg. to restore / davs 5.4 <1 2.r
Docket No. 2020O071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 6 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 5 of9
201612017 Hurricanes -Performance
To assess the effectiveness of FPL's infrastructure storm hardening investments, the Company
utilizes information collected through post-storm forensic data collection and various systems
(e.g., FPL's outage management system) to conduct post-storm infrastructure performance
analysis. These efforts and analysis allow FPL to quantify and assess its distribution and
transmission infrastructure performance including the performance of: hardened and non-
hardened facilities; overhead and underground facilities; and smart grid performance. For
distribution, this includes reviewing the storm performance of poles, feeders and laterals. For
transmission, this includes reviewing the storm performance of poles/structures, line sections
and substations. The data demonstrates that hardened infrastructure performed better than non-
hardened infrastructure, underground facilities performed better than overhead facilities and
smart grid devices prevented a significant number of outages from occurring'
Distribution/Transmission Poles/ Structures Performance
The performance of FPL's approximately 1.2 million distribution and transmission
poles/structures during Hurricanes Matthew and Irma was excellent, as hardened poles and
structures performed as expected by minimizing outages and reducing restoration times. The
total number of dislribution/transmission poles that failed (i.e., had to be repaired/replaced in
order to restore service) during Hurricanes Matthew and Irma was a mere fraction of lo/o of the
1.2 million pole/structure pole population.
Additionally, hardened distribution and transmission pole performance was significantly better
than non-hardened pole performance, as hardened pole failures were either non-existent (e.g.,
Hurricane Matthew) or significantly less than non-hardened pole failures (e.g., during Hurricane
Irma, hardened feeder poles had a 0.02Yo failure rate, while non-hardened feeder poles had a
0.20% failure rate). Also, total poles replaced (i.e., poles that failed + poles that were replaced
during follow-up work) were also a mere fraction of lo/o of the total pole population and
significantly less than the number of poles replaced during Huricane Wilma.
FPL notes that for Hurricanes Matthew and Irma, while it did track hardened vs. non-hardened
pole performance during restoration, it did not track poles replaced (hardened vs. non-hardened)
during follow-up work, since these poles had accomplished their intended purpose of not failing
during the storms. Therefore, FPL cannot provide the number of hardened poles replaced during
follow up work in Hurricanes Matthew and Irma. Based on the performance of hardened poles
that failed during these storms (see table below), it is highly unlikely that there would be a
significant number of hardened poles, if any, that needed to be replaced during follow-up work.
However, going forward, should the Commission want FPL to track replacement of hardened
vs. non-hardened poles during follow-up work, FPL will begin to track this information.
FPL attributes this excellent pole performance to its FPSC-approved distribution and
transmission storm hardening plan initiatives (e.g., extreme wind load construction standards for
distribution poles and replacing wood transmission poles/structures) and its pole inspection
programs.
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 7 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs tr'irst Data Request
Request No. 29 - Third Supplemental Amended
Page 6 of9
Distribution P oles l2l3 1 I l7
Total Number
Total Hardened
1,188,202
t24,5lg*
* This number is understated as it includes only poles hardened as a result of FPL's approved
hardening plan projects, as FPL does not track or maintain the number of hardened poles
installed as a result of new construction (e.g., new feeders or laterals) andlor daily work activities
(e.g., maintenance, pole line extensions, relocation projects). There are also other existing poles
throughout FPL's service territory that would currently meet the NESC's extreme wind loading
criteria and therefore qualii/ as a hardened pole, however, FPL does not currently track or
maintain that information.
*Broken/Fallen poles that must be repaired/replaced to restore service
Transmission Pole/Structures l2l3 L I l7
Total
Concrete
Wood
66,685
60,694 (91%)
5,991 (9%)
*Broken/Fallen poles that must be repaired/replaced to restore service
Distribution Feedersllaterals Performance
As demonstrated below, FPL's hardened feeders performed significantly better than non-
hardened feeders and underground feeders/laterals performed significantly better than overhead
feeders/laterals. Performance was compared considering feeder and lateral outages that occurred
during Hurricanes Matthew and Irma. It is also important to note that during Hurricane Irma, the
Construction Man Hours ("CMH") to restore hardened feeders was 50% less than non-hardened
feeders, primarily due to hardened feeders experiencing less damage than non-hardened feeders.
It is important to note that the majority of outages for overhead facilities resulted from trees that
broke andlor fell into FPL's facilities. Many of these trees were outside of easements or public
rights of way where FPL is generally allowed to trim. As a result, no additional amount of
Matthew - 2016 0 408 408
lrma-2OL7 26 2834 2860
Matthew - 2016 n 0 0
lrma - 2Ot7 0 5 5
Docket No. 20200071-El
F PL's 2O2O-2O29 Storm Protection Plan
Exhibit MJ-1, APPENDIX A (Page 8 of 18)
Florida Power & Light Company
f)ocket No. 20170215-EU
Staff s First Data Request
Request No. 29 - Third Supplemental Amended
Page 7 of 9
traditional tree trimming would help mitigate this issue. Tree damage was particularly impactful
on FPL laterals.
The two tables below provide feeder and lateral outage performance statistics for Hurricanes
Matthew and Irma.
Pop : poputuaton; Lateral population includes laterals witl-r rnulti-stage fusing
Pop : Population; Latelal population includes laterals with multistage fusing
FPL notes that, overall, for Hurricane Irma, many more laterals experienced outages compared to
feeders, thus laterals required significantly more time to restore (871,000 CMH) compared to
feeders (170,000 CMH). FPL continues to promote its Right Tree Right Place initiative and
recommends there be changes to state laws and/or local ordinances to restrict the type and
location of trees and provide utilities additional trimming rights to address existing tree
conditions.l
Additionally, FPL notes that day-to-day, hardened feeders perform approximately 40o/" better
than non-hardened feeders.
Transmission Line Sections/Substations Performance
The transmission system's performance was excellent during Hurricanes Matthew and Irma.
Equipment and conductor damage was minimal as a result of our investments in transmission
hardening and the installation of flood monitoring equipment in those substations located in
flood prone areas. Substations that experienced outages were restored in one day. During
Hurricanes Matthew and Irma, flood monitoring equipment operated as expected, providing
notification which allowed FPL to proactively de-energize three substations (one in Matthew and
two in Irma) and prevent potential serious damage from occurring at these substations.
I Where municipalities are not actively engaged in ensuring appropriate limitations on planting trees in public rights
of way, restoration efforts are impeded and made more costly. In fact,-one particular municipality is actively
planting "wrong trees in the wrong place," in spite of FPL's direct communications and efforts to encourage its
Right Tree Right Place initiative.
Matthew
Overhead non-Hardened
Overhead
Hardened Underground Total
Out Pop
%
Out Out Pop
%
Out Out Pop
o/o
Out Out Pop %Ottt
Distribution Feeders 280 2,031 r4%68 -121 9o/o r.493 359 3,245 t3%
Distribution Laterals 3,413 82,729 4%N.A.N.A.N.A.238 101,892 0.2%3,711 1,84,62r 2%
IRMA.2017 Overhead Non-Hardened
Overhead
Hardened Underground Total
Out Pop
%
Out Out Pop
%
Out Out Pop
lo
Out Out Pop
o/o
Out
Distribution Feeders 1-,609 1,958 82%592 859 69%B5 410 18o/"2,286 3,287 10%
Distribution Laterals 20,34r 84,574 24%N.A.N.A N.A.3,767 103,384 24,rOB 187,958 13%
Docket No. 2O2OO071-E\
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 9 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 8 of 9
The tables below provide substation line section outage performance for Hurricanes Matthew
and Irma.
* 2 sections were out because substation was proactively de-energized due to flooding** 4 sections were out because substations were proactively de-energized due to flooding*** No underground section was damaged or failed causing an outage; howevero the sections were out due to line
termination equipment in substations.
The table below compares substation outage and restoration performance - Irma vs, Wilma.
Smart Grid Performance
During Humicane Matthew and Irma, smart grid devices prevented a significant amount of
customer outages, assisted with restoration efforts and reduced restoration time and costs.
Specifically, automated feeder switches avoided approximately 664,000 outages during
Hurricanes Matthew and Irma. Additionally, FPL's restoration crews are able to "ping" smart
meters before leaving an area to ensure that power is, in fact, restored. This prevents restoration
crews from leavingan are1 thinking all power was restored, only to be called back when the
customer informs FPL that they are still without service. FPL is also enhancing an application,
first utilized during Hunicanes Matthew and Irma, whereby it will be able to "bulk meter ping"
smart meters to confirm whether customers have service.
Trans. Line Sections L5 3s0 5%23*846 3o/o 0 49 o%39 1,245 3%
i,.r)t
',
,(:Jr.L, i{'JL,r,illl- :lliri\irl );.1 l:i aiLl 'lfjt, aJlii 1'1. !, ,t,)
i:lriiir,ti:i4rir ti f t;.
.Jl,lr):\ ).
flf/r Ji:;f i t: I i:
i ilLr'/l.trl:lr,
,,.
a ]\t.
( jl/.irji r,,,if''ri: r;i.,l,L;!i I i, lri.r.:
:\
Trans. Line Sections 60 306 20%742**884 t6%13x **51 25o/"275 124r t7%
' '1,
atlL I
iliitr rrritJ;t{jl I.t;f f it:t.;',,i
1,
i:l( j 'tall {:li ii
ll,
cl r l.;
'lt,
(tl( I
i i!/:).lil t;l{il *i.1.r. .{"i1,.!.'rf'tr
l i,J:i i L:li r.j..jt:ctr trlt
{rt r.
I:,,J r:.1
i'Jt'!:a]rl
iiiifrl, )t1.1.
De-energized 241,92
Restored {Davs)5 1
Matthew - 2016 118,000
lrma - 2O17 s46,000
' tr , . :, ,. ,)./ r-l I
L!\J..J1 . l rjr
. ,rt.l i:.)rft.J
Docket No. 20200071-El
FPL'S 2O2O-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 1 0 of 18)
tr'lorida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 9 of9
Estimate of Storm Restoration Cost Savinqs Due to Hardening based on Storm Damage
Model Simulation
The attached analysis provides an estimate of transmission and distribution storm restoration
savings for Hunicanes Matthew and Irma that resulted from storm hardening completed by FPL
prior to the storms' impacts. To calculate these savings, FPL utilized its Storm Damage Model
(the same model FPL utilizes to estimate damage when a storm approaches FPL's service
territory) to simulate damage that likely would have occurred without hardening and determine
the associated required construction man hours (CMH) that would have been required to restore
service in the absence of hardening, days to restore in the absence of hardening and associated
incremental restoration costs. Additionally, FPL calculated the 4O-year net present value of these
savings for two scenarios - (l) a similar storm occurs every 3 years; and (2) a similar storm
occurs every 5 years.
As indicated on the attached analysis, the 40-year net present values of the savings related to
storm hardening are significant. In the absence of hardening the estimated percentage increase in
CMHs for Hurricane Matthew and Hurricane Irma restoration would have been significantly
higher (36Yo and 40o/o, respectively), days to restore would have been increased (50%o and 40%o,
respectively) and restoration costs would have been greater (36%o and 40%o, respectively).
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. L
Tablof5
Docket No. 2O200071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 1 1 of 18)
Estimate of Storm Restoration Cost Savinss Due to Hardening based on Storm Damaee Model Simulation
tll I2l I31
Construction Man-Hours
I4I tsl 161 l7l
to Restore
I81
Yo lncrease
without
Hardening
50%
40%
Additional
Days to
Restore
without
Hardening
2
4
Modeled
System
Without
Hardening
6
1,4
Actual
4
10
tel [r0] [111
Storm Restoration Costs
I 12l
Y" lncrease
without
Hardening
36%
40%
Additional
Storm
Restoration
Costs
without
HardeninE
s105
s496
Modeled
System
without
Hardening
s39s
sL.722
Actual
s290
sr.226
[13]
40 Yr NPV
[141
Storm
Matthew
lrma
Notes:
All costs and CMH are Transmission and Distribution only, and exclusive offollow-up work
I I I Calculated based on actual storm restoration requirements
[2] FPLstormdamagemodelsimulationresultsofCMHincurredwithouthardening
[ 3 I Additional CMH without hardening (Col. 2 - Col. 1)
[ 4] Percent increase in CMH without hardening (Col. 3/Col. L)
[ 5 I Actual days to restore seruice
[ 6 I Storm damage model simulation result ofthe days to restore seruice without hardening (assumes same restoration resources as actual)
[ 7 I Additional days to restore without hardeninB (Col. 6 - Col. 5)
[ 8 I Percent increase in days to restore without hardening {Col. 7/Col. 5)
[ 9 I Actual cost of restoration. lrma costs are preliminarv
[ 10 I Storm damage model simulation result of restoration costs without hardening
[ 11 ] Additional restoration costs without hardening (Col- 10 - Col.9)
I 12 ] Percent increase in restoration costs without hardening ((Col. L7/Col.9\
[ 13 I 40 year net present value savings assuming a similar storm everythree years {ca]culation details attached)
[ 14 ] 40 year net present value savings assuming a similar storm everyfrve years (calculation details attached]
0/6 lncrease
without
Hardening
36%
40%
Additional
CMH
without
Hardening
93,000
483.000
System
Modeled
Without
Hardening
3s0.000
1.678.000
Actual
257,000
1.195.000
40 Yr NPV
Savings Every
5 Years
(2017sl
s406
s1.,91s
40 Yr NPV
Savings Every
3 Years
(2oL7sl
S6s3
s3.082
Docket No. 20200071-El
FPL'S 2o2o-2o29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 12 o'f 18\
Florida Power & Light Company
Docket No. 20170215-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1
Tab2of5
$1os
So
So
$113
5o
so
s121
So
$o
S13o
$o
$o
Si_39
slso
So
So
$rer
$o
$o
S173
so
$o
Slss
So
So
Estimated Storm Restoration Costs Savings due to Hardening (SMM)
40-Year NPV (20175)
Matthew Savings
Everv 3 vears Everv 5 vears
S6s3 $406
Discount Rate = 7.76%
So
So
L
2
3
4
5
6
7
8
9
10
L1.
12
13
L4
15
L6
17
18
19
20
2t
22
23
24
25
26
21
Slos
So
So
$o
$o
Sr.i_8
so
So
So
So
S133
So
So
$o
$o
slso
So
So
So
So
$169
so
$o
$o
So
Sleo
$o
cPl
Multiplier
1.000
1.024
1.049
1.076
1.105
1.124
1.152
1.179
1.206
1.233
1.260
1.288
1.317
1.346
1.375
1.404
1.434
1.464
1.495
1.526
1.558
1.590
1.623
1.656
'1.691
1.727
1.763
Matthew
L05
ro7
110
113
115
118
121
L24
r27
130
s133
s136
S13e
S143
S146
slso
S1s3
Si.s7
Si-G1
S16s
$r"6s
Si.73
$117
s181_
518s
sleo
S1s4
cPl
2.1%
2.4%
2.4%
2.6%
2.t%
L.7%
2.5%
2.4%
2.3%
2.2%
2.2%
2.2%
2.2%
2.2%
2.2%
2.1%
2.L%
2.r%
2.I%
21%
2.1%
2.1%
2.1%
2.L%
2.r%
2.t%
2.L%
$
s
s
s
s
5
$
$
$
s
Year
Matthew Savings
Everv 3 vears Everv 5 vears
Docket No. 20200O71-El
FPL's 202O-2029 Storm Protection PIan
Exhibit MJ-1 , APPENDIX A (Page 13 of 1B)
28
29
30
31
32
33
34
35
36
37
38
39
40
51ee
So
So
Szr4
So
So
s23o
$o
so
5246
$o
so
s26s
So
$o
So
521.4
So
So
so
So
5z4L
So
So
$o
So
21%
2.2%
2.2%
2.r%
2.2%
2.Lo/o
2.r%
2.r%
2.1%
2.L%
2.L%
2.7%
2.7%
1.801
1.840
1.880
1.920'1.962
2.004
2.047
2.090
2.135
2.180
2.226
2.274
2.322
Slss
s204
s2oe
$2r4
s21s
s224
S23o
s23s
iz+t
$246
Szsz
S2s8
s26s
NPv (20u$)s6s3 S406
Docket No. 20200071-El
FPL's 2O2O-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 14 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1-
Tab3of5
Estimated Storm Restoration Costs Savings due to Hardening ($MMl
40-Year NPV (2017S)
lrma Savings
Everv 3 vears Everv 5 vears
$3,082 S1,915
Discount Rate = 7.76%
96St
S4s6
5o
So
$s:z
So
$o
ss71
$o
$o
S6r-3
'J.
2
3
4
5
6
7
8
9
10
LL
12
13
t4
15
L6
17
18
19
20
2t
22
23
24
25
26
27
So
$o
s6ss
so
So
57Ol
so
So
sTss
So
$o
s8Ls
$o
So
Ss76
So
$o
$4s6
So
So
SO
So
Ssss
So
So
5o
So
$62s
$o
so
so
So
$tot
so
so
So
$o
cPr
21%
2.4%
2,4%
2.6%
2.t%
L.1%
25%
2.4%
23%
2.2%
2.2%
2.2%
2.2%
2.2%
2,2%
21%
2.1%
2J%
2.L%
2,1%
2.1%
2.r%
2.1%
2.r%
2.r%
2.t%
2.1%
lrma
S4s6
SsoT
Ss20
Ss32
Ss+s
sss8
Sszr
ssss
Sses
S6r"3
s62s
s543
$6ss
$atq
S6s1
5707
5tz+
5742
$7ss
5178
s796
S81s
s83s
$8ss
Ss76
S8s7
Ssi"s
So
So
So
So
$897
so
cPt
Multiplier
1.000
1.024
1.049
1,076
1.105
1j24
1.152
1.179
1.206
1.233
1.260
1.288
1.317
1.346
1.375
1.404
1.434
1.464
1.495
1.526
1.558
1.590
1.623
1.656
1.691
1.727
1.763
Year
Matthew Savings
Everv 3 vears Everv 5 vears
Docket No. 2O20OO71-E\
FPL'g 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 15 of 1B)
28
29
30
31
32
33
34
35
36
37
38
39
40
so
so
s1,084
$o
So
Ss4o
SO
So
S1,oo9
51,L64
$o
So
s1,250
so
$o
$o
Si.,oo9
So
So
So
So
S1,136
$o
So
$o
$o
2.I%
2.2%
2.2%
2.1o/o
2.2%
2.L%
2.I%
2.1%
2.t%
2.L%
2.L%
2.1%
2.I%
1.801
1.840
1.880
1.920
1.962
2.404
2.047
2.090
2.135
2.180
2.226
2.274
2.322
Ss4o
se63
Ss86
$t,oos
S1,034
Sr,oss
S1,084
S1,110
S1,136
s1,164
5t,tsz
5t,2zo
$1,250
NPV (2017$)S1,915s3,082
Docket No. 20200O71-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 16 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1
Tab4of5
FPL
WEIGHTED AVERAGE COST OF CAPITAL
STATE INCOME TAX
FEDERAL INCOME T
5.50%
21.OOo/o
COMPOSITE INCOME TAX RA] 25,35O/O
MODEL DATE:1-Jan-1 8
Debt Cost Based on Blue Chin Cornorate Aaa and Bbb Bonds
AFTERTAX PRETAX
SOURCE n/EIGHT(1) coST(2)/TD COST /TD COST /TD COST
DEBT
COMMON
40/0%
59.60%
4.88o/o
10.55%
1.97o/o
6.29%
147%
6.29%
1.97%
8.42%
TOTAL 100.00%8.26% 7.76% 10.39%
AFTER-TAX WACC 7.760/"
Docket No. 20200071-El
FPL'I 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 17 of 1B)
Florida Power & Light Company
Docket No. 20L70215-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1
Tab5of5
Consumer Prices (1982-84=1.000) All-Urban
(Forecast adjusted to match budget assumptions)
lndex % Change
2009 2.1454
20LO 2.1806 1.64%
201.1. 2.2494 3.1,6%
2012 2.2959 2.07%
2013 2.3296 1.46%
20t4 2.3674 r.62%
2015 2,3702 0.L2%
20L6 2.4001, 1.26%
20L7 2.4512 2.L3%
2018
20L9
2020
2027
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031,
2032
2033
2034
2035
2036
2037
2038
2039
2040
2041
2042
2043
2044
2045
2046
2.5100
2.5703
2.6371.
2.t083
2.1553
2.8231.
2.8909
2.9569
3.0228
3.0895
3.1573
3.2270
3.2981
3.3693
3.441.1
3.5142
3.5887
3.6642
3.7408
3.8187
3.8972
3.9779
4.0603
4.t449
4.2324
4.3226
4.4153
4.5LO4
4.6077
2.40o/o
2.40%
2.60%
2.70%
1..73%
2.46%
2.40%
2.28%
2.23%
2.21%
2.I9%
2.2r%
2.20%
2.1.6%
2.13%
2.L2%
2.12o/o
210%
2.O9%
2.08%
2.060/o
2.O7%
2.O7%
2.08%
2.1,1o/o
2.r3%
2.L5%
2.1.5%
2.16%
Budget Assumptions
2.40%
2.40%
2.6A%
2.70%
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 1B of 1B)
2047
2048
4.7067
4.8099
2.r5%
2.L9%
2049
2050
2051
2052
2053
2054
205s
20s6
2051
4.9122
5.0167
s.1233
s.2323
5.3435
5.4572
5.5132
5.6917
5.8128
2.1-3%
2.13%
2.13%
2.L3%
2.13%
2.13%
2.L3%
2.I3%o
2.L3%
Actuals thru 2017 from BLS
APPENDIX
(FPL's Management ]
_** _J
I
lIJ
I
i
lt
I
3
lf
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX C (Page I of 2)
APPENDIXC
(FPL's 2020-2A29 Estimated SPP Costs)
2O2o-2O29 tPL 5?P Program Costs/Activities
Docket No. 202OO071-E\
FPL'S 2020-2029 Storm Protection PIan
Exhibit MJ-1, APPENDIX C (Page 2 of 2)
Distribution - Pole lnspections
Operating Expenses
Capital Expenditures
Total
# of Pole lnspections
Transmission - lnspections
Operating Expenses
Capital Expenditures
Total
# of Structure lnspections
Distribution - Feeder Hardenine (1) (2)
Operating Expenses
capital Expenditures
Total
# of Feeders (3)
Distribution Lateral Hardeninq (1) (21
Operating Expenses
Capital Expenditures
Total
# of Laterals (3)
Transmission - Replacing Wood Structures
Operating Expenses
Capital Expenditures
Total
# of Structures to be Replaced
Distribution - Vegetation Manasement
Labor - Contractor
tabor - FPL
Equipment - Contractor
Equipment - FPL
Total
# of Miles Maintained
Transmission - Vegetation Management
Labor - Contractor
Labor - FPL
Equipment - Contractor
Equipment - FPL
Tota I
# of Miles Maintained
Substation Storm surge/Flood Mitisation
Operating Expenses
Capital Expenditures
Total
# of Substations
s 61".1 s 61.3 s 60.2 s
r-5,200 15,200 1.5,200
in mil
3.8 s 3.8 s 3.e s 3.s s 4.0 s 4.1 s 4.2s 3e.1 s 3.e
s5.3s ss.3s s5.4s s7.8s s9.3s 60.8s 52.3s s55.1s s6.6
s s4.ss s7.9s s7.9s s9.0s s9.1s 60.3s 51.8s 53.35 64.9 s 66.ss 60s.2s 60.s
150,000 L50,000 r"s4,000 154,000 l-s4,000 154,000 154,000 154,000 1s4,000 154,000
27.9
1.Os 1".0s 1.0s 1.0s 1.05 1.0s r..0s 10.ss 1.0
67.ss s4.6s s2.0s s3.3s s4.6s s6.0s s7.4s 489.0s 48.9
s 3s.8 5 32.2 S 28.9 S 58.s S ss.6 S s3.0 5 s4.3 S ss.7 S s7.0 S s8.4 S 499.s S s0.0
68,000 68,000 68,000 68,000 58,000 68,000 58,000 68,000 68,000 68,000
s 62S.1s 564.ss 654.es s73.3s 474.s9 200.0s - 5 - 5 - S - S3,20s.8S 534.3
s 628.1 s 664.9 s 654.9 s s73.3 5 474.5 5 200.0 S - S 5 $ S 3,205.8 S 534.3
300-350 300-350 300-350 300-350 250-350
3.8 s
s0.7 s
3.8
54.1
1.0
31.2
s
5
3.8
54.1
s
5
34.5
s
s
1.05
s
s
s
s!2O.45212.ss342^8s47s.6s63r..4s631.45647.2s663.4s679.9s596.9ss,101.4ss10.1s 120.4
220-230
5212jS342.8547s.6S631.4$631.45647.2S553.45679.9S696.9Ss,101.4Ss10.1
300-350 400-500 600-700 800-900 800-900 800-900 800-900 800-900 800-900
o.2s 0.2 s 0.2 s s s 5 s s s s 0.5 5 0.2
s s2.7s 42.7s 21.ss - s - 5 - s - s - s - 5 - s 117.3s 3e.1
s s2.e s 42.s s 22.r s - s s s s s 5 s. x17.e s 3s.3
1,400-1,600 900-1,100 300-500
s
5
s
s
47.7
1.3
11.9
0.1
s
s
s
s
s
s
47 -8
1".4
12.o
u.i
6.7
0.5
r.7
0.1
8.9
,000
10.0
46.9
r.4
tl.7
0.1"
s
5
5
s
s
)
)
s
46.9s47.ts47.t
1".ss 1.ss 1.6
r.1.7s 11.8s 11.8
o.1s 0.1s 0.1
60.25 50.6S 50.5
15,200 15,200 L5,200
s8.s s s7.4 s s6.4 5
15,200 15,200 75,200
463.7 5 46.4
74.7 5 1.5
115.9 s 1r-.6
1.4 s 0.1
23.0
7.7
7.7
s9s.7 s s9.6
r"0.7s 96.4s 9.6
45.5
1.5
rl.4
0.1
46.3
1.5
IL.6
0.1
5
)
s
s
s
5
)
s
s
44.6
L.5
u.2
0.1
s
s
s
s
43.8 s
1.5 I
11.0 s
0.1 s
s 59.5
15,200
s
s
5
s
5
s
s
s
s
5.7 s
0.5 s
1.7 5
0.1 s
6.7 s
0.s 5
1.7 s
0.1 s
7.2 5
0.6 s
1.8 s
0.1 s
6.6
0.5
0.1
s
5
s
s
7.2
0.5
1.8
0.1
s
s
s
s
7.4 s 7.6 s 7.8 s 7.9 5 7r.7 5 7.2
0.6s 0.6s 0.5s 0.6s s.3s 0.s
r".85 1.sS 1.s5 2.oS r7.s$ 1.8
o.1s o.1s 0.15 o.2s 1.4$ 0.1s s.os 8.e s s.0 s 9.7 s s.7 s s.s s 10.2 s 10.4 5
7,000 7,000 7,000 7,000 7,ooo 7,000 7,0007,000 7 7,OOO
s
s
23.O
s
s
ss
s
s
s
5
s
ss
3.0
s
s
s
10.0
10.0
to7
10.0
2
3.0
L
I s s
s
s s
Total SPP Costs
(1") Project level detail for 2020 in Appendix
{2) Costs include previous year(s) projects carried over to current year's project costs and future year's preliminary project costs (e.9., engineering)
(3) # of feeders or lateral to be initiated in the current year
5s64.7S1,090.7S1,1es.85r,24s.6S1,290.9S1,014.eS832.7S851.0S85e.7$889.0Sx0,24s.05r,27r.L
Total SPP
Costs
An n ual
Average Cost2022FPL SPP Programs 20272026202s202420232021,2020 2028 2029
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 1 of 14)
APPENDIXD
(FPL's Hardening Design Guidelines)
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 2 of 14\
@FPL
Distribution Design Guidelines
The following guidelines will be used to standardize the design of FPL's overhead distribution
facilities when practical, feasible, and cost effective.
General
1. FPL has made a change to adopt Extreme \Mnd loading (EWL) as the design criteria for:
(1) new pole line construction, (2) pole line extensions, (3) pole line relocations, (4)
feeder pole replacements on multi-circuit pole lines, and (5) feeder pole replacements on
Top-ClF feeders. Reference the Pole Sizing section (pg. 7) for the guidelines to
determine the necessary pole class and type for all work. Refer to the Distribution
Engineering Reference Manual Addendum for calculating pole sizes for specific framing
under extreme wind loading conditions.
2. For maintenance, existing non-top-ClF pole lines may be evaluated using NESC combined
ice and wind loading with Grade B construction. This represents the loading prior to the
adoption of extreme wind loading. lf the pole must be replaced, refer to the Pole Sizing
section for the minimum class pole to be installed. Refer to the Distribution Engineering
Reference Manual (DERM) Section 4 for calculating pole sizes for specific framing under
the NESC combined ice and wind loading conditions.
3. Every attempt should be made to place new or replacement poles in private easements
or as close to the front edge of property (right of way line) as practical.
4. Overhead pole lines should be placed in front lot lines or accessible locations where
feasible.
5. When replacing poles, the new pole should be set as close as possible to the existing
pole to avoid the creation of a new pole location.
6. Poles are not to be placed in medians.
7. Concrete poles are not to be placed in inaccessible locations or locations that could
potentially become inaccessible.
B. Please reference the minimum setting depth charts located in DCS D-3.0.0 which shows
the increased setting depths for concrete poles.
g. Every effort should be made not to install poles in sidewalks. lf a pole must be placed in
a sidewalk, a minimum unobstructed sidewalk width of 32" must be maintained to comply
with the American Disabilities Act (ADA) requirements.
10. lf concrete poles are required by the governing agency as a requirement of the permit,
and if the work is being done solely for FPL purposes (feeder tie, etc.), then the concrete
Christopher T. Wright
Senior Attorney - Regulatory
Florida Power & Light Company
700 Universe Blvd
Juno Beach, FL 33408-0420
Phone: (561) 691-7144
E-mail : Christoper.Wri eht@fpl.com
Florida Authorized House Counsel;
Admitted in Pennsylvania
April10,2020
VA ELECTRONIC FILING
Mr. Adam Teitzman
Division of the Commission Clerk and Administrative Services
Florida Public Service Commission
2540 Shumard Oak Blvd.
Tallahassee, FL 32399-0850
Re: Docket No. 20200071-El
Review of 2020-2029 Storm Protection PIan pursuant to Rule 25-6.030, F.A.C.,
Florida Power & Lisht Comnanv
Dear Mr. Teitzman:
Enclosed for electronic filing in the above-referenced docket, please find Florida Power & Light
Company's Petition for Approval of the 2020-2029 Storm Protection Plan pursuant to Rule 25-
6.030, F.A.C., together with the Direct Testimony of FPL witness Michael Jarro and Exhibit MJ-
1. Copies of this filing will be pt'ovided as indicated on the enclosed Certificate of Service.
If you or your staff have any question regarding this filing, please contact me at (561) 691-7144.
Respectfully submitted,
s/Christonher Wri
Christopher T. Wright
Authorized House Counsel No. 1007055
Enclosure
FFL-
Florida Power & Light Company
700 Universe Boulevard, Juno Beach, FL 33408
Page | 1
BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
Docket No. 2020007t-El
Filed: April 10,2020
PETITION OF FLORIDA POWER & LIGHT COMPANY
FOR APPROVAL OF THE 2020-2029 STORM PROTECTION PLAN
I. INTRODUCTION
Florida Power & Light Company ("FPL" or the "Company") hereby files this petition (the
"Petition") requesting that the Florida Public Service Commission ("Commission") approve the
proposed Transmission and Distribution ("T&D") Storm Protection Plan for the years 2020-2029
(hereinafter, the "SPP") pursuant to Section 366.96, Florida Statutes ("F.S.") and Rule 25-6.030,
Florida Administrative Code ("F.A.C."). FPL's SPP is, in large part,acontinuation and expansion
of its previously approved and successful storm hardening and storm preparedness programs. FPL
submits that the storm hardening and storm preparedness programs included in its SPP are
appropriate and necessary to achieve the legislative objectives of Section366.96, F.S., to protect
and strengthen T&D infrastructure from extreme weather conditions, reduce outage times and
restoration costs, and improve overall service reliability to customers.l In support of this Petition,
FPL states as follows:
1. The name and address of the Petitioner is:
Florida Power & Light Company
700 Universe Blvd
Juno Beach, FL 33408
I The recovery of costs associated with the SPP, as well as the actual and projected costs to be included in
FPL's Storm Protection Plan Cost Recovery Clause, will be addressed in subsequent and separate Storm
Protection Plan Cost Recovery Clause dockets pursuant to Rule 25-6.031, F.A.C. The Commission has
opened Docket No. 20200092-EI to address Storm Protection Plan Cost Recovery Clause petitions to be
filed the third quarter of 2020.
1
Review of 2020-2029 Storm Protection Plan pursuant ll
to Rule 25-6.030, F.A.C., Florida Power & Light llCompany ll
2. FPL is a corporation organized and existing under the laws of the State of Florida
and is an electric utility as defined in Sections 366.02(2) and366.96, F.S. FPL provides generation,
transmission, and distribution service to nearly five million retail customer accounts.
3. Any pleading, motion, notice, order or other document required to be served upon
the petitioner or filed by any party to this proceeding should be served upon all of the following
individuals:
Kenneth A. Hoffrnan
Vice President, Regulatory Affairs
Florida Power & Light Company
215 South Monroe Street, Suite 810
Tallahassee,FL 32301
Phone: 850-521-3919
Fax: 850-521-3939
Emai I : ken. hoffman @fpl com
John T. Burnett
Vice President and Deputy General Counsel
Christopher T. Wright
Senior Attorney
Florida Power & Light Company
700 Universe Boulevard
Juno Beach, FL 33408-0420
Phone: 561-691-7 144
F ax: 561-691-7 135
Email : j ohn.t.burnett@fpl.com
Email : christopher.wri ght@fpl.com
4. The Commission has jurisdiction pursuant to Section 366.96, F.S., and Rule 25-
6.030, F.A.C.
5. This Petition is being filed consistent with Rule 28-106.201, F.A.C. The agency
affected is the Commission, located at2540 Shumard Oak Boulevard, Tallahassee, Florida32399.
This case does not involve reversal or modification of an agency decision or an agency's proposed
action. Therefore, subparagraph (c) and portions of subparagraphs (b), (e), (f) and (g) of subsection
(2) of Rule 28-106.207, F.A.C., are not applicable to this Petition. ln compliance with
subparagraph (d) of Rule28-106.201, F.A.C., FPL states that it is not known which, if any, of the
issues of material fact set forth in the body of this Petition may be disputed by any others who may
plan to participate in this proceeding. The discussion below demonstrates how the petitioner's
substantial interests will be affected by the agency determination.
2
II. BACKGROUND AND OVERVIEW
6. On June 27,2019, the Governor of Florida signed CS/CS/CS/SB 796 addressing
Storm Protection Plan Cost Recovery, which was codified in Section 366.96, F.S. Therein, the
Florida Legislature found that it was in the State's interest to "strengthen electric utility
infrastructure to withstand extreme weather conditions by promoting the overhead hardening of
electrical distribution and transmission facilities, the undergrounding of certain electrical
distribution lines, and vegetation management," andfor each electric utility to "mitigate restoration
costs and outage times to utility customers when developing transmission and distribution storm
protection plans." Section 366.96(I), F.S. The Florida Legislature directed the Commission to
adopt rules to specify the elements that must be included in each utility's SPP. Section366.96(l),
F.S.
7. Rule 25-6.030, F.A.C., requires each utility to file an updated SPP at least every
three years that covers the utility's immediate ten-year planning period. Rule 25-6.030, F.A.C.,
also specifies the information to be included in each utility's SPP. Consistent with these
requirements, FPL is herein submitting its SPP for the ten-year period of 2020-2029, which is
provided as Exhibit MJ-1.
8. FPL's SPP is largely a continuation and expansion of its existing storm hardening
and storm preparedness programs, which were most recently approved in FPL's 2019-2021Storm
Hardening Plan.2 These existing hardening and storm preparedness programs have already
demonstrated that they have and will continue to increase T&D infrastructure resiliency, reduce
restoration times, and reduce restoration costs when FPL's system is impacted by extreme weather
2 See Inre: Petitionfor Approval of FloridaPower & Light Company's 2019-2021 Storm Hardening Plan
pursuant to Rule 25-6.0342, F.A.C.,DocketNo. 20180144-EI, OrderNo. PSC-2019-0364-CO-EI (Fla. PSC
Aug. 27 ,2019) (making Order No. PSC-201 9-0301 -PAA-EI issued on July 29, 2079, effective and final).
J
events. FPL performed an analysis of Hurricanes Matthew and Irma that indicated the restoration
construction man-hours ("CMH"), days to restore, and storm restoration costs for these storms
would have been significantly higher without FPL's storm hardening programs.3
9. While FPL's nation-leading initiatives have made significant progress toward
strengthening FPL's infrastructure, FPL must continue its T&D storm hardening and storm
preparedness plans and initiatives. Storms remain a constant threat and Florida is the most
hurricane-prone state in the nation. With the significant coast-line exposure of FPL's system, and
the fact that the majority of FPL's customers live within twenty miles of the coast, a robust storm
protection plan is critical to maintaining and improving grid resiliency and storm restoration as
contemplated by the Legislature in Section 366.96.
10. As part of its SPP, FPL will continue the previously approved storm hardening and
storm preparedness programs to achieve the legislative objectives of promoting the overhead
hardening of T&D facilities, the undergrounding of distribution lines, and vegetation management
to reduce restoration costs and outage times to customers and improve the overall service reliability
for customers. In addition, FPL proposes to implement a new substation storm surge/flood
mitigation program. FPL submits that the SPP will continue and expand the benefits of hardening,
including improved day-to-day reliability, to all customers throughout FPL's system.
1 1. Submitted herewith and in support of FPL's SPP is the Direct Testimony of Michael
Jarro and Exhibit MJ-l, which includes FPL's SPP for the period of 2020-2029 and supporting
schedules.
3 ,9ee FPL's Third Supplemental Response to Stafls First Data Request No. 29 ("Third Supplemental
Amended") in Docket No. 20170215-EI, which is provided as Appendix A to Exhibit MJ-l.
4
ilI.STORM CTTON PI,AN
A. Description of the SPP Programs
12. FPL's SPP is largely a continuation and expansion of the following previously
aPProved storm harde;":H.;ffi;:,:::;*
Structures/Other Equipment Inspections - Transmission Program
Feeder Hardening (EWL) - Distribution Program
Lateral Hardening (Undergrounding) - Distribution Program
Wood Structures Hardening (Replacing) - Transmission Program
Vegetation Management - Distribution Program
Vegetation Management - Transmission Program
In addition, FPL proposes to implement a new Substation Storm Surge/Flood Mitigation-Program
to protect T&D substations and equipment that are susceptible to storm surge or flooding during
extreme weather events. These SPP programs are summarized below and a detailed description
of each SPP program, consistent with Rule 25-6.030(3)(d), F.A.C., is provided in Section IV of
Exhibit MJ-1.
13. The Pole Inspection - Distribution Program will continue FPL's existing
Commission-approved distribution pole inspection program, which is an eight-year pole
inspection cycle for all distribution poles that targets approximately 1/8 of the system annually
(the actual number of poles inspected can vary somewhat from year to year). With approximately
1.2 million distribution poles as of year-end 2019, FPL expects to inspect approximately 150,000
poles annually. The estimated 2020-2029 annual average cost for the Pole Inspection -
Distribution Program is approximately $61 million per year, which is consistent with historical
5
costs for the existing distribution pole inspection program.a A detailed description of the Pole
Inspection - Distribution Program is provided in Section IV(A) of Exhibit MJ-1.
14. The Structures/Other Equipment Inspections - Transmission Program will continue
FPL's current Commission-approved transmission inspection program which requires: (a)
transmission circuits and substations and all associated hardware to be inspected on a six-year
cycle; (b) wood structures to be visually inspected from the ground on an annual basis and climbing
or bucket truck inspections to be conducted on a six-year cycle; and (c) steel and concrete
structures to be visually inspected on an annual basis and climbing or bucket truck inspections to
be conducted on a ten-year cycle. FPL expects to inspect approximately 68,000 transmission
structures annually. The estimated 2020-2029 annual average cost for the Structures/Other
Equipment Inspections - Transmission Program is approximately $50 million per year, which is
consistent with historical costs for the existing transmission inspection program.s A detailed
description of the Structures/Other Equipment Inspections - Transmission Program is provided in
Section IV(B) of Exhibit MJ-1.
15. The Feeder Hardening (EWL) - Distribution Program will continue FPL's existing
Commission-approved approach to harden existing feeders and certain critical distribution poles,
as well as FPL's initiative to design and construct new pole lines and major planned work to meet
the extreme wind loading ("EWL") criteria set forth in the National Electric Safety Code. FPL
a Note, the2020-2029 progtam costs shown above are projected costs estimated as of the time of this filing.
Subsequent projected and actual costs could vary by as much as 10Yo to 75%o. The annual projected costs,
actual/estimated costs, actuals costs, and true-up of actual costs to be included in FPL's Storm Protection
Plan Cost Recovery Clause will all be addressed in subsequent and separate Storm Protection Plan Cost
Recovery Clause filings pursuant to Rule 25-6.031, F.A.C. The Commission has opened Docket No.
20200092-EI to address Storm Protection Plan Cost Recovery Clause petitions to be filed the third quarter
of2020.
5 See footnote 4.
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expects to harden approximately 280-350 feeders annually, with 100% of FPL's feeders expected
to be hardened or underground by year-end 2024 and with the final costs of the program to be
incurred in 2025. The estimated average annual cost for the Feeder Hardening (EWL) -
Distribution Program to be incurred over the period of 2020-2025 is approximately $534 million
per year, which is consistent with historical costs for the existing distribution feeder hardening
program.6 A detailed description of the Feeder Hardening (EWL) - Distribution Program is
provided in Section IV(C) of Exhibit MJ-1.
16. The Lateral Hardening (Undergrounding) - Distribution Program includes
completing FPL's existing three-year Storm Secure Underground Program Pilot ("SSUP Pilot") in
2020 andexpanding the application of the SSUP to the implementation of the system-wide Lateral
Hardening (Undergrounding) - Distribution Program for the period of 2021-2029. The SSUP Pilot
is a program that targets certain overhead laterals that were impacted by recent storms and have a
history ofvegetation-related outages and other reliability issues for conversion from overhead to
underground. As part of its SPP, FPL will incorporate, continue, and expand the SSUP during the
ten-year SPP period to provide the benefits of underground lateral hardening throughout its system.
After completing the SSUP Pilot in 2020,FPL estimates that it will convert approximately 300-
700 laterals annually in202l-2023 and approximately 800-900 laterals annually in2024-2029.
The estimat ed 2020-2029 annual average cost for the Lateral Hardening (Undergrounding) -
Distribution Program is approximately $510 million per year.1 A detailed description of the
Lateral Hardening (Undergrounding) - Distribution Program is provided in Section IV(D) of
Exhibit MJ-l.
6 See foolnote 4.
7,See footnote 4.
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17. The Wood Structures Hardening (Replacing) - Transmission Program is a
continuation of FPL's existing transmission hardening program to replace all wood transmission
structures with steel or concrete structures. As of year-end 2019, 960A of FPL's transmission
structures, system-wide, were steel or concrete, with less than 2,900 (or 4%) wood structures
remaining to be replaced. FPL expects to replace the 2,900 wood transmission structures
remaining on its system by year-end2022. The estimated2020-2022 annual average cost for the
Wood Structure Hardening (Replacing) - Transmission Program is approximately $39 million per
year, which is a decrease from the historical costs for the existing transmission hardening
program.8 A detailed description of the Wood Structure Hardening (Replacing) - Transmission
Program is provided in Section IV(E) of Exhibit MJ-1.
18. The Substation Storm Surge/Flood Mitigation Program is the only new storm
hardening program that FPL proposes to implement as part of its SPP. The Substation Storm
Surge/Flood Mitigation Program will implement measures to protect certain T&D substations and
equipment that are susceptible to storm surge or flooding due to extreme weather events.
Specifically, FPL will raise the equipment at certain substations above the flood level and construct
flood protection walls around other substations that are susceptible to storm surge or flooding
during extreme weather events. The Storm Surge/Flood Mitigation - Transmission and
Distribution Program will reduce customer outages due to flooding and the need to de-energize
substations that arc impacted by storm surge or flooding, as well as reduce flood damage and
restoration costs at these targeted substations. At this time, FPL has identified between 8-10
substations where it initially plans to implement storm surge/flood mitigation measures over the
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8 See footnote 4.
next three years (2020-2022). The estimated 2020-2022 annual average cost for the new
Substation Storm Surge/Flood Mitigation Program is approximately $8 million per year.e A
detailed description of the Substation Storm Surge/Flood Mitigation Program is provided in
Section IV(F) of Exhibit MJ-1.
19. The Vegetation Management - Distribution Program is a continuation of FPL's
existing, Commission-approved distribution vegetation management program. FPL's currently
approved distribution vegetation program, includes the following system-wide vegetation
inspection and management activities: three-year cycle for feeders; mid-year cycle targeted
trimming for certain feeders; six-year cycle for laterals; and continued education of customers
through its Right Tree, Right Place initiative. FPL plans to inspect and maintain, on average,
approximately 15,200 miles annually, which is consistent with the historic miles inspected and
trimmed annually. The estimated2020-2029 average annual cost for the Vegetation Management
- Distribution Program is approximately $60 million per year, which is consistent with historical
costs for the existing distribution vegetation management program.l0 A detailed description of the
Vegetation Management - Distribution Program is provided in Section IV(G)of Exhibit MJ-1.
20. The Vegetation Management - Transmission Program is a continuation of FPL's
existing transmission vegetation management program, which includes visual and aerial
inspections of all transmission line coruidors, LiDAR inspections of North American Electric
Reliability Corporation transmission line corridors, developing and executing annual work plans
to address identified vegetation conditions, and identifying and addressing priority and hazard tree
conditions prior to and during storm season. FPL plans to inspect and trim, on average,
e See footnote 4.
lo See footnote 4
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approximately 7,000 miles of transmission lines annually, which is consistent with the historic
miles inspected and trimmed annually. The estimated 2020-2029 average annual cost for the
Vegetation Management - Transmission Program is approximately $10 million per year, which is
consistent with historical costs for the existing transmission vegetation management program.ll A
detailed description of the Vegetation Management- Transmission Program is provided in Section
IV(H) ofExhibitMJ-1.
B. Additional Details for First Three Years of the SPP
21. The following additional project level information required by Rule 25-
6.030(3)(e)(1), F.A.C., for the first year of the SPP (2020) is provided in Appendix E to Exhibit
MJ-l: (a) the actual or estimated construction start and completion dates; (b) a description of the
affected existing facilities, including number and type(s) of customers served, historic service
reliability performance during extreme weather conditions, and how this data was used to prioritize
the storm protection project; and (c) a cost estimate including capital and operating expenses. A
description of the criteria used to select and prioritize storm protection projects is included in the
description of each SPP program provided in Section IV of Exhibit MJ-1.
22. Pursuant to Rule 25-6.030(3)(eX2), F.A.C., FPL has also provided the estimated
number and costs of projects under each specific program for the second and third years (2021-
2022) of the SPP. This information is provided in Appendix C to Exhibit MJ-1.
23. The following additional information required by Rule 25-6.030(3)(f), F.A.C., for
the first three years (2020-2022) of the vegetation management activities under the SPP is provided
in Sections IV(G) and IV(H) of Exhibit MJ-l and Appendix C to Exhibit MJ-l: (a) the projected
frequency (trim cycle); (b) the projected miles of affected transmission and distribution overhead
ll ,See footnote 4.
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facilities; and (c) the estimated annual labor and equipment costs for both utility and contractor
personnel. Descriptions of how the vegetation management activities will reduce outage times
and restoration costs due to extreme weather conditions are provided in Sections IV(G) and IV(H)
of Exhibit MJ-1.
C. Estimated Revenue Requirements and Rate Impacts
24. Pursuant to Rule 25-6.030(3)(9), F.A.C., the estimated annual jurisdictional
revenue requirements of FPL's SPP for the ten-year period of 2020-2029 are provided in Section
VI of Exhibit MJ-l. While FPL has provided estimated costs by program as of the time of this
filing and associated total revenue requirements in its SPP, consistent with the requirements of
Rule 25-6.030, F.A.C., subsequent projected and actual program costs submitted for cost recovery
through the Storm Protection Plan Cost Recovery Clause (per Rule 25-6.03I, F.A.C.,) could vary
by as much as 10-l5Yo, which variations would also impact the associated estimated revenue
requirements and rate impacts.
25. FPL anticipates the programs included in the SPP will have zero bill impacts on
customer bills during the first year of the SPP and only minimal bill increases for years two and
three of the SPP. An estimate of hypothetical overall rate impacts for the first three years of the
SPP (2020-2022) based on the total program costs reflected in this filing, without regard for the
fact that FPL remains under a general base rate freeze pursuant to a Commission-approved
settlement agreement through December 31,2021, are provided in Section VII of Exhibit MJ-l.
The annual jurisdictional revenue requirements and the estimated rate impacts are based on the
total estimated costs, as of the time of this filing, for all programs included in the SPP regardless
of whether those costs will be recovered in FPL's Storm Protection Plan Cost Recovery Clause or
through base rates. In addition, under FPL's Commission-approved rate case settlement
11
agreement, any incremental base rate adjustment may not take place until FPL's base rates are
established by the Commission in FPL's next base rate proceeding.12
26. FPL is not seeking Commission approval, through this petition, to recover any of
the estimated costs associated with the SPP in this filing. The projected costs, actual/estimated
costs, actual costs, and true-up of actual costs to be included in FPL's Storm Protection Plan Cost
Recovery Clause, including whether these costs are included in current base rates, will all be
addressed in subsequent and separate Storm Protection Plan Cost Recovery Clause filings pursuant
to Rule 25-6.031, F.A.C. The Commission has opened DocketNo. 20200092-EI to address Storm
Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
D. FPL's SPP is in the Public Interest and Should Be Approved
27. Sections 366.96(4)-(5), F.S., provide that the Commission shall review each
utility's SPP and, within 1 80 days from filing, determine whether the SPP is in the public interest. 13
28. As explained above, the programs included in the SPP are largely a continuation
and expansion ofFPL's already successful and ongoing storm hardening and storm preparedness
programs previously approved by the Commission, as well as a new storm hardening program to
t2 See In re: Petitionfor rate inuease by Florida Power & Light Company, Docket No. 160021-EI, Order
No. PSC-16-0560-AS-EI (Fla. PSC Dec. 15, 2016).
13 In reaching this determination, the Florida Legislature has directed the Commission to consider the
following:
(a) The extent to which the plan is expected to reduce restoration costs and outage times associated with
extreme weather events and enhance reliability, including whether the plan prioritizes areas of lower
reliability performance.
(b) The extent to which storm protection of transmission and distribution infrastructure is feasible,
reasonable, or practical in certain aleas of the utility's service territory, including, but not limited to,
flood zones and rural areas.
(c) The estimated costs and benefits to the utility and its customers of making the improvements
proposed in the plan.
(d) The estimated annual rate impact resulting from implementation of the plan during the first 3 years
addressed in the plan.
See Section 366.96(4), F.S.
12
protect T&D substations and equipment from storm surge and flooding due to extreme weather
events. These SPP programs will continue to provide increased T&D infrastructure resiliency,
reduced restoration times, and reduced restoration costs when FPL's system is impacted by
extreme weather events.
29. In DocketNo.20l702l5-EU, the Commission reviewed the electric utilities' storm
hardening and storm preparedness programs and found the following:
Florida's aggressive storm hardening programs are working;
The length of outages was reduced markedly from the 2004-2005 storm
season;
Hardened overhead distribution facilities performed better than non-
hardened facilities;
Underground facilities performed much better compared to overhead
facilities; and
The primary causes of power outages came from outside the utilities' rights-
of-way including falling trees, displaced vegetation, and other debris.
See Review of Florida's Electric Utility Hunicane Preparedness and Restoration Actions 2018,
Dobket No. 20 I 7021 5-EU (July 24,201 8). t4
30. The estimate of cumulative reductions in restoration costs and outage times
associated with the SPP will be directly affected by how frequently storms hit FPL's service
territory. Of course, no one is in a position to know for sure how frequently FPL's service territory
will be impacted by strong hurricanes. However, consistent with historical results, FPL expects
that the storm hardening and storm preparedness programs included in its SPP will result in a
reduction in storm as well as non-storm (day-to-day) restoration costs. See FPL's Third
Supplemental Response to Staff s First Data Request No. 29 ("Third Supplemental Amended") in
la Available at http://www.psc.state.fl.us/library/fi1ings/2018/04847-2018/04847-2018.pdf.
l3
DocketNo.20170215-EI, which is provided as Appendix A to Exhibit MJ-l.
31. FPL's storm hardening and storm preparedness programs have also provided and
will continue to provide increased levels of day-to-day reliability. For example, FPL has
previously submitted reports to the Commission that show hardened feeders have performed
approximately 40%;o beffer (i.e., fewer outages) on a day-to-day basis than non-hardened feeders.
32. A detailed summary of the benefits of FPL's SPP is provided in Section II of
Exhibit MJ-l, and the benefits and costs associated with each program is provided in Section IV
of Exhibit MJ-1.
33. FPL's SPP meets the objectives of Section366.96, F.S., satisfies the requirements
of Rule 25-6.030, F.A.C., is in the public interest, and should be approved.
IV. CONCLUSION
34. As explained above and in further detail in Exhibit MJ-l and the supporting Direct
Testimony of FPL witness Michael Jarro, FPL's SPP provides a systematic approach to achieve
the legislative objectives of reducing restoration costs and outage times associated with extreme
weather events and enhancing reliability. FPL's SPP appropriately and effectively maintains and
builds on FPL's commitment to provide safe and reliable electric service to customers, consistent
with our customers' needs and expectations .
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WHEREFORE, FPL respectfully requests that the Commission find FPL's proposed SPP,
provided as Exhibit MJ-l, is in the public interest and approve the SPP for the years2020-2029.
Respectfully submitted this 10th day of April,2020,
John T. Burnett
Vice President and Deputy General Counsel
Christopher T. Wright
Senior Attorney
Florida Power & Light Company
700 Universe Boulevard
Juno Beach, FL 33408-0420
Phone: 561-691-7144
Fax: 561-691-7135
Email : i ohn.t.burnett@fpl.com
Email : christopher.wri ght@fpl.com
By:s/Christooher T. Wrisht
Christopher T. Wright
Fla. Auth. House Counsel No. 1007055
15
CERTIFICATE OF SERVICE
I I{EREBY CERTIFY that a true and correct copy of Florida Power & Light Company's
Petition for Approval of the 2020-2029 Storm Protection Plan in Docket No. 2020007I-EI, along
with the Direct Testimony of Michael Jano and Exhibit MJ-l, has been furnished by Electronic
Mail to the following parties of record this 1Oth day of April,2020:
s/ Christopher T. Wrisht
Christopher T. Wright
Fla. Auth. House Counsel No. 1007055
Fla. Auth. House Counsel No. 1017875
Florida Power & Light Company
700 Universe Boulevard (JB/LAW)
Juno Beach, Florida 33408
Attorneyfor Florida Power & Light Company
Charles Murphy, Esquire
Rachael D ziechciarz. Esquire
Florida Public Service Commission
2540 Shumard Oak Boulevard
Tallahassee,FL 32399
rdziechc@nsc. state.fl .us
cmurphy(Epsc.state.fl .us
Office of Public Counsel
J.R.Kelly
Patricia A. Christensen
c/o The Florida Legislature
111 West Madison Street, Room 812
Tallahassee, FL 32399-1400
kelly jr@le g.state. fl .us
christensen.patty@le g. state.fl .us
BEFORE TIIE FLORIDA PUBLIC SERYICE COMMISSION
FLORIDA POWER & LIGHT COMPAIIY
2020.2029 STORM PROTECTION PLAI\
DOCKET NO. 202000071-Er
DIRECT TESTIMONY OF
MICHAEL JARRO
APRrL 10,2020
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TABLE OF'CONTENTS
I. INTRODUCTION ...3
il. OVERVIEW OF FPL'S Spp............ .....................4
III. DESCRIPTION OF EACH SPP PROGRAM.......... ................7
IV. ADDITIONAL DETAILS F'ORFIRST THREE YtrARS OF THE SPP....................16
v. coNCLUSrON...........
EXHIBIT MJ-l - FPL's 2020-2029 Storm Protection PIan
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I. INTRODUCTION
Please state your name and business address.
My name is Michael Jarro. My business address is Florida Power &,LighI Company, 15430
Endeavor Drive, Jupiter, FL, 3347 8.
By whom are you employed and what is your position?
I am employed by Florida Power & Light Company (.'FPL" or the "Company") as the Vice
President of Distribution Operations.
Please describe your duties and responsibilities in that position.
My curent responsibilities include the operation and maintenance of FPL's approximately
68,000 miles of distribution infrastructure, including 42,000 miles of overhead and 26,000
miles of underground, that safely, reliably, and efficiently deliver electricity to more than five
million customers in FPL's service tenitory covering approximately 28,000 square miles. I am
responsible for the oversight of more than 1,600 employees in a control center and sixteen
management areas. The functions and operations within my area are quite diverse and include
distribution operations, major projects and construction services, power quality, meteorology,
and other operations that together help provide the highest level of service to FPL's customers.
Please describe your educational background and professional experience.
I graduated from the University of Miami with a Bachelor of Science Degree in Mechanical
Engineering and Florida International University with a Master of Business Administration. I
ioined FPL in 7997 and have held several leadership positions in distribution operations and
customer service, including serving as distribution reliability manager, manager of distribution
operations for south Miami-Dade area, control center general manager, director of network
operations, senior director ofcustomer strategy and analytics, senior director ofpower delivery
central maintenance and construction, and vice-president of transmission and substations.
What is the purpose of your direct testimony?
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The purpose of my testimony is to present and provide an overview of FPL's proposed 2020-
2029 Storm Protection Plan ("SPP" or "the Plan"), which is attached to my direct testimony as
Exhibit MJ-1, and demonstrate that FPL's SPP is in compliance with Section 366.96, Florida
Statutes ("F.S.") and Rule 25-6.030, Florida Administrative Code ("F.A.C."). I will provide a
description of each storm protection program included in FPL's SPP and how it is expected to
reduce restoration costs and outage times. I will also describe the estimated start/completion
dates, estimated costs, and criteria used to select and prioritize the projects in each program.
Finally, I will describe the additional detail provided for the first three years of FPL's SPP
pursuant to Rule 25-6.030(3)(e)-(f), (h), and (i), F.A.C.
Are you sponsoring any exhibits in this case?
Yes. I am sponsoring Exhibit MJ-l - FPL's Storm Protection Plan 2020-2029.
il.OVF"RVIF"\^/OF FPL'S SPP
What is the purpose of FPL's SPP?
On June 27,2019, the Governor of Florida signed into law the Storm Protection Plan Cost
Recovery legislation, which was codified in Section 366.96, F.S. As part of the new law, the
Florida Legislature expressly found that it is in the State's interest: (a) "to strengthen electric
utility infrastructure to withstand extreme weather conditions by promoting the overhead
hardening of electrical transmission and distribution facilities, the undergrounding of certain
electrical distribution lines, and vegetation management;" and (b) "for each electric utility to
mitigate restoration costs and outage times to utility customers when developing transmission
and distribution storm protection plans." ,See Sections 366.96(1)(c)-(d), F.S. Based on these
findings, the Florida Legislature directed each electric utility to file a SPP with the Florida
Public Service Commission ("Commission") covering the immediate ten (10) year planning
period. See Section 366.96(3), F.S. Consistent with this legislative requirement, FPL is
submitting its SPP for the ten-year period of 2020-2029.
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FPL's SPP is a systematic approach to achieve the legislative objectives of reducing restoration
costs and outage times associated with extreme weather events and enhancing reliability. As
required by Rule 25-6.030, F.A.C., FPL's SPP includes, among other things, a description of
each proposed storm protection program, including: (a) how each program will enhance the
existing system to reduce restoration costs and outage times; (b) applicable start and completion
dates for each program; (c) a cost estimate for each program; (d) a comparison of the costs and
benefits for each program; and (e) a description ofhow each program is prioritized. The SPP
also provides an estimate of the annual jurisdictional revenue requirement for each year of the
SPP and additional details on each program for the first three years ofthe SPP (2020-2022),
including estimated rate impacts.
What programs are included in FPL's SPP?
FPL's SPP is, in large parI, a continuation and expansion of its previously approved storm
hardening and storm preparedness programs, and includes the following SPP programs:
o Pole Inspections - Distribution Program
o .Structures/Other Equipment Inspections - Transmission Program
. Feeder Hardening - Distribution Program
r Lateral Hardening (Undergrounding) - Distribution Program
. Wood Structures Hardening (Replacing) - Transmission Program
o Vegetation Management - Distribution Program
o Vegetation Management - Transmission Program
In addition, FPL proposes to implement a new Substation Storm Surge/Flood Mitigation
Program to protect T&D substations and equipment that ue susceptible to storm surge or
flooding during extreme weather events.
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With the exception of the new storm surge/flood mitigation program, the majority of these
programs have been in place since 2007. As demonstrated by recent storm events, these
programs have been successful in reducing restoration costs and outage times following major
storms, as well as improving day-to-day reliability. FPL submits that continuing these
previously approved storm hardening and storm preparedness programs in the SPP, together
with the new storm surge/flood mitigation program, is appropriate and necessary to meet the
requirements of Section 366.96, F.S., and Rule 25-6.030, F.A.C. These programs will address
the expectations ofFPL's customers and other stakeholders for increased storm resiliency, and
will result in fewer outages, reduced restoration costs, and prompt service restoration. The SPP
will continue and expand the benefits of hardening, including improved dayto-day reliability,
to all customers throughout FPL's system.
Please provide an overyiew of the benefits of FPL's SPP.
The major benefit of FPL's SPP is to provide increased resiliency and faster restoration to the
electric infiastructure that FPL's five million customers and Florida's economy rely on for their
electricity needs. Safe and reliable electric service is essential to the life, health, and safety of
the public, and has become a critical component of modern life. Florida remains the most
hurricane-prone state in the nation and, with the significant coast-line exposure of FPL's system
and the fact that the vast majority of FPL's customers live within 20 miles of the coast, a robust
storm protection plan is critical to maintaining and improving grid resiliency and storm
restoration as contemplated by the Legislature in Section 366.96.
FPL's SPP programs have already demonstrated that they have provided and will continue to
provide increased Transmission and Distribution ("T&D") infrastructure resiliency, reduced
restoration time, and reduced restoration cost when FPL is impacted by extreme weather
events. FPL performed an analysis of Hurricanes Matthew and Irma that indicated the
restoration construction man-hours ("CMH"), days to restore, and storm restoration costs for
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these storms would have been significantly greater without FPL's storm hardening programs.
In the case of Hurricane Matthew, FPL estimated that without hardening, restoration would
have taken two additional days (50% longer), and resulted in additional restoration costs of
$105 million (36% higher than actual costs). In the case of Hurricane lrma, FPL estimated that
without hardening, restoration would have taken four additional days (40%o longer), and
resulted in additional restoration costs of $496 million (4}%higher than actual costs). A copy
of FPL's analysis is provided in Appendix A to Exhibit MJ-1.
A detailed summary of the benefits of FPL's SPP is provided in Section II of the SPP, and the
benefits ofeach program are provided in Section IV ofthe SPP.
Does FPL's SPP address recovery of the costs associated with the SPP?
No. FPL anticipates the programs included in the SPP will have zero bill impacts on customer
bills during the first year of the SPP and only minimal bill increases for years two and three of
the SPP. However, the recovery of the actual costs associated with the SPP, as well as the costs
to be included in FPL's Storm Protection Plan Cost Recovery Clause, will be addressed in
subsequent and separate Storm Protection Plan Cost Recovery Clause dockets pursuant to Rule
25'6.03I, F.A.C. The Commission has opened Docket No. 20200092-EI to address Storm
Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
Iil. DESCRIPTION OF EACH SPP PROGRAM
Has FPL provided the information required by Rule 25-6.030(3Xd) for each program
included in its SPP?
Yes. FPL's SPP provides the information required by the Rule 25-6.030(3Xd) for each
program. If applicable, each program description included in FPL's SPP includes: (1) a
description of how each program is designed to enhance FPL's existing transmission and
distribution facilities including an estimate of the resulting reduction in outage times and
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restoration costs due to extreme weather conditions; (2) identification of the actual or estimated
start and completion dates of the program; (3) a cost estimate including capital and operating
expenses; (4) a comparison ofthe costs and the benefits; and (5) a description ofthe criteria
used to select and prioritize proposed storm protection programs. Each of the above listed
descriptions is provided in Section IV of FPL's SPP. Below, I will provide a brief overview
of each program included in FPL's SPP.
Please provide a summary of FPL's Pole Inspection - Distribution Program included in
the SPP.
The Pole Inspection - Distribution Program included in the SPP is a continuation of FPL's
existing Commission-approved distribution pole inspection program. FPL's existing,
Commission-approved distribution pole inspection program is an eight-year pole inspection
cycle for all distribution poles that targets approximately 1/8 of the system annually (the actual
number of poles inspected can vary somewhat from year to year). To ensure inspection
coverage throughout its service territory, FPL established nine inspection zones (based on
FPL's management areas and pole population) and annually performs pole inspections of
approximately 1/8 of the distribution poles in each of these zones, as well as any necessary
remediation as a result of such inspections. As explained in the SPP, recent storm events
demonstrate that FPL's existing distribution pole inspection program has contributed to the
overall improvement in distribution pole performance during storms, resulting in reductions in
storm damage to poles, days to restore, and storm restoration costs.
With approximately 1.2 million distribution poles as of year-end 2019,FPL expects to inspect
approximately 150,000 poles annually (spread throughout its nine inspection zones) during the
2020-2029 SPP period. The total estimated costs for the Pole Inspection - Distribution
Program for the ten-year period of 2020-2029 is $605 million with an annual average cost of
approximately $61 million, which is consistent with historical costs for the existing distribution
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pole inspection program.r A detailed description of the Pole Inspection - Distribution Program
is provided in Section IV(A) of FPL's SPP.
Please provide a summary of FPL's Structures/Other Equipment Inspections -
Transmission Program included in the SPP.
The Structures/Other Equipment Inspections - Transmission Progtam included in the SPP is a
continuation of FPL's existing Commission-approved transmission inspection program. The
SPP will continue FPL's current, Commission-approved transmission inspection program
which requires: (a) transmission circuits and substations and all associated hardware to be
inspected on a six-year cycle; (b) wood structures to be inspected visually from the ground on
an annual basis and climbing or bucket truck inspections to be conducted on a six-year cycle;
and (c) steel and concrete structures to be inspected visually on an annual basis and climbing
or bucket truck inspections to be conducted on a ten-year cycle. As explained in the SPP, the
performance of FPL's transmission facilities during recent storm events indicates FPL's
transmission inspection program has contributed to the overall storm resiliency of the
transmission system and provided savings in storm restoration costs.
FPL expects to inspect approximately 68,000 structures annually during the 2020-2029 SPP
period. The total estimated costs for the Structures/Other Equipment Inspections -
Transmission Program for the ten-year period of 2020-2029 is $500 million with an annual
average cost of approximately $50 million, which is consistent with historical costs for the
1Note, the2020-2029 program costs shown above are projected costs estimated as of the time of this filing.
Subsequent projected and actual costs could vary by as much as l0%o to 15o/o. The annual projected costs,
actual/estimated costs, actuals costs, and true-up of actual costs to be included in FPL's Storm Protection Plan
Cost Recovery Clause will all be addressed in subsequent and separate Storm Protection Plan Cost Recovery
Clause filings pursuant to Rule 25-6.031, F.A.C. The Commission has opened Docket No.20200092-EIto
address Storm Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
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existing transmission inspection program.2 A detailed description of the Structures/Other
Equipment Inspections - Transmission Program is provided in Section IV(B) of FPL's SPP.
Please provide a summary of FPL's Feeder Hardening (EWL) - Distribution Program
included in the SPP.
The Feeder Hardening (EWI-) - Distribution Program included in the SPP is a continuation of
FPL's existing Commission-approved approach to harden existing feeders and certain critical
distribution poles, as well as FPL's initiative to design and construct new pole lines and major
planned work to meet the National Electrical Safety Code's ("NESC") extreme wind loading
criteria ("EWL"). During the period 2006-2019, FPL hardened over 1,300 existing feeders, the
vast majority being Critical Infrastructure Function ("CIF") feeders (i.e., feeders that serve
hospitals, 911 centers, police and fire stations, water treatment facilities, county emergency
operation centers) and Community Project feeders (l.e., feeders that serve other key community
needs like gas stations, grocery stores and pharmacies) throughout FPL's service territory.
Additional feeders were hardened as aresult of FPL's Priority Feeder Initiative, areliability
program that targeted feeders experiencing the highest number of interruptions andlor customers
interrupted. FPL also applied EWL to the design and construction of new pole lines and major
planned work, including pole line extensions and relocations and certain pole replacements.
As provided in previous FPL Annual Reliability Report filings and three-year Storm Hardening
Plan filings (per Rule 25-6.0342, F.A.C.), hardened feeders perform better than non-hardened
feeders, both in day-to-day reliability performance and during severe storms. Additionally, upon
review of the electric utilities' storm hardening and storm prepa.redness programs, the
Commission found that for Hurricane Irma, hardened feeders performed significantly better than
2 See footnote I
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non-hardened feeders with respect to outage rates, pole failures, and CMH required to restore
power.3
FPL expects to harden approximately 250-350 feeders annually, with 100% of FPL's feeders
expected to be hardened or underground by year-end 2024 and with the final costs of the
program to be incurred in2025. The total estimated costs for the Feeder Hardening (EWL) -
Distribution Program for the period of 2020-2025 is $3,206 million with an annual average cost
of approximately $534 million, which is consistent with historical costs for the existing
distribution feeder hardening program.a A detailed description of the Feeder Hardening (EV[,)
- Distribution Program is provided in Section IV(C) of FPL's SPP.
Please provide a summary of FPL's Lateral Hardening (Undergrounding) - Distribution
Program included in the SPP.
The Lateral Hardening (Undergrounding) - Distribution Program included in the SPP is a
continuation and expansion ofFPL's existing three-year Storm Secure Underground Program
Pilot ("SSUP Pilot") implemented in 2018. The SSIIP Pilot is a program that targets certain
overhead laterals that were impacted by recent storms and have a history of vegetation-related
outages and other reliability issues for conversion from overhead to underground. As part ofits
proposed SPP, FPL will complete its existing three-year SSUP Pilot in 2020 and expand the
application of the SSUP during 2021-2029 to the implementation of the system-wide Lateral
Hardening (Undergrounding) - Distribution Program to provide the benefits of underground
lateralhardening throughout its system. As explained in the SPP, the proposal to continue and
expand the application of the SSTIP under the SPP is based on the performance of the
3 See Review of Florida's Electric Utility Hurricane Preparedness and Restoration Actions 2018, Docket No.
20 l7 021 5 -EU (July 24, 2018).
4 See footnote 1.
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underground facilities as compared to overhead facilities and the extensive damage to the
overhead facilities caused by vegetation during Hurricanes Matthew and Irma.
By the end of 2020, the third and final year of the SSUP Pilot, FPL expects to have converted
a total of 220-230 laterals from overhead to underground, which is consistent with the SSIIP
Pilot plan most recently approved in July 2019 in FPL's most recent storm hardening plan
docket, Docket No. 20180144-EI. After completing the SSUP Pilot in 2020, FPL estimates
that it will convert approximately 300-700laterals annually in2021-2023 and approximately
800-900 laterals annually in2024-2029. The total estimated costs for the Lateral Hardening
(Undergrounding) - Distribution Program for the ten-year period of 2020-2029 is $5,101
million with an arurual average cost of approximately $5 10 million.5 A detailed description of
the Lateral Hardening (Undergrounding) - Distribution Program is provided in Section IV(D)
of FPL's SPP.
Please provide a summary of FPL's Wood Structures Hardening (Replacing) -
Transmission Program included in the SPP.
The Wood Structure Hardening (Replacing) - Transmission Program included in the SPP is a
continuation of FPL's existing transmission hardening program to replace all wood transmission
structures with steel or concrete structures. As explained in the SPP, the performance of FPL's
transmission facilities during recent storm events indicates FPL's transmission hardening
program has contributed to the overall storm resiliency ofthe transmission system and provided
savings in storm restoration costs.
As of year-end 2019, 96Yo of FPL's transmission structures, system-wide, were steel or
concrete, with less than2,900 (or 4%) wood structures remaining to be replaced. FPL expects
5 See footnote 1
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to replace the 2,900 wood transmission structures remaining on its system by year-end 2022.
The total estimated costs for the Wood Structure Hardening (Replacing) - Transmission
Program for the period of 2020-2022 is $118 million with an annual average cost of
approximately $39 million, which is a decrease from the historical costs for the existing
transmission hardening program.6 A detailed description of the Wood Structure Hardening
(Replacing) - Transmission Program is provided in Section IV(E) of FPL's SPP.
Please provide a summary of FPL's Substation Storm Surge/Flood Mitigation Program.
The Substation Storm Surge/Flood Mitigation Program is the only new storm hardening
program that FPL proposes to implement as part of its SPP. The Storm Surge/Flood Mitigation
- Transmission and Distribution Program will implement measures to protect T&D substations
and equipment that are susceptible to storm surge or flooding due to extreme weather events.
Historically, several FPL distribution and transmission substations have been impacted by
storm surge and/or flooding as a result of extreme weather conditions. While proactively de-
energizing those substations impacted by storm surge and/or flooding helps reduce damage to
substation equipment, FPL is still required to implement both temporary flood mitigation
efforts and repairs to substation facilities and equipment that become flooded as a result of
extreme weather conditions. Further, flooding and the need to proactively de-energize
substations located in areas susceptible to storm surge and flooding can result in significant
customer outages. To prevent/mitigate future substation equipment damage and customer
outages due to storm surge and flooding, FPL's new Storm Surge/Flood Mitigation Program
will raise the equipment at certain substations above the flood level and construct flood
protection walls around other substations to prevent/mitigate future damage due to storm surge
and flooding.
6 See footnote I
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At this time, FPL has identified between 8-10 substations where it initially plans to implement
storm surge/flood mitigation measures over the next three years (2020-2022). The total
estimated costs for the new Substation Storm Surge/Flood Mitigation over this three-year
period is approximately $23 million with an annual average cost of approximately $8 million
per year.1 A detailed description of the Storm Surge/Flood Mitigation - Transmission and
Distribution Program is provided in Section IV(F) of FPL's SPP.
Please provide a summary of FPL's Vegetation Management - Distribution Program
included in the SPP.
The Vegetation Management - Distribution Program included in the SPP is a continuation of
FPL's existing, Commission-approved distribution vegetation management program. FPL's
cunently-approved distribution vegetation program, includes the following system-wide
vegetation management activities: three-year cycle for feeders; mid-year cycle targeted
trimming for certain feeders; six-year cycle for laterals; and continued education of customers
through its Right Tree, Right Place initiative. In approving FPL's current distribution vegetation
management cycles, the Commission indicated that FPL's distribution vegetation management
cycles were cost-effective and would provide savings to customers. Additionally, as explained
in the SPP, recent storm events demonstrate that FPL's existing distribution vegetation
management program has contributed to the overall improvement in the resiliency of
distribution system during storms, resulting in reductions in storm damage to poles, days to
restore, and storm restoration costs.
Under the SPP, FPL plans to trim, on average, approximately 75,200 miles annually, including
approximately 11,400 miles for feeders (cycle and mid-cycle) and 3,800 miles for laterals,
which is consistent with the historic miles trimmed annually. The total estimated costs for the
7 See footnote I
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Vegetation Management - Distribution Program for the ten-year period of 2020-2029 is $596
million with an annual average cost of approximately $60 million, which is consistent with
historical costs for the existing distribution vegetation management program.8 A detailed
description ofthe Vegetation Management-Distribution Program is provided in Section IV(G)
of FPL's SPP.
Please provide a summary of FPL's Vegetation Management - Transmission Program
included in the SPP.
The Vegetation Management - Transmission Program included in the SPP is a continuation of
FPL's existing transmission vegetation management program. The key elements of FPL's
transmission vegetation management program are to inspect the transmission right-of-ways,
document vegetation inspection results and findings, prescribe a work plan, and execute the
work plan. In its SPP, FPL will continue its current transmission vegetation management plan,
which includes visual and aerial inspections of all transmission line corridors, Light Detection
and Ranging ("LiDAR") inspections of North American Electric Reliability Corporation's
("NERC") transmission line corridors, developing and executing annual work plans to address
identified vegetation conditions, and identiffing and addressing priority and hazard tree
conditions prior to and during storm season. As explained in the SPP, the execution of FPL's
transmission vegetation management plan has been and is a significant factor in mitigating
damage to transmission facilities and avoiding transmission-related outages.
Under the SPP, FPL plans to inspect and maintain, on average, approximately 7,000 miles of
transmission lines annually, including approximately 4,300 miles for NERC transmission line
corridors and2,100 miles for non-NERC transmission line conidors. This is comparable to
the approximately 7,000 miles inspected and maintained annually, on average for 2011-2019.
8,See footnote 1
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The total estimated costs for the Vegetation Management - Transmission Program for the ten-
year period of 2020-2029 is $96 million with an annual average cost of approximately $10
million, which is consistent with historical costs for the existing transmission vegetation
management program.e A detailed description of the Vegetation Management - Transmission
Program is provided in Section IV(H) of FPL's SPP.
TV. ADDITIONALDETAILS FORFIRST THREE YEARS OF THE SPP
Has FPL provided additional project-level details and information for the first year
(2020) of the SPP?
Yes. The following additional information required by Rule 25-6.030(3)(e)(1), F.A.C., for the
first year (2020) of the SPP is provided in Appendix E to FPL's SPP: ( 1) the actual or estimated
construction start and completion dates; (2) a description of the affected existing facilities,
including number and type(s) of customers served, historic service reliability performance
during extreme weather conditions, and how this data was used to prioritize the proposed storm
protection project; and (3) a cost estimate including capital and operating expenses.
Additionally, a description ofthe criteria used to select and prioritize proposed storm protection
projects is included in the description ofeach proposed SPP program provided in Section IV
ofthe SPP.
Does FPL's SPP provide sufficient detail to develop preliminary estimates of the rate
impacts for the second and third years (2021-2022) of the SPP?
Yes. As required by Rule 25-6.030(3Xe)(2), F.A.C., FPL has provided the estimated number
and costs of projects under each specific SPP program, which information was used to develop
the estimated rate impacts for202l-2022. This information is provided in Appendix C to FPL's
SPP.
a.
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e See footnote I
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Did FPL provide a description of its vegetation management activities under the SPP for
the first three years (2020-2022) of the SPP?
Yes. The following additional information required by Rule 25-6.030(3)(f), F.A.C., for the
first three years (2020-2022) of the vegetation management activities under the SPP is provided
in Sections IV(G) and IV(H) of FPL's SPP and Appendix C to FPL's SPP: the projected
frequency (trim cycle); the projected miles of affected transmission and distribution overhead
facilities; and the estimated annual labor and equipment costs for both utility and contractor
personnel. Additionally, descriptions of how the vegetation management activities will reduce
outage times and restoration costs due to extreme weather conditions are provided in Sections
IV(G) and IV(H) of FPL's SPP.
Has FPL provided the annual jurisdictional revenue requirements for the 2020-2029
SPP?
Yes. Pursuant to Rule 25-6.030(3Xg), F.A.C., FPL has provided the estimated annual
jurisdictional revenue requirements in Section VI of the SPP. While FPL has provided
estimated costs by program as of the time of this filing and associated total revenue
requirements in its SPP, consistent with the requirements of Rule 25-6.030, F.A.C., subsequent
projected and actual program costs submitted for cost recovery through the Storm Protection
Plan Cost Recovery Clause (per Rule 25-6.031, F.A.C.) could vary by as much as l0-15%o,
which variations would also impact the associated estimated revenue requirements and rate
impacts. The projected costs, actuall estimated costs, actuals costs, and true-up ofactual costs
to be included in FPL's Storm Protection Plan Cost Recovery Clause will all be addressed in
subsequent filings in separate Storm Protection Plan Cost Recovery Clause dockets pursuant
to Rule 25-6.031, F.A.C.ro
Has FPL estimated the rate impacts for each of the first three years of the SPP?
a.
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10 The Commission has opened Docket No. 20200092-EI to address Storm Protection Plan Cost Recovery Clause
petitions to be filed the third quarter of 2020.
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FPL anticipates the programs included in the SPP will have zero bill impacts on customer bills
during the first year of the SPP and only minimal bill increases for years two and three of the
SPP. An estimate of the hypothetical overall rate impacts for the first three years of the SPP
(2020-2022) based on the total program costs reflected in this filing, without regard for the fact
that FPL remains under a general base rate freeze pursuant to a Commission-approved
settlement agreement through December 31, 2021, are provided in Section VII of the SPP. The
projected costs, actual/estimated costs, actuals costs, and true-up ofactual costs to be included
in FPL's Storm Protection Plan Cost Recovery Clause will all be addressed in subsequent
filings in separate storm protection plan cost recovery clause dockets pursuant to Rule 25-
6.031, F.A.C.rr
V. CONCLUSION
Does FPL believe that its SPP will achieve the legislative objectives of Section 366.96, F.S.,
to reduce costs and outage times associated with extreme weather events by promoting
the overhead hardening of electrical transmission and distribution facilities, the
undergrounding of certain electrical distribution lines, and vegetation management?
Yes. While no electrical system can be made completely resistant to the impacts of hurricanes
and other extreme weather conditions, FPL's SPP provides a systematic approach to achieve
the legislative objectives of reducing restoration costs and outage times associated with extreme
weather events and enhancing reliability. As explained above and in further detail in the SPP,
FPL's SPP programs are largely a continuation and expansion of FPL's already successful and
ongoing storm hardening and storm preparedness programs previously approved by the
Commission, as well as a new storm hardening program to protect T&D substations and
equipment from storm surge and flooding due to extreme weather events. These SPP programs
lrSee footnote 10
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will continue to provide increased T&D infrastructure resiliency, reduced restoration time, and
reduced restoration costs when FPL's system is impacted by extreme weather events. FPL's
SPP appropriately and effectively maintains and builds on FPL's commitment to provide safe
and reliable electric service to customers, and to meet the needs and expectations of our
customers, today and for many years to come.
Does this conclude your direct testimony?
Yes.
l9
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 1 of 48
Florida Power & Light Company
Storm Protection Plan
2020-2029
(Rule 25-6.030, F.A.C.)
Docket No. 20200071-El
April 10, 2020
TABLE OF CONTENTS
Executive Summary.
The 2020-2029 SPP will Strengthen FPL's lnfrastructure to
Withstand Extreme Weather Conditions and will Reduce
Restoration Costs and Outage Times
Description of Service Area and T&D Facilities..........
2020-2029 SPP Programs..........
A. Pole lnspections-Distribution Program.....................
1. Description of the Program and Benefits..........
2. Actual/Estimated Start and Completion Dates .
3. CostEstimates..........
4 Comparison of Costs and Benefits.......
B
5. Criteria used to Select and Prioritize the Program
Structures/Other Equipment lnspections - Transmission
Program
1. Description of the Program and 8enefits..............
2. Actual/Estimated Start and Completion Dates
3 Cost Estimates.....
4. Comparison of Costs and 8enefits.............
5. Criteria used to Select and Prioritize the Program ..
C. FeederHardening (EWL)-Distribution Program..............
1. Description of the Program and 8enefits.................
2. Actual/Estimated Start and Completion Dates ........
3 Cost Estimates
D
4. Comparison of Costs and Benefits.............
5. Criteria used to Select and Prioritize the Program ........
Lateral Hardening (Undergrounding) - Distribution Program...
1. Description of the Program and 8enefits.............
2. Actual/Estimated Start and Completion Dates
3. CostEstimates..........
4. Comparison of Costs and Benefits.............
5. Criteria used to Select and Prioritize the Program ........
Docket No. 20200O71-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1, Page 2 of 48
.3
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IV
Docket No. 202O0071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 3 of 48
E Wood Structures Hardening (Replacing) - Transmission
Program
1. Description of the Program and Benefits..............
2. ActualiEstimated Start and Completion Dates.....
3. CostEstimates.........
4. Comparison of Costs and Benefits.............
5. Criteria used to Select and Prioritize the Program
F. Substation Storm Surge/Flood Mitigation Program
L Description of the Program and 8enefits.....................
2. Actual/Estimated Start and Completion Dates
3. CostEstimates.........
4. Comparison of Costs and Benefits.............
5. Criteria used to Select and Prioritize Projects.............
G. Vegetation Management - Distribution Program ..........
1. Description of the Program and Benefits.....................
2. Actual/Estimated Staft and Completion Dates
3. CostEstimates.........
4. Comparison of Costs and Benefits.............
5. Criteria Used to Select and Prioritize the Program......
H. Vegetation Management - Transmission Program
1. Description of the Program and Benefits.....................
2. Actual/Estimated Start and Completion Dates
3. CostEstimates.........
4. Comparison of Costs and Benefits.............
5. Criteria used to Select and Prioritize the Programs.....
Detailed lnformation on the First Three Years of the SPP (2020-
2022)
A. Detailed Description for the First Year of the SPP (2020).......................
B Detailed Description of the Second and Third Years of the
sPP (2021-2022)
c Detailed Description of the Vegetation Management
Activities for the First Three Years of the SPP (2020-2022)
Estimate of Annual Jurisdictional Revenue Requirements for the
2020-2029 SPP......... ..r..............
26
26
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VI
42
Vll. Estimated Rate lmpacts for First Three Years of the SPP (2020-
2022)
Vlll. Conclusion
Appendices:
Appendix A -
Docket No. 2O2O0071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 4 of 48
FPL's Third Supplemental Response to Staffs First Data
Request No. 29 ('Third Supplemental Amended") in Docket No.
2017021s-El
FPL Management Areas and Customers Served
FPL 2020-2029 SPP Estimated Annual Costs and Estimated
Number and Costs of Projects
FPL Distribution Design Guidelines
Project Level Detail for First Year of the SPP (2020)
43
44
Appendix B -
Appendix C -
Appendix D -
Appendix E -
ilt
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 5 of 48
Florida Power & Light Gompany
2020-2029 Storm Protection Plan
l. Executive Summary
Pursuant to Section 366.96, Florida Statutes ("F.S."), and Rule 25-6.030, Florida
Administrative Code ("F.A.C.'), Florida Power & Light Company ('FPL") submits its Storm
Protection Plan for the ten (10) year period 2020-2029 (hereinafter, the "SPP'). As
explained herein, the SPP is largely a continuation of FPL's successful storm hardening
and storm preparedness programs previously approved by the Florida Public Service
Commission ("Commission") over the last fourteen years. FPL anticipates the programs
included in the SPP will have zero bill impacts on customer bills during the first year of
the SPP and only minimal bill increases for years two and three of the SPP.1
Since 2006, FPL has been implementing Commission-approved programs to strengthen
its transmission and distribution ("T&D") infrastructure. These programs include multiple
storm hardening and storm preparedness programs, such as feeder hardening, replacing
wood transmission structures, vegetation management, and pole inspections. As
demonstrated by recent storm events, these ongoing storm hardening and storm
preparedness programs have resulted in FPL's T&D electricalgrid becoming more storm
resilient, experiencing less infrastructure damage and reduced restoration times, as
compared to non-hardened facilities. These programs have also provided significant
improvements in dayto-day reliability.
The success of FPL's storm hardening and storm preparedness programs has been
achieved through the development and implementation of FPL's fonuard-looking storm
hardening, grid modernization, and reliability initiatives and investments, combined with
the use of cutting-edge technology and strong employee commitment. Under the SPP,
FPL remains committed to continue these successful and industry-leading programs to
1 The recovery of the costs associated with the SPP, as well as the actual and projected costs to
be included in FPL's Storm Protection Plan Cost Recovery Clause, will be addressed in a
subsequent and separate Storm Protection Plan Cost Recovery Clause docket pursuant to Rule
25-6.031, F.A.C.
1
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 6 of 48
further strengthen its T&D infrastructure, mitigate restoration costs and outage times,
continue to provide safe and reliable electric service to customers, and meet future
increasing needs and expectations.
As stated previously, FPL's SPP is, in large part, a continuation and expansion of its
previously approved storm hardening and storm preparedness programs, and includes
the following SPP programs:
. Pole lnspections - Distribution Program
. Structures/Other Equipment Inspections - Transmission Program
. Feeder Hardening (EWL) - Distribution Program
. Lateral Hardening (Undergrounding) - Distribution Program
. Wood Structures Hardening (Replacing) - Transmission Program
. Vegetation Management - Distribution Program
. Vegetation Management - Transmission Program
ln addition, FPL will implement a new Substation Storm Surge/Flood Mitigation Program
to harden certain targeted substations that, based on prior experience, are susceptible to
storm surge or flooding during extreme weather events.
With the exception of the new storm surge/flood mitigation program, the majority of the
programs included in the SPP have been in place since 2007. As demonstrated by recent
storm events, these programs have been successful in reducing restoration costs and
outage times following major storms, as well as improving dayto-day reliability. FPL
submits that continuing these previously approved storm hardening and storm
preparedness programs in the SPP, together with the new storm surge/flood mitigation
substation program, is appropriate and necessary to address the mandates set forth in
Section 366.96, F.S., and Rule 25-6.030, F.A.C., as well as the expectations of FPL's
customers and other stakeholders for increased storm resiliency and will result in fewer
2
Docket No. 2O2OOO71-EI
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-'1 , Page 7 of 48
outages, reduced restoration costs, and prompt service restoration.2 The SPP will
continue and expand the benefits of hardening, including improved day{o-day reliability,
to all customers throughout FPL's system.
The following sections provide information and details on FPL's SPP as required by and
in compliance with Rule 25-6.030, F.A.C. For the reasons explained below, FPL submits
that implementing the SPP is necessary and appropriate to achieve the goals and
requirements expressed by the Florida Legislature in Section 366.96, F.S., to reduce
restoration costs and outage times associated with extreme weather events and improve
overall service reliability to customers and the State of Florida by promoting the overhead
hardening of electrical transmission and distribution facilities, the undergrounding of
certain electrical distribution lines, and vegetation management.
ll. The 2020-2029 SPP will Stren qthen FPL's lnfrastructure
to Withstand Extreme Weather Gonditions and will
Reduce Restoration Costs and Outaqe Times
Pursuant to Rule 25-6.030(3)(a), F.A.C., this section provides an overview of how the
SPP will strengthen FPL's electric utility infrastructure to withstand extreme weather
conditions by promoting the overhead hardening of electricaltransmission and distribution
facilities, the undergrounding of certain electrical distribution lines, and vegetation
management. Consistent with Rule 25-6.030(3Xb), F.A.C., this section also provides a
summary of how the SPP is expected to further reduce restoration costs and outage times
associated with extreme weather conditions and, therefore, improve overall service
reliability.
To date, significant progress has been made toward strengthening FPL's infrastructure.
For example, at year-end 2019, approximalely 54o/o of FPL's distribution feeders have
been either hardened or placed underground, and approximately 96% of FPL's
transmission structures are either steel or concrete. Also, since 2006, FPL has completed
multiple system-wide cycles of distribution and transmission pole inspections and
2 As explained below, a couple of the programs included in the SPP are expected to be completed
within the next severalyears.
3
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection PIan
Exhibit MJ-'l , Page 8 of 4B
vegetation management. Within the next few years several significant milestones are
also expected to be reached, including replacement of all wood transmission structures
with steel or concrete structures by year-end 2022 and for all feeders to be hardened or
placed underground by year-end 2024.
FPL also implemented a three-year Storm Secure Underground Program Pilot in 2018
("SSUP Pilot") that converts certain targeted overhead laterals - laterals that have been
impacted by recent storms and have a history of vegetation-related outages and other
reliability issues - to underground laterals. At year-end 2020, the final year of the SSUP
Pilot, FPL expects 220-230 of these targeted laterals to be converted from overhead to
underground. ln addition, FPL's Design Guidelines incorporate and apply extreme wind
loading (.EWL') criteria to the design and construction of all new overhead pole lines and
major planned work, including pole line extensions, relocations, and certain pole
replacements.
FPL's SPP programs have already demonstrated that they have and will continue to
provide increased T&D infrastructure resiliency, reduced restoration time, and reduced
restoration costs when FPL's system is impacted by severe weather events. ln FPL's
Third Supplemental Response to Staff's First Data Request No. 29 ("Third Supplemental
Amended") in Docket No. 20170215-E1,3 FPL prepared and submitted an analysis of
Hurricanes Matthew and lrma that indicated the restoration construction man-hours
('CMH'), days to restore, and storm restoration costs for these storms would have been
significantly higher without FPL's storm hardening programs. Below is a summary of the
results of FPL's analysis:
Without Hardeni Hurricane Matthew Hurricane lrma
3 The Commission opened Docket No. 20170215-El to review electric utility preparedness and
restoration actions and to identify potential areas where infrastructure damage, outages, and
recovery time for customers could be minimized in the future.
Additional CMH (%)93,000 (36%)483,000 (40o/o)
2 (50o/o)4 (40%)Additionaldays to restore (%)
$105 (36%)$4e6 (40%)Additional restoration costs
($millions) (%)
4
Docket No. 2O2O0071-E\
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page g of 48
A copy of FPL's Third Supplemental Amended Response in Docket No. 20170215-El,
including the analysis referenced above, is provided in Appendix A. Based on a 40-year
net present value analysis, the savings achieved from storm hardening would equate to
$653 million (for a storm occurring once every three years) and $406 million (for a storm
occurring once every five years) for a storm similar to Hurricane Matthew and $3.1 billion
(for a storm occurring once every three years) and $1.9 billion (for a storm occurring once
every five years) for a storm similar to Hurricane lrma.
These programs have also provided increased levels of dayto-day reliability. For
example, FPL has previously submitted reports to the Commission that show hardened
feeders have performed approximately 40% better (i.e., fewer outages) on a day{o-day
basis than non-hardened feeders.a Further details on the benefits of the SPP programs
are provided throughout the remaining sections of this SPP.
Although FPL's storm preparedness and hardening programs to date have produced a
more storm resilient and reliable T&D electrical grid, FPL must continue its efforts to
storm-harden its T&D electrical grid consistent with the findings, conclusions, and
objectives of the Florida Legislature in Section 366.96, F.S. lndeed, Florida remainsthe
most hurricane-prone state in the nation and, with the significant coast-line exposure of
FPL's system and the fact that the vast majority of FPL's customers live within 20 miles
of the coast, a robust storm protection plan is critical to maintaining and improving grid
resiliency and storm restoration.
Safe and reliable electric service is essential to the life, health, and safety of the public,
and has become a critical component of modern life. lmportantly, as evidenced by the
significant numbers of Florida's workforce that are working remotely during the COVID-
19 pandemic, today's digital society, economy, national security, and daily life are more
dependent on reliable electric service than ever before. While no electrical system can
be made completely resistant to the impacts of hurricanes and other extreme weather
conditions, the programs included in FPL's SPP have already demonstrated that they
5
a See Appendix A
Docket No. 20200071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , Page 10 of 48
mitigate and will continue to mitigate the impacts of future storms.s While FPL's nation-
leading initiatives have made significant progress toward strengthening FPL's
infrastructure, continuing these previously approved storm hardening and storm
preparedness programs in the SPP, together with the new storm surgelflood mitigation
substation program, is appropriate and crucial to further mitigate restoration costs and
outage times, continue to provide safe and reliable electric service to customers, and
meet current and future needs and expectations of customers, today and for many years
to come.
lll. Description of Servic e Area and T&D Facilities
Pursuant to Rule 25-6.030(3)(c), F.A.C., this section provides a description of FPL's
service area, including areas prioritized for enhancement, if any, and any areas where
FPL has determined that enhancement of its existing T&D facilities would not be feasible,
reasonable, or practical at this time.
Today, FPL's service territory consists of approximately 28,000 square miles. To serve
its more than 5 million customers, FPL has constructed a T&D electric grid that contains
approximately 75,000 miles of electrical lines, including:
. Approximately 42,000 miles of overhead distribution lines;
. Approximately 26,000 miles of underground distribution lines;
. Approximately 7,000 miles of high-voltage transmission lines;
. Approximately 1.2 million distribution poles; and
. Approximately 68,000 transmission structures.
FPL's service territory is divided into sixteen (16) distribution management areas. A map
depicting FPL's service territory and distribution management areas (with the number of
customers served within each management area) is provided in Appendix B.
At this time, FPL has not identified any areas of its service territory where its SPP
programs would not be feasible, reasonable, or practical. While all of FPL's SPP
5 lt is important to note that despite the implementation of these storm hardening and storm
preparedness programs, outages will still occur when severe weather events impact Florida.
6
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-l, Page 11 of 48
programs are currently system-wide initiatives, annual activities are prioritized based on
certain factors such as last inspection date, last trim date, reliability performance, and
efficient resource utilization.o At this time, there is no area specifically targeted or
prioritized for enhanced performance based on its geographical location.
lV. 2020-2029 SPP Proqrams
Pursuant to Rule 25-6.030(3XcXd), F.A.C., this section provides a description of each
program included in FPL's SPP. lf applicable, each program description below includes:
(1) a description of how each program is designed to enhance FPL's existing transmission
and distribution facilities including an estimate of the resulting reduction in outage times
and restoration costs due to extreme weather conditions; (2) identification of the actual or
estimated start and completion dates of the program; (3) a cost estimate including capital
and operating expenses; (4) a comparison of the costs and the benefits; and (5) a
description of the criteria used to select and prioritize storm protection programs.
A. Pole lnspections - Distribution Program
1. Description of the Proqram and Benefits
The Pole lnspection - Distribution Program included in the SPP is a continuation of FPL's
existing Commission-approved distribution pole inspection program. Below is an
overview of FPL's existing distribution inspection program and its associated benefits.
a. Overview of the Distribution Pole Inspection Proqram
ln response to the 2004-2005 storm seasons and, in particular, the "large number of poles
throughout Florida that required replacement," the Commission required investor-owned
utilities ("lOUs") to implement an eight-year pole inspection cycle for all wood distribution
poles.T FPL's plan was approved in September 20068 and modified in January 2007.s
6 The criteria and factors used to select and prioritize projects within each SPP program are
described below.
7 See Order No. PSC-06-0144-PAA-El.
8 See Order No. PSC-06-0778-PAA-EU.
e See Order No. PSC-07-0078-EU.
7
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 12 of 48
Subsequently, FPL expanded its distribution pole inspection plan to also include concrete
poles.
FPL's eight-year pole inspection cycle for all distribution poles targets approximately 1/8
of the system annually (the actual number of poles inspected can vary somewhat from
year to year). To ensure inspection coverage throughout its service territory, FPL
established nine (9) inspection zones (based on FPL's management areas and pole
population)and annually performs pole inspections of approximately 1/8 of the distribution
poles in each of these zones, as well as any necessary remediation as a result of such
inspections. FPL utilizes Osmose Utilities Services, lnc. ("Osmose"), an industry-leading
pole inspection contractor, to perform the system-wide inspection of its distribution poles.
FPL's strength and loading calculations for its distribution poles and pole inspections are
based on the National Electrical Safety Code's ("NESC') Grade B construction standard,
as outlined by Table 261-1A section 26 of the NESC. Osmose utilizes mobile computing
technology to record inspection data and to calculate strength and loading. The loading
calculation, span lengths, attachment heights, and wire sizes are recorded in the mobile
computer to determine whether the remaining pole strength capacity meets or exceeds
NESC requirements. This data is then transferred to FPL's Geographic lnformation
System ("GlS'). Pole locations inspected by Osmose are also randomly audited by FPL
to verify that inspections are completed and meet inspection standards.
lnspections include a visual inspection of all distribution poles from the ground-line to the
top of the pole to identify visual defects (e.9., woodpecker holes, split tops, decayed tops,
cracks, etc.). lf, due to the severity of the defects, the poles are not suitable for continued
service, the poles are designated for replacement.
Wood poles that pass the above-ground visual inspection are excavated to a depth of 18"
(where applicable), and sounded and bored to determine the internal condition of the
pole. Poles encased in concrete or asphalt are not excavated, but are sounded and bored
to determine their internal condition using a standard industry-accepted inspection
process called "Shell Boring." All suitable wood poles receive external and/or internal
preservative treatment or, if not suitable, are replaced. Strength calculations are also
8
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page '13 of 48
performed on wood poles to determine compliance with NESC requirements. The poles
that are not suitable for continued service are designated for replacement or remediation.
ln 2014, FPL obtained Commission approval to: (1) exempt the loading assessment
during the second eight-year cycle for any pole that had less than 80% of full load during
FPL's initialeight-year cycle; and (2) excavate Chromium CopperArsenate ('CCA") poles
every 28 years (extended from 16 years originally approved by the Commission).1o To
ensure that these exceptions to the standard eight-year inspection cycle do not
compromise existing safety and storm hardening programs, FPL conducts annual testing
on 1o/o of the exempted poles.
b. Benefits of the Distribution Pole Inspection Proqram
The Commission has previously found that "efforts to maintain system components can
reduce the impact of hurricanes and tropical storms upon utilities' transmission and
distribution systems," and noted that an "obvious key component in electric infrastructure
is the transmission and distribution poles."lt The Commission has also previously
identified multiple benefits of and reasons for justifying pole inspections cycles for electric
utilities, including, but no limited to: the likelihood of increased hurricane activity in the
future, the high probability for equipment damage if a pole fails during a storm; the
likelihood that failure of one pole often causes other poles to fail; the fact that deteriorated
poles are more prone to fail when exposed to high winds; the fact that Florida electric
utilities replaced nearly 32,000 poles during the 2004 storm restoration efforts; and the
fact that restoration times increase significantly when a large number of poles fail, which
limits the electric utilities' ability to respond quickly to widespread outages.l2
ln addition to the benefits discussed above that underlie the creation of the Commission's
mandated pole inspection requirements, recent storm events indicate that FPL's
distribution pole inspection program has contributed to the overall improvement in
distribution pole performance during storms, resulting in reductions in storm damage to
poles, days to restore, and storm restoration costs. The table below compares distribution
10 See Order No. PSC-14-0594-PAA-El
11 See Order No. PSC-06-0144-PAA-E.
12 See id.
I
Docket No. 2O20OO71-E\
FPL'i 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 14 of 48
pole performance for Hurricane Wilma, which occurred in 2005 before FPL implemented
its current distribution pole inspection program, and Hurricane lrma, which occurred in
2017 after FPL implemented its current distribution pole inspection program:
Hurricane Wilma Hurricane lrma
H u rricane Strength (Category)3 4
Customer Outages (Millions)3.2 4.4
Distribution Poles Replaced >12,400 <2,90013
Total Days to Restore 18 10
Average Days to Restore 5.4 2.1
FPL's Commission-approved distribution pole inspection program has facilitated the
replacement and/or strengthening of over 140,000 distribution poles since it was first
implemented in 2006 and has directly improved and will continue to improve the overall
health and storm resiliency of its distribution pole population.
2. Actual/Estimated Start and Comoletion Dates
The SPP will continue FPL's ongoing Commission-approved distribution pole inspection
program described above. With approximately 1.2 million distribution poles as of year-
end 2019, FPL expects to inspect approximately 150,000 poles annually (spread
throughout its nine inspection zones) during the 2020-2029 SPP period.
3. Cost Estimates
Estimated/actual annual distribution pole inspection costs are a function of the number of
inspections estimated to be/actually completed and the number of poles estimated to
be/actually remediated/replaced as a result of the annual inspections. Although costs to
inspect the poles are operating expenses, the vast majority of pole inspection program
costs are capital costs resulting from remediation/replacement of poles that fail
inspection.
13 Approximately 99% of distribution poles replaced after Hurricane lrma were non-hardened
poles.
10
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 15 of 4B
The table below provides a comparison of the 2017-2019 total actual distribution pole
inspection costs with the 2020-2022 (first three years of the SPP) total estimated
distribution pole inspection costs and the 2020-2029 lolal estimated distribution pole
inspection costs:
Total Program Costs Annual Average Program
millions Costs millions
Further details regarding SPP estimated distribution pole inspection costs, including
estimated annual capitalexpenditures and operating expenses, are provided in Appendix
c.14
4. Comparison of Costs and Benefits
As provided in Section (|VXAX3) above, during 2020-2029, total costs for FPL's Pole
lnspection - Distribution Program are expected to average approximately $61 million per
year. Benefits associated with FPL's Pole lnspection - Distribution Program, discussed
in Sections ll and |V(AX1)(b) above, include a more storm resilient pole population that
will result in reductions in pole failures and poles needing to be replaced during storms,
fewer storm-related outages and reductions in storm restoration costs.
5. Criteria used to Select and Prioritize the Proqram
Poles to be inspected annually are selectediprioritized within each of the nine (9)
inspection zones established throughout FPL's service territory based on the last cycle's
inspection dates, to ensure that poles are in compliance with FPL's established eight-year
14 Note, lhe 2020-2029 program costs shown above are projected costs estimated as of the time
of this filing. Subsequent projected and actual costs could vary by as much as 10% to 15%. The
annual projected costs, actual/estimated costs, actuals costs, and true-up of actual costs to be
included in FPL's Storm Protection Plan Cost Recovery Clause will all be addressed in
subsequent and separate Storm Protection Plan Cost Recovery Clause filings pursuant to Rule
25-6.031, F.A.C. The Commission has opened Docket No.20200092-EI to address Storm
Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
2017-2019 $1 sz $51
2020-2022 $1 70 $57
2020-2029 $605 $61
11
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , Page 16 of 48
cycle. As such, approximately 1/8 of the distribution poles in each inspection zone are
inspected annually.
At this time, FPL has not identified any areas where the Pole lnspection - Distribution
Program would not be feasible, reasonable or practical.
B. Structures/Other Equipment lnspections Transmission
Program
1. Description of the Proqram and Benefits
The StructuresiOther lnspections - Transmission Program included in the SPP is a
continuation of FPL's existing Commission-approved transmission inspection program.
Below is an overview of FPL's existing transmission inspection program and the
associated benefits.
a Overuiew of the lransmission ln sncafion Prooram
ln 2006, as part of its Storm Preparedness lnitiative No. 3, the Commission required
electric utilities to develop and implement plans to fully inspect alltransmission structures,
substations, and all hardware associated with these facilities on a six-year cycle.
Consistent therewith, FPL implemented a Commission-approved transmission inspection
plan in 2006 and has continued that plan to date.
Under its Commission-approved transmission inspection plan, FPL inspects its
transmission circuits, substations, and other equipment on a six-year cycle. Additionally,
all of FPL's transmission structures are visually inspected from the ground each year.
Finally, FPL performs climbing or bucket truck inspections on all wood transmission
structures on a six-year cycle and all steel and concrete structures on a ten-year cycle.
lnspections for wood structures include an overall assessment of the condition of the
structures, as well as other pole/structure components including the foundation, all
attachments, insulators, guys, cross-braces, cross-arms, and bolts. lf a wood
transmission structure does not pass visual inspection, it is designated for replacement
with a concrete or steel transmission structure.
12
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 17 of 48
For steel and concrete structures, the visual inspection includes an overall assessment
of the structure condition (e.9., cracks, chips, exposed rebar, and rust) as well as other
pole/structure components including the foundation, all attachments, insulators, guys,
cross-braces, cross-arms, and bolts. lf a concrete or steel pole/structure fails the
inspection, it is designated for repair or replacement.
The SPP will continue FPL's current transmission inspection program which requires: (a)
transmission circuits and substations and all associated hardware to be inspected on a
six-year cycle; (b) wood structures to be inspected visually from the ground each year
and climbing or bucket truck inspections to be conducted on a six-year cycle; and (c) steel
and concrete structures to be inspected visually each year and climbing or bucket truck
inspections to be conducted on a ten-year cycle.
b. Benefits of the Transmission lnspection Program
As noted in Section IV(AX1)(b) above, the Commission has found numerous benefits and
reasons justifying inspections of electrical utility facilities, including transmission facilities.
lmportantly, the transmission system is the backbone of the electric grid. While outages
associated with distribution facilities (e.9., a transformer, lateral orfeeder) can result in
an outage affecting anywhere from a few customers up to several thousands of
customers, a transmission related outage can affect tens of thousands of customers.
Additionally, an outage on a transmission facility could cause cascading (a loss of power
at one transmission facility can trigger the loss of power on another interconnected
transmission facility, which in turn can trigger the loss of power on another interconnected
transmission facility, and so on) and result in the loss of service for hundreds of thousands
of customers. As such, it is imperative that transmission facilities be properly inspected
using appropriate cycles and standards to help ensure they are prepared for storms.
Further, the performance of FPL's transmission facilities during recent storm events
indicates FPL's transmission inspection program has contributed to the overall storm
resiliency of the transmission system and provided savings in storm restoration costs.
The table below compares the performance of FPL's transmission system for Hurricane
Wilma, which occurred in 2005 before FPL implemented its current transmission
13
Docket No. 202OO071-E\
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 1B of 48
inspection program, and Hurricane lrma, which occurred in 2017 after FPL implemented
its current transmission inspection program:
Transmission Facilities Hurricane Wilma Hurricane lrma lm ent
As shown above, the impacts on FPL's transmission facilities associated with Hurricane
lrma were significantly reduced from those experienced with Hurricane Wilma, even
though Hurricane lrma's winds were stronger and its path impacted substantially more of
FPL's facilities. As reflected in the Commission's reasoning for mandating transmission
facility inspections, FPL submits that its systematic transmission inspection program is a
key factor for this improved performance.
2. Actual/Estimated Start and Comoletion Dates
The SPP will continue FPL's ongoing Commission-approved transmission inspection
program described above. This requires FPL to inspect: (a) transmission circuits and
substations and all associated hardware on a six-year cycle; (b) wood structures to be
visually inspected from the ground each year and conduct climbing or bucket truck
inspections on a six-year cycle; and (c) steel and concrete structures visually each year
and conduct climbing or bucket truck inspections on a ten-year cycle.
3. Cost E mates
Estimated/actual annual transmission inspection costs are a function of the number of
inspections estimated to be/actually completed and the transmission facilities estimated
to be/actually remediated/replaced as a result of those annual inspections. Although the
inspection costs are operating expenses, the vast majority of the transmission inspection
program costs are capital costs resulting from remediationireplacement of facilities that
fail inspection.
The table below provides a comparison of the 2017-2019 total actual transmission
inspection costs with the 2020-2022 (first three years of the SPP) total estimated
215 38%Line Section Outages 345
620/o24192Substation Outages
100 5 95o/oStructures Failed
14
Docket No. 2O2OO071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 19 of 48
transmission inspection costs and the 2020-2029 total estimated transmission inspection
costs:
Total Program Costs Annual Average Program
millions Gosts illions
Further details regarding the SPP estimated transmission inspection costs, including
estimated annualcapitalexpenditures and operating expenses, are provided in Appendix
c.15
4. Comparison of Costs and Benefits
As provided in Section |V(BX3) above, during 2020-2029, total costs for FPL's
Structures/Other lnspections - Transmission Program are expected to average
approximately $50 million per year. Benefits associated with the Structures/Other
lnspections - Transmission Program discussed in Sections ll and |V(BX1)(b) above,
include avoiding outages that can affect tens of thousands of customers and, in particular,
cascading outages where the loss of service can affect hundreds of thousands of
customers.
5 Criteria used fo Se lect and Prioritize the Prooram
As explained above, FPL visually inspects from the ground alltransmission structures on
an annual basis. For the inspection of transmission circuits and substations and all
associated hardware, the facilities are selected/prioritized throughout FPL's service
territory based on the last cycle's inspection dates, to ensure that facilities are inspected
in compliance with the established six-year inspection cycle. Similarly, for bucket truck
or climbing inspections, structures are selected/prioritized throughout FPL's service
territory based on the last cycle's inspection dates, to ensure that structures are inspected
2017-2019 $1 28 $43
2020-2022 $e7 $32
2020-2029 $500 $50
15 See footnote 14
15
Docket No. 20200071-El
FPL's 2020-2o29 Storm Protection Plan
Exhibit MJ-1, Page 20 of 4B
in compliance with the established six-year (wood) and ten-year (steel and concrete)
cycles.
At this time, FPL has not identified any areas where the Structures/Other lnspections -
Transmission Program would not be feasible, reasonable or practical.
c. Feeder Hardening (EWL) - Distribution Program
1. Description of the Proqram and Benefits
The Feeder Hardening (EWL) - Distribution Program included in the SPP is a
continuation of FPL's existing Commission-approved approach (most recently approved
in Docket No.20180144-El) to harden existing feeders and certain critical distribution
poles, as well as FPL's initiative to design and construct new pole lines and major planned
work to meet the NESC's extreme wind loading criteria ("EWL'). FPL will continue the
distribution feeder hardening program unlil2024, when FPL expects 100% of its feeders
to be hardened or underground. Below is an overview of FPL's existing distribution feeder
hardening program and the associated benefits.
a Overuiew of the Distribution Fe erler H a rden i no P roo ra m
The foundation for FPL's distribution feeder hardening program was the extensive
forensic and other analyses that FPL conducted after Hurricane Wilma.16 These analyses
concluded that "wind only" (as opposed to, for example, trees or other flying debris) was
the predominant root cause of distribution pole breakage. This data, together with the
overall performance of FPL's transmission poles thatwere already built to the NESC EWL
standards and the performance of hardened feeders during Hurricanes Matthew and
Irma, formed the basis for FPL's feeder hardening strategy.
The SPP will continue FPL's previously approved approach to apply EWL criteria to
harden existing distribution feeders and certain critical poles. The NESC extreme wind
map for Florida will continue to be applied to FPL's system by dividing the application of
16 These analyses were conducted either directly by FPL or with the aid of external resources
(e.9., KEMA, lnc.).
16
Docket No. 20200071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , Page 21 of 48
EWL into three wind regions, corresponding to expected extreme winds of 105, 130 and
145 mph, as shown below.
FPL Extreme Wind Reqions - mph (meter/sec)
r{o(G3l
105 mph
130 mph
145 mph
$(GA
By evaluating each of the counties served by FPL, including each county's applicable
wind zones, FPL determined that utilizing three extreme wind regions of 105, 130 and
145 mph for its service territory was appropriate for the following reasons:
A smaller number of wind regions generate advantages through efficiency of
work methods, training, engineering and administrative aspects (e.9.,
standards development and deployment); and
I
n
a
a
The SPP will also continue to utilize FPL's Design Guidelines and processes that apply
EWL criteria to the design and construction of new pole lines and major planned work,
including pole line extensions and relocations and certain pole replacements. Depending
on the scope of the work that is performed in a particular project, this could result in the
EWL hardening of an entire circuit (in the case of large-scale projects) or in EWL
hardening of one or more poles (in the case of small projects) so that the affected circuit
will be in a position to be fully EWL hardened in the future. The Design Guidelines are
Using 105, 130 and 145 mph wind zones is a well balanced approach that
recognizes differences in the EWL requirements in the counties within each
region.
17
Docket No. 20200071-El
FPL'S 2020-2029 Storm Proiection Plan
Exhibit MJ-1, Page 22 of 48
primarily associated with changes in pole class, pole type, and desired span lengths to
be utilized. The Design Guidelines standardize the design and construction of new pole
lines and major planned work to ensure that these projects align with FPL's hardening
strategy.
FPL's current pole sizing guidelines provide for a minimum installation of. Class 2 wood
poles for all new feeder and three-phase lateral work; Class 3 wood pole for two-phase
and single-phase lateral work; and Class 3 wood pole for service and secondary work.
For critical poles, FPL's current pole sizing guidelines provide for the installation of
concrete poles at accessible locations. These guidelines significantly increase the wind
ratings (up to nearly 50 percent) from the Design Guidelines in place prior to 2007. FPL's
current Distribution Design Guidelines are provided in Appendix D.
To determine how an existing overhead circuit or critical pole will be hardened, a field
survey of the circuit facilities is performed. By capturing detailed information at each pole
location, such as pole type, class, span distance, attachments, wire size, and framing, a
comprehensive wind-loading analysis can be performed to determine the current wind
rating of each pole, and ultimately the circuit itself. This data is then used to identify
specific pole locations on the circuit that do not meet the desired wind rating. For all poles
that do not meet the applicable EWL, FPL develops recommendations to increase the
allowable wind rating of the pole.
FPL plans to continue to utilize its "design toolkit" that focuses on evaluating and using
cost-effective hardening options for each location, including:
Storm Guying - lnstalling a guy wire in each direction perpendicular to the line,
which is a very cost-effective option but is dependent on proper field conditions;
Equipment Relocation - Moving equipment on a pole to a stronger pole near-
by;
lntermediate Pole - lnstalling an additionalsingle pole within long span lengths,
which reduce the span length and increases the wind rating of both adjacent
poles;
a
a
a
18
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 23 of 4B
Upgrading Pole Class - Replacing the existing pole with a higher class pole to
increase the pole's wind rating, and;
Undergrounding Facilities - Evaluated on a case-by-case basis using site-
specific factors and conditions.
These options are not mutually exclusive and, when used in combination with sound
engineering practices, provide cost-effective methods to harden a circuit. FPL's design
recommendations also take into consideration issues such as hardening, mitigation
(minimizing damage), and restoration (improving the efficiency of restoration in the event
of failure). Since multiple factors can contribute to losing power after a storm, utilizing
this multi-faceted approach to pole design helps to reduce the amount of work required
to restore power to a damaged circuit.
b. Benefits of the Distribution Feeder Hardeninq Proqram
Distribution feeders are the backbone of the distribution system and are critical
component to providing safe and reliable electric service to FPL's customers. Thus,
improving the storm resiliency of distribution feeders logically provides substantial
benefits for customers. Therefore, hardening distribution feeders has been and continues
to be one of FPL's highest storm hardening priorities.
During the period 2006-2019, FPL hardened over 1,300 existing feeders, the vast majority
being Critical Infrastructure Function ("CIF") feeders (i.e., feeders that serve hospitals,
911 centers, police and fire stations, water treatment facilities, county emergency
operation centers) and Community Project feeders (r.e., feeders that serve other key
community needs like gas stations, grocery stores, and pharmacies) throughout FPL's
service territory. Additional feeders were hardened as a result of FPL's Priority Feeder
Initiative, a reliability program that targeted feeders experiencing the highest number of
interruptions and/or customers interrupted. As of year-end 2019, approximately 54% of
FPL's feeders were either hardened or placed underground. Additionally, FPL has
hardened 125 highway crossings and over 300 '01" switches (first pole out of a substation
with a feeder switch). FPL also applied EWL to the design and construction of new pole
a
a
19
Docket No. 2O200071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1, Page 24 of 48
lines and major planned work, including pole line extensions and relocations and certain
pole replacements.
As provided in previous FPL Annual Reliability Report filings and three-year Storm
Hardening Plan filings (per Rule 25-6.0342, F.A.C.) hardened feeders perform better than
non-hardened feeders. This has been demonstrated in-day-to-day reliability performance
and during severe storms. For example, when comparing day-to-day reliability
performance, hardened feeders have performed 40o/o better than non-hardened feeders.
Also, during Hurricanes Matthew and lrma, hardened feeders performed better than non-
hardened feeders.
Additionally, in Docket No.20170215-EU, the Commission reviewed the electric utilities'
storm hardening and storm preparedness programs and found for Hurricane lrma that:
(1) outage rates were nearly 20% less for hardened feeders than non-hardened feeders;
(2) CMH to restore hardened feeders were 50% less than non-hardened feeders
(primarily due to hardened feeders experiencing less damage than non-hardened
hardened feeders); and (3) hardened feeders had significantly less pole failures as
compared to non-hardened feeders.lT
2. Actual/Estimated Start and Completion Dates
FPL initiated its feeder hardening initiative in 2006. As of year-end 2019, there are
approximately 1,600 feeders remaining to be hardened or placed underground. FPL
expects to harden approximately 250-350 feeders annually, with 100% of FPL's feeders
expected to be hardened or underground by year-end 2024 and with the final costs of the
program to be incurred in 2025.
17 See Review of Florida's Electric Utility Hurricane Prepared ness and Restoration Actions 2018,
Docket No. 20170215-EU (July 24,2018), available at
http://www. psc.state.fl.us/librarvffilinqs/2018/04847-2018/04847-2018.odf.
20
Docket No. 2O200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 25 of 48
3. Cost Estimates
Estimated distribution feeder hardening costs are determined utilizing the length of each
feeder, the average historical feeder hardening cost per mile, and updated cost
assumptions (e.9., labor and materials).
The table below provides a comparison of the 2017-2019 total actual distribution feeder
hardening costs with the 2020-2022 (first three years of the SPP) total estimated
distribution feeder hardening costs and the total estimated distribution feeder hardening
costs to be incurred over the period of 2020-202518:
Total Program Costs Annual Average Program
millions Costs millions
Further details regarding the SPP distribution feeder hardening costs, including estimated
annual capital expenditures are provided in Appendix C.1s
4. Comoarison of Costs and Benefits
As provided in Section lV(C)(3) above, during 2020-2025, total costs for FPL's Feeder
Hardening (EWL) - Distribution Program average approximately $534 million per year
through 2025. Benefits associated with the Feeder Hardening (EWL) - Distribution
Program discussed in Sections ll and |V(CX1)(b) above, include improved storm
resiliency as well as improved dayto-day reliability.
5. Criteria used to Select and Prioritize the Proqram
As explained above, there are approximately 1,600 feeders remaining to be hardened or
placed underground. FPL attempts to spread its annual projects throughout its service
territory. ln prioritizing the remaining existing feeders to be hardened each year,
18 lt is currently estimated that 100% of FPL's feeders will be hardened or underground by year-
end 2024, with the final costs to be incurred in 2025.
1e See footnote 14.
2017-2019 $1,492 $497
2020-2022 $1,958 $653
2020-2025 $3,206 $534
21
Docket No. 2020007l-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 26 of 48
considerations include the feeder's historical reliability performance, restoration
difficulties (e.9., environmentally sensitive areas, islands with no vehicle access, river
crossings, etc.), on-going or upcoming internal/external projects (e.9., FPL maintenance
or system expansion projects, municipal overhead/underground conversion project or
municipal road project) and geographic location.
At this time, FPL has not identified any areas where the Feeder Hardening (EWL) -
Distribution Program would not be feasible, reasonable or practical.
D. Lateral Hardening (Undergrounding) - Distribution Program
1. Description of the Prooram and Benefits
ln 2018, FPL implemented a three-year Commission-approved SSUP Pilot. The SSUP
Pilot is a program that targets ceftain overhead laterals for conversion from overhead to
underground. As part of its SPP, FPL will expand undergrounding laterals in 2021-2029.
Below is an overview of FPL's Lateral Hardening (Undergrounding) - Distribution
Program and the associated benefits.
a. Overview of the Distribution Lateral Hardeninq Proqram
As part of the SPP, FPL will complete its existing approved three-year SSUP Pilot (in
2020) and expand the application of the SSUP during 2021-2029 to the implementation
of the system-wide Lateral Hardening (Undergrounding) - Distribution Program. The
SSUP Pilot targeted certain overhead laterals that were impacted by recent storms and
that have a history of vegetation-related outages and other reliability issues for conversion
from overhead to underground. Key objectives of the SSUP Pilot included validating
conversion costs and identifying cost savings opportunities, testing different design
philosophies, better understanding customer impacts and sentiments, and identifying
barriers (e.9., obtaining easements, placement of transformers, and attaching entities'
issues).
Two design options are being utilized when FPL converts overhead laterals to
underground, referred to as the North American and the European designs. The North
American design currently is the predominant design, but both undergrounding designs
eliminate all overhead lateral and service wire. The North American design generally
22
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 27 of 48
utilizes more primary conductor and a greater number of smaller-sized transformers, with
less customers per transformer, and is better suited for front lot construction and service.
The European design utilizes more secondary conductor, and a smaller number of larger-
sized transformers, with more customers per transformer, and is better suited for rear lot
construction and service. Where practical, FPL attempts to relocate existing facilities from
the rear of to the front of customers' premises; however, there are instances where that
option is not available (e.9., FPL is unable to obtain easements in front of customers'
premises). FPL's standard design is the North American design (front lot construction),
but FPL is gaining important experience and knowledge from its utilization of the
European design (rear lot construction), which it can then better utilize for future projects
as appropriate.
As part of the conversion process, FPL is also installing meter base adaptors that allow
underground service to be provided to the customer by utilizing the existing meter and
meter enclosure. The meter base adaptors minimize the impact on customer-owned
equipment and facilities. For example, in certain situations, overhead to underground
conversions of electric service can trigger a local electrical code requirement that
necessitates a customer upgrade of the home's electric service panel. This can cost the
customer thousands of dollars. However, by utilizing a meter base adaptor, overall costs
are reduced and customers are able to avoid the need and expense to convert their
electrical service pa nels.
b. Benefits of the Distribution Lateral Hardeninq Proqram
Laterals make up the majority of FPL's distribution system. For example, system-wide,
there are over 180,000 laterals (including laterals with multi-stage fusing), in contrast to
approximately 3,300 feeders, and there are 1.8 times as many miles of overhead laterals
as there are overhead feeders (approximately 23,000 miles vs. 13,000 miles,
respectively). Additionally, while feeders are predominately located in the front of
customers' premises, many laterals are "rear of' or behind customers' premises. This is
especially the case in older neighborhoods located throughout FPL's service territory.
Generally, facilities in the rear of customers' premises take longer to restore than facilities
in front of customers' premises because rear-located facilities are more difficult to access
23
Docket No. 2O2OO071-E\
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 28 of 48
and are more likely to be near vegetation. This results in a greater amount of CMH being
devoted to laterals during storm restoration.
The basis for FPL's SSUP Pilot and the proposal to expand upon the Pilot under the SPP
is the performance of the underground facilities as compared to overhead facilities and
the extensive damage to the overhead facilities caused by vegetation during Hurricanes
Matthew and lrma. This performance was demonstrated by the results of FPL's analysis
referenced above in Section |V(AX1)(b) and contained in the Commission's Review of
Florida's Electric lJtility Hurricane Preparedness and Restoration Actions in 2018,20 which
is summarized in the table below:
Storm and Facil Laterals Out Total Laterals % Out
Finally, it is important to note that underground facilities also perform better than overhead
facilities on a day-to-day basis. For example, based on the reliability performance metrics
for overhead and underground facilities provided to the Commission in FPL's February
28,2020 Annual Reliability Report filing, the System Average lnterruption Duration lndex
("SAlDl') for underground facilities is significantly better than hybrid facilities (combination
of overhead and underground) or overhead facilities as shown in the table below:
Year
SAIDI2l
UGOHH brid
20 See footnote 17.
21 See pages 93-97 of FPL's February 28, 2020 Annual Reliability Report filing for more details
on day-to-day reliability performance - overhead vs. underground.
Matthew OH 3,473 82,729 4o/o
101,892 O.2o/oMatthew UG 238
24o/olrma OH 20,341 84,574
lrma UG 3,767 103,384 4o/o
102.4 60.0201521.4
2016 17.2 80.4 57.6
17.7 89.6 55.52017
2018 21.2 89.0 54.2
2019 30.3 87.4 49.4
24
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 29 of 48
2. Actual/Estimated Start and Completion Dates
FPL's SSUP Pilotwas initiated in 2018. Bythe end of 2020, the third and final yearof
the SSUP Pilot, FPL expects to have converted a total of 220-230laterals from overhead
to underground, which is consistent with the SSUP Pilot's plan most recently approved in
Docket No. 20180144-El. As part of its SPP, FPL will incorporate, continue, and expand
the SSUP to provide the benefits of underground lateral hardening throughout its system.
After completing the SSUP Pilot in 2020, FPL estimates it will convert 300-700 laterals
annually. ln 2024-2029 FPL estimates it will convert 800-900 laterals annually.
3. Cost Estimates
Estimated lateral undergrounding costs are determined utilizing the length of each lateral,
the average historical lateral undergrounding cost per mile, and updated cost
assumptions (e.g., labor and materials). The table below provides a comparison of the
2018-2019 total actual costs for the SSUP Pilot with the 2020-2022 (first three years of
the SPP) total estimated distribution lateral hardening program costs and the 2020-2029
total estimated distribution lateral hardening program costs:
Total Annual Average
P m Costs millions P ram Costs millions
Further details regarding the SPP estimated distribution lateral hardening program costs,
including estimated annual capitalexpenditures are provided in Appendix C.23
4. Comparison of Costs and Benefits
As provided in Section lV(D)(3) above, during 2020-2029, total costs for FPL's Lateral
Hardening (Undergrounding) - Distribution Program average approximately $510 million
per year. Benefits associated with the Lateral Hardening (Undergrounding) - Distribution
22 The Storm Secure Underground Program Pilot was initiated in 2018.
23 See footnote 14.
2018-201922 $76 $38
2020-2022 $676 $225
2020-2029 $5,101 $510
25
Docket No. 20200071-El
F PL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1, Page 30 of 48
Program discussed in Sections ll AND |V(DX1Xb) above, include improved storm
resiliency as well as improved dayto-day reliability.
5. Criteria used to Select and Prioritize the Proqram
FPL will selectiprioritize future laterals for conversion to undergrounding based on an
overall feeder performance methodology. Rather than selecting individual "stand-alone"
laterals, FPL will underground all the laterals on a feeder such that when a hardened
feeder that has experienced an outage is restored, all associated underground laterals
would also be restored (unless the underground lateralwas damaged).
On average, there are currently 20-30 overhead laterals on a feeder. The selection and
prioritization of the laterals to be converted will be based on a methodology that considers:
(a) all of the overhead laterals on each feeder; (b) outage experience during the recent
Hurricanes Matthew and lrma; (c) the number of vegetation-related outages experienced
over the most recent 10 years; and (d) the total number of lateral and transformer outages
experienced overthe most recent'10 years. These overhead lateral factors are totaled
for each feeder, and the feeders are ranked based on these totals. All laterals on the
feeders will then be hardened according to the ranking of each feeder.
ln order to optimize resources and provide lateral hardening throughout FPL's system,
lateral hardening projects will be performed annually in all sixteen (16) of FPL's
management areas. At this time, FPL has not identified any areas where the Lateral
Hardening (Undergrounding) - Distribution Program would not be feasible, reasonable,
or practical. However, in areas that are more prone to flooding or storm surge, FPL will
consider alternative construction methods (e.9., elevating transformer pads).
E. Wood Structures Hardening (Replacing) - Transmission
Program
1. Description of the Proqram and Benefits
The Wood Structure Hardening (Replacing) - Transmission Program included in the SPP
is a continuation of FPL's existing transmission hardening program through the end of
2022, when FPL expects that 100% of its transmission structures will be steel or concrete.
26
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection PIan
Exhibit MJ-1 , Page 31 of 48
Below is an overview of FPL's existing transmission wood structure hardening program
and the associated benefits.
a. Overview of the Transmission Hardenino Proqram
While FPL's transmission facilities were affected by the 2004 and 2005 storms, the
damage experienced was significantly less than the damage sustained by distribution
facilities. A primary reason for this resulted from the fact that transmission structures were,
at that time, already constructed to meet EWL consistent with Florida Statute 366.04 and
the National Electrical Safety Code, Rule 250 C.
Based on the forensic data collected from the 2004 and 2005 storms, FPL implemented a
Commission-approved transmission storm hardening initiative to replace all wood
transmission structures, which accounted for nearly 70 percent of all transmission
structures replaced during lhe2004-2005 storm seasons, with steelor concrete structures.
As explained below, this initiative is ongoing and expected to be completed by the end of
2022. As part of its SPP, FPL will continue its initiative to replace allwood transmission
structures with steel or concrete structures.
b. Benefits of the Transmission Hardeninq Proqram
While an outage associated with distribution facilities (e.9., a transformer, lateral, or
feeder) can impact up to several thousands of customers, a transmission-related outage
can result in an outage affecting tens of thousands of customers. Additionally, an outage
on a transmission facility could cause cascading (a loss of power at one transmission
facility can trigger the loss of power on another interconnected transmission facility, which
in turn can trigger the loss of power on another interconnected transmission facility, and
so on) and result in the loss of service for hundreds of thousands of customers. As a
result, the prevention of transmission-related outages is essential. As discussed earlier,
while transmission facilities performed significantly better than distribution facilities during
the 2004 and 2005 storms, there were several opportunities for improvement identified,
including the replacement of wood transmission structures. As a result of its transmission
inspection programs and its replacement of wood transmission structures, FPL's
transmission facilities have demonstrated to be more storm resilient.
27
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 32 of 4B
The table below compares the performance of FPL's transmission system for Hurricane
Wilma, which occurred in 2005 before FPL implemented its current transmission
hardening program, and Hurricane lrma, which occurred in 2017 after FPL implemented
its current transmission hardening program:
Hurricane Wilma Hurricane
lrma
% Line Section Outages 37%17o/o
Transmission Structure Failures 100 5
(all non-hardened)
Transmission Substations De-energized 241 92
Days to Restore Substation Outages 5 1
As shown above, the impacts on FPL's transmission facilities associated with Hurricane
lrma were significantly reduced from those experienced with Hurricane Wilma, even
though Hurricane lrma's winds were stronger and its path impacted substantially more of
FPL's facilities.
2. Actual/Estimated Start and Completion Dates
FPL implemented its transmission hardening program in 2007. As of year-end 2019, 96%
of FPL's transmission structures, system-wide, were steel or concrete, with less than
2,900 (or 4o/o) wood structures remaining to be replaced. FPL expects to replace the
2,900 wood transmission structures remaining on its system by year-end 2022.
3. Cost Estimates
Estimated/actual annual transmission hardening costs are a function of the number of
poles to be replaced, actual historical replacement costs, and updated cost assumptions
(e.9., labor and materials). The vast majority of the transmission hardening program costs
are capital costs resulting from replacement of the wood transmission structures.
28
Docket No. 20200071-El
FPL's 2020-2O29 Storm Proteclion Plan
Exhibit MJ-1, Page 33 of 48
The table below provides a comparison of the 2017-2019 total actual transmission
hardening costs with the 2020-2022 (first three years of the SPP) total estimated
transmission hardening costs:24
Total Annual Average
P ram costs millions ram costs millions
Further details regarding the SPP estimated transmission hardening costs, including
estimated annual capitalexpenditures and operating expenses, are provided in Appendix
c.25
4. Comparison of Costs and Benefits
As provided in Section lV(E)(3) above, during 2020-2022, total costs for FPL's Wood
Structure Hardening (Replacing) - Transmission Program average approximately $39
million per year. Benefits associated with the Wood Structure Hardening (Replacing) -
Transmission Program discussed in Sections ll and |V(EX1)(b) above, include improved
storm resiliency.
5. Criteria used to Select and Prioritize the Proqram
The annual prioritization/selection criteria for the remaining wood structures to be
replaced includes proximity to high wind areas, system importance, customer counts, and
coordination with other storm initiatives (e.9., distribution feeder hardening). Other
economic efficiencies, such as opportunities to perform work on multiple transmission line
sections within the same transmission corridor, are also considered.
At this time, FPL has not identified any areas where the replacement of the remaining
wood transmission structures under the Wood Structure Hardening (Replacing) -
Transmission Program would not be feasible, reasonable or practical.
24 FPL expects that 100% of the remaining wood transmission structures in its system will be
replaced by year-end 2022.
25 See footnote 14.
2017-2019 $1 62 $s+
2020-2022 $1 18 $3e
29
Docket No. 202OO071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 34 of 48
F. Substation Storm Surge/Flood Mitigation Program
1. Description of the Proqram and Benefits
The Substation Storm Surge/Flood Mitigation Program is the only new program included
in FPL's SPP. As explained below, Substation Storm Surge/Flood Mitigation Program is
a new program to mitigate damage at several targeted distribution and transmission
substations that are susceptible to storm surge and flooding during extreme weather
events.
Historically, several FPL distribution and transmission substations have been impacted
by storm surge and/or flooding as a result of extreme weather conditions. For example,
as a result of flooding caused by Hurricanes Matthew and lrma, FPL's St. Augustine
substation was required to be proactively de-energized (i.e., shut down before water
reached levels that would cause significant damage to powered substation equipment).
Another example is FPL's South Daytona substation that was proactively de-energized
during Hurricane lrma as a result of flooding. While proactively de-energizing those
substations impacted by storm surge and/or flooding helps reduce damage to substation
equipment, FPL is still required to implement both temporary flood mitigation efforts and
repairs to substation facilities and equipment that become flooded as a result of extreme
weather conditions.
An outage associated with distribution substations can impact up to several thousands of
customers, and an outage associated with a transmission substation can result in an
outage affecting tens of thousands of customers. Flooding and the need to proactively
de-energize substations located in areas susceptible to storm surge and flooding can
result in significant customer outages. For example, the flooding and de-energization of
St. Augustine and South Daytona during Hurricane lrma resulted in more than 8,000
customer outages. Therefore, the prevention of outages at transmission and distribution
substations due to storm surge or flooding is essential.
To prevent/mitigate future substation equipment damage and customer outages due to
storm surge and flooding, FPL's new Substation Storm Surge/Flood Mitigation Program
will target and harden certain substations located in areas throughout FPL's service
30
Docket No. 2O20O071-E\
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 35 of48
territory that are susceptible to storm surge or flooding during extreme weather events.
Specifically, FPL plans to raise the equipment at certain substations above the flood level
and construct flood protection walls around other substations to prevent/mitigate future
damage due to storm surge and flooding.
2. ActualiEstimated Start and Completion Dates
At this time, FPL has identified between 8-10 substations where it initially plans to
implement storm surge/flood mitigation measures over the next three years (2020-2022).
FPL plans to initiate construction in late summer/early fall 2020 to raise the equipment at
the St. Augustine substation, which is expected to be completed in2021. ln2021 and
early 2022, FPL also plans to begin construction on flood protection walls for the other 7-
9 substations identified for mitigation, which is expected to be completed by 2022.
3. Cost Estimates
The storm surge/flood mitigation costs associated with St. Augustine substation (raising
substation equipment) are estimated to be approximately$10 million in total (2020and
2021). Estimated storm surge/flood mitigation costs for the remaining 7-9 substations
identified at this time (constructing surrounding flood walls) are estimated to be
approximately $13 million in total (2021 and2022). See the table below the estimated
annual program costs:
Annual Average
millions P ram Costs millions
Further details regarding the SPP estimated storm surge/flood mitigation costs, including
estimated annual capitalexpenditures and operating expenses, are provided in Appendix
c.26
4. Comparison of Costs and Benefits
As provided in Section |V(FX3) above, during 2020-2022, total costs for FPL's Substation
Storm Surge/Flood Mitigation Program average approximately $8 million per year.
P
Total
Gosts
2020-2022 $23 $8
26 See footnote 14.
31
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 36 of 4B
Benefits associated with this program discussed in Section |V(FX1) above, include
improved storm resiliency (avoiding storm surge/flood damage), reduced customer
outages and storm restoration costs.
5. Criteria used to Select and Prioritize Projects
The annual prioritization/selection criteria for the targeted substations is based on FPL's
historical storm surge/flood experience, in particular, Hurricanes Matthew and lrma. At
this time, for the targeted substations, FPL has not identified any areas where the
upgrades would not be feasible, reasonable or practical.
c. Vegetation Management - Distribution Program
1 . Description of the P ram and Benefits
The Vegetation Management - Distribution Program included in the SPP is a continuation
of FPL's existing Commission-approved Vegetation Management - Distribution Program.
Below is an overview of FPL's existing Vegetation Management - Distribution Program
and the associated benefits.
a Overview of the Veqetation Manaoement - Distribution
Proqram
Prior to 2006, FPL's Vegetation Management - Distribution Program consisted of
inspecting and maintaining its feeders on a three-year average trim cycle and performing
targeted trimming on certain feeders more frequently (e.9., targeting vegetation with faster
growth rates and palm trees) through its "mid-cycle" program. Lateral trimming was
prioritized based on reliability performance. Another important component of this program
was FPL's "Right Tree Right Place" initiative, which provided information to educate
customers on FPL's vegetation management program and practices, safety issues, and
the importance of placing trees in the proper location.
After the 2004-2005 storm seasons, the Commission determined that the "vegetation
management practices of the investor-owned electric utilities do not provide adequate
assurance that tree clearances for overhead distribution facilities are being maintained in
a manner that is likely to reduce vegetation related storm damage. We believe that
32
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 37 of 48
utilities should develop more stringent distribution vegetation management programs."27
As result, FPL proposed and the Commission approved the continuation of FPL's system-
wide three-year average trim cycle for feeders, mid-cycle targeted trimming for certain
feeders, and its Right Tree Right Place initiative, as well as the implementation of a new
six-year average trim cycle for laterals.2s These same initiatives, which have provided
storm and day-to-day reliability benefits, remain in place today.
Tree limbs and branches, especially palm fronds, are among the most common causes
of power outages and momentary interruptions during both dayto-day operations and
storm events. The primary objective of FPL's Vegetation Management - Distribution
Program is to clear vegetation in areas where FPL is permitted to trim from the vicinity of
distribution facilities and equipment in order to provide safe, reliable, and cost-effective
electric service to its customers. The program is comprised of multiple initiatives
designed to reduce the average time customers are without electricity as a result of
vegetation-related interruptions. These include preventive maintenance initiatives
(planned cycle and mid-cycle maintenance), corrective maintenance (trouble work and
service restoration efforts), customer trim requests, and support of system improvement
and expansion projects, which focus on long{erm reliability by addressing vegetation that
will impact new or upgraded overhead distribution facilities.
FPL's Vegetation Management Distribution Program's practices follow the NESC, the
American National Standards lnstitute ("ANSl') A-300, and all other applicable standards,
while considering tree species, growth rates, and the location of trees in proximity to FPL's
facilities. Danger or hazard trees (leaning, structurally damaged, or diseased/dead that
have a high likelihood to fail and impact FPL's facilities) located outside of right-of-way
("ROW'), which cannot be trimmed without approval from the property owner, are
identified as candidates for customer-approved removal.
Finally, a very impoftant component of FPL's vegetation program is providing information
to customers to educate them on the company's trimming program and practices, safety
issues, and the importance of placing trees in the proper location - FPL's "Right Tree,
27 See Order No. PSC-06-0351-PAA-El
28 See Order No. PSC-07-0468-FOF-El
33
Docket No. 20200071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ- 1 , Page 3B of 4B
Right Place" initiative. Right Tree, Right Place is a public education program based on
FPL's core belief that providing reliable electric service and sustaining the natural
environment can go hand-in-hand and is a win-win partnership between the utility and its
customers.
The SPP will continue FPL's currently-approved distribution vegetation program, which
includes the following system-wide vegetation management activities: three-year cycle
for feeders; mid-cycle targeted trimming for certain feeders; six-year cycle for laterals;
and continued education of customers through its Right Tree, Right Place initiative.
b. Benefits of the Veqetation Manaqement - Distribution
Proqram
ln Order No. PSC-07-0468-FOF-El, the Commission confirmed that FPL should continue
to implement three-year and six-year average cycles for its feeders and laterals because
the cycles complied with the Commission's storm preparedness objectives to increase
the level of trimming over historical levels, promote system reliability and reduce storm
restoration costs.2e Additionally, Commission's orders indicated that FPL's proposed
cycles: were cost-effective; would improve day-to-day "tree SAlFl" from 0.221o 0.16 in
ten years;30 and would provide savings when comparing savings on a customers
interrupted ('Cl") per storm basis. Further, day-to-day distribution tree SAIFI has
significantly improved as a result of FPL implementing its approved distribution vegetation
management program (from 0.20 prior to the 2004-2005 storm seasons to 0.08 at year-
end 2019).
Finally, another indication that the current program is providing benefits is that, while
forensic analysis indicated vegetation was the overwhelming primary cause for pole and
wire failures and a significant cause of outages during Hurricanes Matthew and lrma, the
vast majority of damage resulted from uprooted trees, broken trunks, and broken limbs
2e FPL's proposed three-year and six-year cycles were initially approved in Order No. PSC-06-
O7B1-PAA-EI.
30 The tree-related SAIFI has averaged less than 0.09 over the last few years.
34
Docket No. 2020O071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 39 of 48
thatfell into distribution facilities from outside of right-of-way, /.e., beyond where FPL is
currently allowed trim without approvalfrom the property owner.
2. Actual/Estimated Start and Completion Dates
FPL's ongoing vegetation management plan was originally approved in 2007, and
remains in place today. Under the SPP, FPL plans to inspect and maintain, on average,
approximately 15,200 miles annually, including approximately 1 1,400 miles for feeders
(cycle and mid-cycle) and 3,800 miles for laterals. This is comparable to the
approximately 15,200 miles inspected and maintained annually, on average, for 2017-
2019.
3. Cost Estimates
The vast majority of vegetation management costs are associated with cycle and mid-
cycle trimming, which is performed by several FPl-approved contractors throughout
FPL's system. Other vegetation management costs include costs associated with day-
to-day restoration activities (e.9., summer afternoon thunderstorms), removals, debris
cleanup, and support (e.9., arborists, supervision, back office support). Costs associated
with vegetation management are generally operating expenses.
The table below provides a comparison of the 2017-2019 total actual distribution
vegetation management costs with the 2020-2022 (first three years of the SPP) total
estimated distribution vegetation management costs and the 2020-2029 total estimated
distribution vegetation management costs:31
Total Annual Average
ram Costs millions P m Costs millions
Further details regarding the SPP estimated distribution vegetation management costs,
31 The vegetation management costs shown in the table below exclude storm-related vegetation
management costs.
2017-2019 $1 89 $63
2020-2022 $1 83 $61
2020-2029 $596 $60
35
Docket No. 2020O071-El
FPL's 2O2O-2029 Storm Protection Plan
Exhibit MJ-l , Page 40 of 4B
including estimated annualcapitalexpenditures and operating expenses, are provided in
Appendix C.32
4. Comparison of Costs and Benefits
As provided in Section |V(GX3) above, during 2020-2029, totalcosts for FPL's Vegetation
Management - Distribution Program average approximately $60 million per year.
Benefits associated with the Vegetation Management - Distribution Program discussed
in Sections ll and |V(GX1Xb) above, include increased storm resiliency.
5. Criteria Used to Select a nd Prioritize the Prooram
The primary reason for maintaining feeders on a three-year average cycle, as opposed
to a six-year average cycle for laterals, is that a feeder outage can affect, on average,
approximately 1,500 customers as compared to an outage on a lateral line that can affect,
on average, approximately 35 customers. FPL enhances its approved feeder inspection
and trimming plan through its mid-cycle trimming program, which encompasses patrolling
and trimming feeders between planned maintenance cycles to address tree conditions
that may cause an interruption prior to the next planned cycle trim. Mid-cycle work units
typically have a trim age of 12to 18 months and usually involve certain fast-growing trees
(e.9., palm trees) that need to be addressed before the next scheduled cycle trim date.
Additionally, customers often contact FPL with requests to trim trees around distribution
lines in their neighborhoods and near their homes. As a result of these discussions with
customers and/or a follow-up investigation, FPL either performs the necessary trimming
or determines that the requested trimming can be addressed more efficiently by
completing it through the normal scheduled cycle trimming.
Cycle trimming is prioritized annually to ensure compliance with cycle schedules. At this
time, FPL has not identified any areas where the Vegetation Management - Distribution
Program would not be feasible, reasonable or practical.
32 Seefootnote 14
36
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 41 of 48
H. Vegetation Management - Transmission Program
1. Description of the Proqram and Benefits
The Vegetation Management - Transmission Program included in the SPP is a
continuation of FPL's existing transmission vegetation management program. Below is
an overview of FPL's existing transmission vegetation management program and the
associated benefits.
a. Overview of the Veqetation Manaqement - Transmission
Proqram
The Nofth American Electric Reliability Corporation's (NERC) vegetation management
standards/requirements serve as the basis for FPL's transmission vegetation
management program. The reliability objective of these standards/requirements is to
prevent vegetation-related outages that could lead to cascading by utilizing effective
vegetation maintenance while recognizing that certain outages such as those due to
vandalism, human errors, and acts of nature are not preventable. Transmission lines that
must conform with these standards/requirements include lines operated at or above 200
kV or any line that is either an element of the lnterconnection Reliability Operating Limit
(IROL) or the Western Electricity Coordinating Council WECC).
For FPL, just over 4,300 miles of its transmission system (or nearly two-thirds of all of
FPL's total transmission system) are subject to NERC's vegetation management
standards/requirements. NERC's vegetation management standards/requirements
include annual inspection requirements, executing 100% of a utility's annual vegetation
work plan, and to prevent any encroachment into established minimum vegetation
clearance distances ('MVCD').
The key elements of FPL's transmission vegetation management program are to inspect
the transmission right-of-ways, document vegetation inspection results and findings,
prescribe a work plan, and execute the work plan.
FPL conducts ground inspections of all transmission corridors annually for work planning
purposes. During these inspections, FPL identifies vegetation capable of approaching
the defined Vegetation Action Threshold ("VAT"). VAT is a calculated distance from the
37
Docket No. 2020O071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 42 of 48
transmission line that factors in MVCD, conductor sag/sway potential, and a buffer. The
identified vegetation is given a work prescription and then prioritized and organized into
batches of work, which collectively become the annual work plan.
For transmission lines that are subject to NERC's vegetation management
standards/requirements, FPL also uses a technology called "LiDAR,' short for light
detection and ranging. L|DAR is a remote sensing technology that uses light in the form
of a pulsed laser to measure ranges (distances) to a target. For vegetation management
purposes, L|DAR is used to measure distance between vegetation and transmission lines.
L|DAR patrols are conducted annually for all NERC transmission corridors. Data
collected by the L|DAR patrols is then used to develop annual preventative and reactive
work plans.
ln its SPP, FPL will continue its current transmission vegetation management plan, which
includes visual and aerial inspections of all transmission line corridors, LiDAR inspections
of NERC transmission line corridors, developing and executing annual work plans to
address identified vegetation conditions, and identifying and addressing priority and
hazard tree conditions prior to and during storm season.
b. Benefits of the Veqetation Manaqement - Transmission
Proeram
The benefits of a Vegetation Management - Transmission Program are self-evident and
the consequences of not having a reasonable transmission vegetation management plan
can be extreme. As discussed previously, the transmission system is the backbone of
the electric grid. While outages associated with distribution facilities (e.9., a transformer,
lateral, or feeder) can result in an outage aff6cting anywhere from a few customers up to
several thousands of customers, a transmission related outage can affect tens of
thousands of customers. Additionally, an outage on a transmission facility could cause
cascading and result in the loss of service for hundreds of thousands of customers. As
such, it is imperative that vegetation impacting transmission facilities be properly
maintained using reasonable and appropriate cycles and standards to help ensure they
are prepared for storms. For these reasons, it is no surprise that NERC has developed
38
Docket No. 20200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 43 of 48
prescriptive vegetation management requirements for transmission facilities to help
prevent such damage from occurring.
FPL also notes that while vegetation-related damage and transmission line outages
occurred during Hurricanes Matthew and lrma, the vast majority of such
damages/outages were caused by vegetation located outside of the right-of-way, i.e.,
beyond where FPL is currently allowed to trim without approval from the property owner,
which further demonstrates that FPL's historical efforts in this area have been beneficial.
2. Actual/Estimated Start and Completion Dates
FPL's Vegetation Management - Transmission Program is an ongoing program, initiated
decades ago. Under the SPP, FPL plans to inspect and maintain, on average,
approximately 7,000 miles annually, including approximately 4,300 miles for NERC
transmission line corridors and 2,700 miles for non-NERC transmission line corridors.
This is comparable to the approximately 7,000 miles inspected and maintained annually,
on average , for 2017-2019.
3. Cost Estimates
The vast majority of vegetation management costs are associated with annual inspections
and the execution of planned work to address identified conditions, which is performed
by several FPL approved contractors throughout FPL's system. Other vegetation
management costs include costs associated with dayto-day restoration activities (e.9.,
summer afternoon thunderstorms), removals, debris cleanup, and support (e.g., arborists,
supervision, back office support). Costs associated with vegetation management are
generally operating expenses.
The table below provides a comparison of the 2017-2019 total actual transmission
vegetation management costs with the 2020-2022 (first three years of the SPP) total
estimated transmission vegetation management costs and the 2020-2029 totalestimated
transmission vegetation management costs:33
33 The vegetation management costs shown in the table below exclude storm-related vegetation
management costs.
39
2017-2019 $zz $g
$s2020-2022 $27
$102024-2029 $e6
Docket No. 2O200O7|-El
FPL's 202O-2O29 Storm Protection Plan
Exhibit MJ-1, Page 44 of 48
Annual Average
illions P ram Gosts millions
Further details regarding the SPP estimated transmission vegetation management costs,
including estimated annualcapitalexpenditures and operating expenses, are provided in
Appendix C.3a
4. Comparison of Costs and Benefits
As provided in Section lV(H)(3) above, during 2020-2029, totalcosts for FPL's Vegetation
Management - Transmission Program average approximately $10 million per year.
Benefits associated with the Vegetation Management - Transmission Program discussed
in Sections Il and |V(HX1)(b) above, include increased storm resiliency. The execution
of FPL's Vegetation Management - Transmission Program is a significant factor in
mitigating damage to transmission facilities and avoiding transmission-related outages.
5. Criteria used to Select an d Prioritize the Proorams
Priority vegetation conditions and hazard tree conditions are completed annually prior to
storm season. Additionally, prior to and during the storm season, FPL conducts aerial
inspections of transmission corridors to identify hazard trees and any priority vegetation
locations. Priority vegetation conditions and hazard tree conditions identified through
aerial inspections are addressed as soon as possible.
At this time, FPL has not identified any areas where the Vegetation Management -
Transmission Program would not be feasible, reasonable or practical.
Total
ram Costs
3a See footnote 14
40
Docket No. 2O20O071-E\
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 45 of 48
V. Detailed lnformation on the First Three Years of the SPP
2020-2022
A. Detailed Description for the First Year of the SPP (20201
The following additional information required by Rule 25-6.030(3XeX1), F.A.C., for the
first year of the SPP (2020) is provided in Appendix E. (1) the actual or estimated .
construction start and completion dates; (2) a description of the affected existing facilities,
including number and type(s) of customers served, historic service reliability performance
during extreme weather conditions, and how this data was used to prioritize the storm
protection projects; (3) a cost estimate including capital and operating expenses. A
description of the criteria used to select and prioritize the storm protection programs is
included in the description of each SPP program provided in Section lV.
Detailed Description of the Second and Third Years of the
sPP (2021-20221
B.
Additional details required by Rule 25-6.030(3XeX2), F.A.C., for the second and third
years of the SPP (2021-2022), including the estimated number and costs of projects
under every program, is provided in in Appendix C.
Detailed Description of the Vegetation Management
Activities for the First Three Years of the SPP (2020-20221
The following additional information required by Rule 25-6.030(3X0, F.A.C., for the first
three years of the vegetation management activities under the SPP (2020-2022) is
provided in n Sections lV(G) and lV(H) above and Appendix C: the projected frequency
(trim cycle); the projected miles of affected transmission and distribution overhead
facilities; the estimated annual labor and equipment costs for both utility and contractor
personnel. A description of how the vegetation management activities will reduce outage
times and restoration costs due to extreme weather conditions is provided in Sections
lV(G) and lV(H) above.
c
41
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 46 of 4B
Vl. Estimate of Annual Jurisdictional Revenue R eo ui rements
for the 2020-2029 SPP
Pursuant to Rule 25-6.030(3X0, F.A.C., the table below provides the estimated annual
jurisdictional revenue requirements for each year of the SPP.
Estimated Annual
Revenue
Requirements
illions
While FPL has provided estimated costs by program as of the time of this filing and
associated total revenue requirements in its SPP, consistent with the requirements of
Rule 25-6.030, F.A.C., subsequent projected and actual program costs submitted for cost
recovery through the Storm Protection Plan Cost Recovery Clause (per Rule 25-6.031,
F.A.C.,) could vary by as much as 10-15%, which would then also impact associated
estimated revenue requirements and rate impacts. The projected costs, actual/ estimated
costs, actuals costs, and true-up of actual costs to be included in FPL's Storm Protection
2020 $257.6
2021 $369.1
2022 $494.3
2023 $625.5
2024 $760.9
2025 $878.1
2026 $96s.7
2027 $1,037.1
2028 $1 ,1 10.9
2029 $1 ,185.2
42
Docket No. 2O20O071-E\
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 47 of 48
Plan Cost Recovery Clause will all be addressed in subsequent filings in separate storm
protection plan cost recovery clause dockets pursuant to Rule 25-6.031, F.A.C.35
vil.Esti mated Rate lm oa cts for First Three Years of the SPP
{p020-20221
FPL anticipates the programs included in the SPP will have zero bill impacts on customer
bills during the first year of the SPP and only minimal bill increases for years two and
three of the SPP. An estimate of hypothetical overall rate impacts for the first three years
of the SPP (2020-2022), without regard for the fact that FPL remains under a general
base rate freeze pursuant to a Commission-approved settlement agreement through
December 31 ,2021, as stated in footnote 36 below are based on the total program costs
reflected in this filing.36 The projected costs, actual/estimated costs, actuals costs, and
true-up of actual costs to be included in FPL's Storm Protection Plan Cost Recovery
Clause will all be addressed in subsequent filings in Storm Protection Plan Cost Recovery
Clause dockets pursuant to Rule 25-6.031, F.A.C.37
Pursuant to Rule 25-6.031, F.A.C., FPL has not identified any reasonable implementation
alternatives that could mitigate the resulting rate impact for each of the first three years
of the SPP. As explained above, FPL's SPP is largely a continuation of existing
Commission-approved storm hardening programs and initiatives, which have already
demonstrated that they have and will continue to provide increased T&D infrastructure
resiliency, reduced restoration time, and reduced restoration costs when FPL's system is
impacted by severe weather events. Further, as explained above, the estimated costs
35 The Commission has opened Docket No. 20200092-El to address Storm Protection PIan Cost
Recovery Clause petitions to be filed the third quarter of 2020.
36 Pursuant to Rule 25-6.030(3)(h), F.A.C., the hypothetical rate impacts for FPL's typical
residential, commercial, and industrial customers for the first three years of the SPP (2020-2022)
without regard for the fact that FPL remains under a general base rate freeze pursuant to a
Commission-approved settlement agreement through December 31,2021, are as follows for
2020, 2021, and 2022, respectively: Residential (RS-1) $0.00251ikwh, $0.00357/kwh, and
$0.00478/kWh; Commercial (GSD-1) $0.81/kW, $1.15/kW, and $1.54/kW; and lndustrial
(GSLDT-3) $0.05/kW, $0.08/kW and $0.1O/kW. These rate impacts are for all programs included
in the SPP and are based on the total estimated costs as of the time of this filing, which could
vary by as much as 10% to 15Vo, regardless of whetherthose costs will be recovered in FPL's
Storm Protection Plan Cost Recovery Clause or through base rates.
37 See footnote 34.
43
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1, Page 48 of 48
for the programs included in FPL's SPP are consistent with the historical costs incurred
for the existing storm hardening and storm preparedness programs, which were most
recently approved in FPL's 2019-2021Storm Hardening Plan.
Vlll. Conclusion
The Florida Legislature has determined that it is in the State's interest to "strengthen
electric utility infrastructure to withstand extreme weather conditions by promoting the
overhead hardening of distribution and transmission facilities, undergrounding of certain
distribution lines, and vegetation management," and for each electric utility to "mitigate
restoration costs and outage times to utility customers when developing transmission and
distribution storm protection plans." Section 366.96(1), F.S. Based on these findings, the
Florida Legislature concluded that it is in the State's interest for each electric utility to
develop and file a SPP for the overhead hardening and increased resilience of electric
T&D facilities, undergrounding of electric distribution facilities, and vegetation
management. See Sections 366.96(1)-(3)
FPL's SPP is a systematic approach to achieve the legislative objectives of reducing
restoration costs and outage times associated with extreme weather events and
enhancing reliability. As explained above, FPL's SPP is largely a continuation and
expansion of its existing and already successful storm hardening and storm preparedness
programs previously approved by the Commission, as well as a new storm hardening
program to harden certain targeted substations that are susceptible to storm surge or
flooding during extreme weather events. Based on the recent experiences of Hurricanes
Matthew and lrma, the existing storm hardening programs have a demonstrated and
proven track record of mitigating and reducing restoration CMH, outage times, and storm
restoration costs, as well as improving day-to-day reliability. FPL's SPP will continue and
expand these important benefits to customers and the State.
44
Docket No. 2020OO71-E\
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 1 of 1B)
APPENDIXA
(FPL's 3rd Supplemental Amended Response to
Staffs lst Data Request)
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 2 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staff s F irst Data Request
Request No. 29 - Third Supplemental Amended
Page I of9
OUESTION:
Please complete the table below summarizing hardened facilities that required repair or
replacement as a result of Hurricanes Matthew, Hermine, Irma, Maria, and Nate.
RESPONSE:
FPL does not maintain its accounting records at the level of detail required to provide the
requested information as they do not differentiate hardened facilities from non-hardened
facilities, nor do they track which assets were repaired. However, FPL does track certain assets,
at the total system level, that were requested and replaced during each hurricane as reflected in
the tables below. Note, FPL did not track storm repairs/replacements for Hurricanes Maria and
Nate as Hurricane Maria did not impact FPL's service territory and Nate had limited impact.
Also, Hurricanes Matthew and Irma capital details associated with follow-up work are not yet
available by plant account as these costs have not yet been unitized from account 106 to account
l0l by plant account.
Hurricane Matthew Number of Facilities Requiring
Repair Replacement
Transmission
Structures N/A 0
Substations N/A 0
Total N/A 0
Distribution
Poles N/A 656
Substation N/A 0
Feeder OH N/A 0
Feeder UG N/A 0
Feeder Combined N/A 0
Lateral OH N/A N/A
Lateral UG N/A N/A
Lateral Combined N/A N/A
Total N/A N/A
Service
Service OH N/A N/A
Service UG N/A N/A
Service Combined N/A N/A
Total N/A N/A
Docket No. 20200071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 3 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs tr'irst Data Request
Request No. 29 - Third Supplemental Amended
Page2 of9
Hurricane Hermine Number of Facilities Requiring
Repair Replacement
Transmission
Structures N/A 0
Substations N/A 0
Total N/A 0
Distribution
Poles N/A I9
Substation N/A 0
Feeder OH N/A 0
Feeder UG N/A 0
Feeder Combined N/A 0
Lateral OH N/A NiA
LateralUG N/A N/A
Lateral Combined N/A N/A
Total N/A N/A
Service
Service OH N/A N/A
Service UG N/A N/A
Service Combined N/A N/A
Total N/A NiA
Docket No. 2O200071-El
FPL'I 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 4 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29'Third Supplemental Amended
Page 3 of9
Hurricane Irma Number of Facilities Requiring
Repair Replacement
Transmission
Structures N/A 0
Substations N/A 0
Total N/A 0
Distribution
Poles N/A 3,s62
Substation N/A 0
Feeder OH N/A 0
Feeder UG N/A 0
Feeder Combined N/A 0
Lateral OH N/A N/A
Lateral UG N/A N/A
Lateral Combined N/A NiA
Total N/A N/A
Service
Service OH N/A N/A
Service UG N/A N/A
Service Combined N/A N/A
Total N/A N/A
Notes:
For Hurricane Matthew, there is a difference of 248 poles between what is provided in this
discovery response for total poles replaced (656 poles) and what is provided in FPL's post-storm
forensic review report for Huricane Matthew (provided in FPL's response to Staff s Second
Data Request No. 2 in this same docket) for poles that failed and needed to be replaced to restore
seruice (408 poles). The difference is associated with poles replaced during "follow-up" - i.e.,
poles that were damaged (e.g., a cracked pole) as a result of the storm and needed to be replaced
to restore the pole to its pre-storm condition - but did not fail during the storm and, thus, did not
need to be replaced to restore service. As mentioned above in FPL's response to this data
request, FPL's accounting records do not differentiate hardened facilities from non-hardened
facilities and FPL did not track or maintain forensic information on the 248 distribution poles
replaced as a result of follow-up work. As a result, FPL does not have a hardened vs. non-
hardened breakdown for the 248 distribution poles replaced during follow-up work.
Docket No. 2020O071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX A (Page 5 of ',l8)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 4 of9
The distribution pole and transmission structure counts provided above represent the amount of
pole/structure replacements FPL has recorded on its books and records associated with Hurricane
Irma as of December 31, 2017. These amounts should be considered preliminary at this time as
they are subject to change (e.g., the counts do not reflect poles that will be replaced during
follow-up work, which has yet to be completed).
N/A - Information is not available at this level of detail in FPL's accounting records.
For substations and feeders, FPL has stated 0 since no entire substation or feeder was replaced.
However, these facilities consist of many pieces of equipment (e.g., wire, cable, breakers,
transformers, cross arms and arrestors) some of which may have been replaced.
2016/2017 Hurricanes - FPL Restoration/Infrastructure Performance
FPL's infrastructure/restoration performance for Hurricanes Matthew (2016) and Irma (2017)
demonstrates that the implementation and execution of its FPSC-approved (1) ten storm
preparedness initiatives (which includes vegetation management): (2) pole inspection programs;
(3) storm hardening plans; and (4) tariffs to incent municipal overhead to underground
conversions have provided great benefits to FPL's customers and to the State of Florida.
During 2016 and 2017, FPL' s service territory was threatened with massive Category 4 and 5
storms. The size and scale of these storms impacted FPL's infrastructure throughout its entire
service territory (which encompasses 35 counties inthe State of Florida). For both Matthew and
Irma, FPL's infrastructure storm resiliency and smart grid investments resulted in improved
infrastrucfure resiliency performance and reduced restoration times.
2016 /2017 Hurricanes - Restoration Performance
FPL saw significant improvements in overall restoration results. As can be seen in the table
below, restoration results for Hurricanes Matthew and Irma show significant improvement vs.
Huricane Wilma. FPL attributes these significant improvements in restoration to the investments
made to make its system smarter and more storm-resilient as well as its well-tested restoration
processes. This includes FPL's distribution and transmission storm hardening and storm
preparedness initiatives, pole inspection programs, smart grid initiatives, vegetation management
programs and continuous efforts to improve its restoration processes.
Customer Outages 3.2M 1.2M 4.4M
% Restored / davs s0%/s 99%/2 s0% lt
All restored / davs 18 4 10
Avs. to restore / davs 5.4 <L 2.7
Docket No. 2O2O0071-E\
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 6 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 5 of9
2016/2017 Hurricanes -frastnrctrr re Performance
To assess the effectiveness of FPL's infrastructure storm hardening investments, the Company
utilizes information collected through post-storm forensic data collection and various systems
(e.g., FPL's outage management system) to conduct post-storm infrastructure performance
analysis. These efforts and analysis allow FPL to quantif,/ and assess its distribution and
transmission infrastructure performance including the performance of: hardened and non-
hardened facilities; overhead and underground facilities; and smart grid performance. For
distribution, this includes reviewing the storm performance of poles, feeders and laterals. For
transmission, this includes reviewing the storm performance of poles/structures, line sections
and substations. The data demonstrates that hardened infrastructure performed better than non-
hardened infrastructure, underground facilities performed better than overhead facilities and
smart grid devices prevented a significant number of outages from occurring.
Distribution/Transmission Poles/ Structures Performance
The performance of FPL's approximately 1.2 million distribution and transmission
poles/structures during Hurricanes Matthew and Irma was excellent, as hardened poles and
structures performed as expected by minimizing outages and reducing restoration times. The
total number of distribution/transmission poles that failed (i.e., had to be repaired/replaced in
order to restore service) during Hurricanes Matthew and Irma was a mere fraction of lYo of the
1.2 million pole/structure pole population.
Additionally, hardened distribution and transmission pole performance was significantly better
than non-hardened pole performance, as hardened pole failures were either non-existent (e.g.,
Hurricane Matthew) or significantly less than non-hardened pole failures (e.g., during Huruicane
Irma, hardened feeder poles had a 0.02%o failure rate, while non-hardened feeder poles had a
0.20% failure rate). Also, total poles replaced (i.e., poles that failed * poles that were replaced
during follow-up worb were also a mere fraction of lo/o of the total pole population and
significantly less than the number of poles replaced during Hurricane Wilma.
FPL notes that for Hurricanes Matthew and Irma, while it did track hardened vs. non-hardened
pole performance during restoration, it did not track poles replaced (hardened vs. non-hardened)
during follow-up work, since these poles had accomplished their intended purpose of not failing
during the storms. Therefore, FPL cannot provide the number of hardened poles replaced during
follow up work in Hurricanes Matthew and Irma. Based on the performance of hardened poles
that failed during these storms (see table below), it is highly unlikely that there would be a
significant number of hardened poles, if any, that needed to be replaced during follow-up work.
However, going forward, should the Commission want FPL to track replacement of hardened
vs. non-hardened poles during follow-up work, FPL will begin to track this information.
FPL attributes this excellent pole performance to its FPSC-approved distribution and
transmission storm hardening plan initiatives (e.g., extreme wind load construction standards for
distribution poles and replacing wood transmission poles/structures) and its pole inspection
programs.
Docket No. 202O0071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-'1 , APPENDIX A (Page 7 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 6 of 9
Distribution Poles I 2/3 1/1 7
Total Number 1,188p02
TotalHardened 124,518*
* This number is understated as it includes only poles hardened as a result of FPL's approved
hardening plan projects, as FPL does not track or maintain the number of hardened poles
installed as a result of new construction (e.g., new feeders or laterals) andlor daily work activities
(e.g., maintenance, pole line extensions, relocation projects). There are also other existing poles
throughout FPL's service territory that would currently meet the NESC's extreme wind loading
criteria and therefore qualify as a hardened pole, however, FPL does not currently track or
maintain that information.
Distribution Pole Failures*Hardened
Non-
Hardened Total
Matthew - 2016 0 408 408
lrma - 20ll 26 2834 2860
*Broken/Fallen poles that must be repaired/replaced to restore service
Transmission Pole/Structures l2l3 l/l 7
Total 66,685
Concrete 60,694 (91%)
Wood 5,991 (9%)
Transmission Pole Failures*Hardened
Non-
Hardened Total
Matthew - 2016 0 0 0
lrma - 20L7 0 E 5
*Broken/Fallen poles that must be repaired/replaced to restore service
Distribution Feeders/Laterals Performance
As demonstrated below, FPL's hardened feeders performed significantly better than non-
hardened feeders and underground feeders/laterals performed significantly better than overhead
feeders/laterals. Performance was compared considering feeder and lateral outages that occurred
during Hurricanes Matthew and Irma. It is also important to note that during Hurricane Irma, the
Construction Man Hours ("CMH") to restore hardened feeders was 50% less than non-hardened
feeders, primarily due to hardened feeders experiencing less damage than non-hardened feeders.
It is important to note that the majority of outages for overhead facilities resulted from trees that
broke andlor fell into FPL's facilities. Many of these trees were outside of easements or public
rights of way where FPL is generally allowed to trim. As a result, no additional amount of
Docket No. 202O0071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page B of '18)
Florida Power & Light Company
Docket No.20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 7 of 9
traditional tree trimming would help mitigate this issue. Tree damage was particularly impactful
on FPL laterals.
The two tables below provide feeder and lateral outage performance statistics for Hurricanes
Matthew and Irma.
Pop: poOutu,'on; Lateral population includes latelals with multi-stage fusing
Pop: Population; Latelal population includes laterals with multi-stage fusing
FPL notes that, overall, for Hurricane Irma, many more laterals experienced outages compared to
feeders, thus laterals required significantly more time to restore (871,000 CMH) compared to
feeders (170,000 CMH). FPL continues to promote its Right Tree Right Place initiative and
recommends there be changes to state laws and/or local ordinances to restrict the type and
location of trees and provide utilities additional trimming rights to address existing tree
conditions.l
Additionally, FPL notes that day-to-day, hardened feeders perform approximately 40Yo better
than non-hardened feeders.
Transmission Line Sections/Substations Performance
The transmission system's performance was excellent during Hurricanes Matthew and Irma.
Equipment and conductor damage was minimal as a result of our investments in transmission
hardening and the installation of flood monitoring equipment in those substations located in
flood prone areas. Substations that experienced outages were restored in one day. During
Hurricanes Matthew and Irma, flood monitoring equipment operated as expected, providing
notification which allowed FPL to proactively de-energize three substations (one in Matthew and
two in Irma) and prevent potential serious damage from occurring at these substations.
I Where municipalities are not actively engaged in ensuring appropriate limitations on planting trees in public rights
of way, restoration efforts are irnpeded and made more costly. In fact,_one particular municipality is actively
planting "wrong trees in the wrong place," in spite of FPL's direct communications and efforts to encourage its
Right Tree Right Place initiative.
Matthew
Overhead non-Hardened
Overhead
Hardened Underground Total
Out Pop
%
Out Out Pop
o/o
Out Out Pop
%
Out Out Pop %Oul
Distribution Feeders 280 2,031 1,4%6B 72r 9%7L 493 2o/o 359 3,245 13%
Distribution Laterals 3,413 82,729 N.A.N.A N.A.238 101,892 0.2%3,7LL r84,621 2%
rRMA- 2017
Overhead Non-Hardened
Overhead
Hardened Undereround Total
Out Pop
Yo
Out Out Pop
o/o
Out Out Pop
%
Out Out Pop
o/o
Out
Distribution Feeders 1,609 1,958 82%592 8s9 69%B5 470 L8%2,286 3,281 70%
Distribution Laterals 20,341 84,574 24%N.A.N.A.N.A.3,767 103,384 4%24,r08 187,958 13%
Docket No. 2020007l-El
FPL'S 2O2O-2O29 Storm Protection Plan
Exhibit MJ- l , APPENDIX A (Page I of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 8 of9
The tables below provide substation line section outage perfonnance for Hurricanes Matthew
and lrma.
* 2 sections were out because substation was proactively de-energized due to flooding
** 4 sections were out because substations were proactively de-energized due to flooding
*** No underground section was damaged or failed causing an outage; however, the sections were out due to line
termination equipment in substations.
The table below compares substation outage and restoration performance - Irma vs, Wilma.
Smart Grid Performance
During Hurricane Matthew and lrma, smart grid devices prevented a significant amount of
customer outages, assisted with restoration efforts and reduced restoration time and costs.
Specifically, automated feeder switches avoided approximately 664,000 outages during
Hurricanes Matthew and Irma. Additionally, FPL's restoration crews are able to "ping" smart
meters before leaving an area to ensure that power is, in fact, restored. This prevents restoration
crews from leavingan area, thinking all power was restored, only to be called back when the
customer informs FPL that they are still without service. FPL is also enhancing an application,
first utilized during Hurricanes Matthew and Irma, whereby it will be able to "bulk meter ping"
smart meters to confirm whether customers have service.
Trans. Line Sections t6 350 5%23*846 3%0 49 0%39 1,,245 3o/o
Trans. Line Sections 60 306 20%742**884 16%13***51 25o/o 215 1241 17%
De-enereized 247 92
7Restored {Davs}5
Matthew - 2016 118,000
lrma - 2Ot7 546,000
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 10 of 1 B)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 9 of9
Estimate of Storm Restoration Cost Savinss Due to Tfardenino based nn Sform T)amaqe
Model Simulation
The attached analysis provides an estimate of transmission and distribution storm restoration
savings for Hurricanes Matthew and Irma that resulted from storm hardening completed by FPL
prior to the storms' impacts. To calculate these savings, FPL utilized its Storm Damage Model
(the same model FPL utilizes to estimate damage when a storm approaches FPL's service
tenitory) to simulate damage that likely would have occurued without hardening and determine
the associated required construction man hours (CMH) that would have been required to restore
service in the absence of hardening, days to restore in the absence of hardening and associated
incremental restoration costs. Additionally, FPL calculated the 4}-year net present value of these
savings for two scenarios - (l) a similar storm occurs every 3 years; and (2) a similar storm
occurs every 5 years.
As indicated on the attached analysis, the 40-year net present values of the savings related to
storm hardening are significant. In the absence of hardening the estimated percentage increase in
CMHs for Hurricane Matthew and Huricane Irma restoration would have been significantly
higher (36% and 40olo, respectively), days to restore would have been increased (50o/o and 40o/o,
respectively) and restoration costs would have been greater (36% and 40o/o, respectively).
Florida Power & Light Company
Docket No. 2Of7O2I'-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1
Tablof5
Docket No. 20200071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX A (Page 11 of 18)
Estimate of Storm Restoration Cost Savinqs Due to Hardening based on Storm Damage Model Simulation
I1l I2l t3I
Construction Man-Hours
t4I I5I t6l I7t
to Restore
[81
o/o lncrease
without
Hardening
50%
40%
Additional
Days to
Restore
without
Hardening
2
4
Modeled
System
Without
Hardening
6
74
Actual
4
L0
tel [10] [111
Storm Restoration Costs
lt2l [ 131
40 Yr NPV
l14l
Storm
Matthew
lrma
Notes:
All costs and CMH are Transmission and Distribution only, and exclusive of follow-up work
[ 1 I Calculated based on actual storm restoration requirements
[2] FPLstormdamagemodel simulationresultsof CMHincurredwithouthardening
[ 3 I Additional CMH without hardening {Col. 2 - Col. 1)
[ 4] Percent increase in CMH without hardening (Col. 3/Col. 1)
[ 5 ] Actual days to restore seruice
[ 6 ] Storm da mage model simu lation result of the days to restore service without hardening (assu mes same restoration resources as actual)
[ 7 ] Additional days to restore without hardening (Col. 6 - Col. 5)
I I ] Percent increase in days to restore without hardening (Col. 7/Col. 5)
[ 9 I Actual cost of restoration. lrma costs are preliminarv
[ 10 ] Storm damage model simulation result of restoration costs without hardening
[ 11 I Additional restoration costs without hardening (Col. 10 - Col.9)
[ 12 I Percent increase in restoration costs without h ardening ((Col. fi/Col. 9\
[ 13 I 40 year net present value savings assuming a similar storm everylEgg years (calculation details attached)
[ 14 I 40 year net present value savings assuming a similar storm everyfive years (calculation details attached)
% lncrease
without
Hardening
356/I
40%
Additional
CMH
without
Hardening
93.000
483,000
Modeled
System
Without
Hardening
350.000
r.,678.000
Actual
257.OO0
1.1q5.000
94 lncrease
without
Hardening
36%
4A%
s10s
Additional
Storm
Restoration
Costs
without
Hardenins
S496
s39s
s1.722
Modeled
System
Without
Hardening
s7.226
Actual
S29o
40 Yr NPV
Savings Every
5 Years
(2017s)
s405
s1.91s
40 Yr NPV
Savings Every
3 Years
(2017s)
s6s3
s3,082
Docket No. 202O0071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 12 ot 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1
Tab2of5
Estimated Storm Restoration Costs Savings due to Hardening (SMM)
40-Year NPV (20175)
Matthew Savings
Everv 3 vears Every 5 vears
S6s3 s406
Discount Rate = 7.760/o
s1
Ls
L
2
3
4
5
6
1
8
9
10
11
t2
13
t4
15
16
17
L8
19
20
2I
22
23
24
25
26
27
Slos
So
So
S1i-3
$o
$o
S121
s13s
So
So
Slso
so
So
$o
So
S13o
So
So
s18s
So
so
61.
$o
$o
73
So
So
cPt
21%
2.4%
2.4%
2.6%
2.t%
t.7%
25%
2.4%
2.3%
2.2%
2.2%
2.2%
2.2%
2.2%
2.2%
2.1%
2.L%
2.1%
2.1%
2.L%
21%
2.to/o
2.L%
2.1%
2.L%
2.1%
2.1%
Si.os
5o
So
So
So
$118
so
5o
So
So
$133
$16s
So
So
So
So
Si.so
So
cPt
Multiplier
1.000
1.024
1.049
1.076
1.105
1124
1.152
1.179
1.206
1.233
1.260
1.288
1.317
1.346
1.375
1.404
1.434
1.464
1.495
1.526
1.558
1.590
1.623
1.656
1.691
1.727
1.763
Matthew
$1os
Si-07
S1i.o
Si_i.3
s11s
$1ls
$t2L
5124
Srzl
S13o
s133
S136
s13e
Si-43
Si_46
s1s0
sls3
S1s7
S16i-
S16s
$16e
$173
St77
S1s1
S18s
Si-so
Si-94
SO
SO
So
So
s1s0
so
so
So
So
Year
Matthew Savings
Everv 3 vears Everv 5 vears
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 13 of 1 B)
28
29
30
31
32
33
34
35
36
37
38
39
40
$1es
So
$o
52L4
So
So
s23o
so
So
s246
$o
So
5o
s2L4
$o
So
So
So
S24L
So
So
so
So
2.7%
2.2%
2.2o/o
2.1o/o
2.2o/o
2.Lo/o
2.7%
2.L%
2.1%
2.L%
2.Lo/o
2.!o/o
2.7%
1.801
1.840
1.880
1.920
1.962
2.004
2.047
2.090
2.135
2.180
2.226
2.274
2.322
Slee
S2o4
S2oe
$zt4
Szt g
s224
s230
s23s
$241
5246
$2s2
$2s8
s26s
so
so
Szos
NPV (2017s)s6s3 S+oe
Docket No. 20200071-El
FPL'9 2O2O-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 14 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1
Tab3of5
So
So
5s32
Estimated Storm Restoration Costs Savings due to Hardening (SMM)
40-Year NPV (2017S)
lrma Savings
Everv 3 vears Everv 5 vears
s3,082 S1,915
Discount Rate =7.760/o
1
2
3
4
5
6
7
8
9
10
11
12
13
t4
15
1.6
17
18
19
20
21.
22
23
24
25
26
27
96S+
s613
$o
So
s6ss
$o
So
s707
5o
$o
STss
So
so
S8]-s
so
So
Ss76
So
So
So
$o
$o
$o
s7e6
so
$o
So
So
SseT
$o
2.L%
2.4%
2.4o/o
2.6%
2.7%
1..7%
2.s%
2.4%
23%
2.2%
2.2%
2.2%
2.2%
2.2%
2.2o/o
2.1%o
2.1%
2.L%
2.I%o
2.1%
2.I%
2.1%
2.r%
2.L%
2.1%
2.1%
2.1%
S4s6
So
So
so
SO
sss8
$o
So
So
so
s628
so
So
$o
So
5707
cPl lrma
S4e6
SsoT
Ss20
Ss32
Ss+s
sss8
Sszr
Ss8s
$sse
$613
$628
$543
S6ss
$at+
s6e1
5707
$t24.
$742
STse
Stig
s7s6
S81s
s83s
S8ss
$876
SseT
ss18
cPl
Multiplier
1.000
1.024
1.049
1.076
1 .105
1j24
1.152
1.179
1.206
1.233
1.260
1.288
1.317
1.346
1.375
1.404
1.434
1.464
1.495
1.526
1.558
1.590
1.623
1.656
1.69'1
1.727
1.763
So
So
$szr
$o
$o
Matthew Savings
EveIy 3 vears Everv 5 vearsYear
Docket No. 20200071-El
FPL's 202O-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 15 of 18)
So
28
29
30
31
32
33
34
35
35
37
38
39
40
ss40
So
so
S1,oo9
So
$o
S1,084
So
$o
s1,164
5o
So
s 2s0
$o
So
So
s1,009
so
$o
$o
s1,136
So
so
$o
So
21%
2.2%
2.2%
2.L%
2.2%
2.7%
2.L%
2.L%
2.t%
2.L%
2.r%
2.L%
2,L%
1.801
1.840
1.880
1.920
1.962
2.004
2.047
2.090
2.135
2.180
2.226
2.274
2.322
Ss40
$e63
se86
Sr_,ooe
Sr,og+
$1,058
S1,084
S1,110
$t,tge
$1,164
$t,tgz
5t,zzo
$1,2s0
NPV (2017s)$1,915s3,082
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-l , APPENDIX A (Page 16 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1
Tab4of5
FPL
WEIGHTED AVERAGE COST OF CAPITAL
STATE INCOME TAX
FEDERAL INCOME T
5.50%
21.00o/o
COMPOSITE INCOME TAX RAT 25.35O/O
MODEL DATE:1-Jan-1 8
Debt Gost Based on Blue Chip Corporate Aaa and Bbb Bonds
AFTERTAX PRETAX
SOURCE /VEIGHT(1) COST(2)/TD COST /TD COST /TD COST
DEBT
COMMON
40.40%
59.60%
4.88o/o
10.55%
1.97%
6.29o/o
147%
6.29%
1.97%
8.42o/o
TOTAL 100.00%8.26% 7.760/0 10.39%
AFTER-TAX WACC 7.76%
Docket No. 20200O71-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX A (Page 17 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. L
Tab5of5
Consumer Prices (1982-84=L.000) All-Urban
(Forecast adjusted to match budget assumptions)
lndex % Change
2009 2.1454
201.0 2.1806 1_.640/o
2017 2.2494 3.16%
20L2 2.2959 2.07%
20L3 2.3296 1.460/o
2014 2.3674 1,.62%
2015 2.3702 0.r2%
20L6 2.4007 1,.26%
20L7 2.4512 2.13%
2018
2019
2020
2021
2022
2023
2A24
2025
2026
2027
2028
2029
2030
2031.
2032
2033
2034
2035
2036
2037
2038
2039
2040
2041.
2042
2043
2044
2045
2046
2.s100
2.5703
2.637r
2.7083
2.7553
2.8237
2.8909
2.9569
3.0228
3.0895
3.1573
3.2270
3.2981
3.3693
3.44LL
3.5142
3.5887
3.6642
3.7408
3.8187
3.8972
3.9779
4.0603
4.L449
4.2324
4.3226
4.4153
4.5104
4.6017
2.40%
2.40%
2.60%
2.70%
L.73%
2.46%
2.40%
2.28%
2.23%
2.2L%
2.19%
2.21%
2.20%
2.16%
2.L3%
2.L2%
2.12%
2.LO%
2.O9%
2.08o/o
2.06%
2.O7%
2.O7%
2.08%
2.tLo/o
2.t3%
2.L5%
2.L5%
2.16%
Budget Assumptions
2.40%
2.40%
2.60%
2.to%
Docket No. 20200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 18 of 1B)
2047
2048
4.7067
4.8099
2.r5%
2.19%
2049
2050
2051
2052
2053
2054
2055
20s6
2051
4.9122
5.0167
5.1233
s.2323
5.3435
5.4572
5.5132
5.6917
5.8128
2.L3%
2.L3%
2.13%
2.r3%
2.13%
2.r3%
2.I3o/o
2.r3%
2.13o/o
Actuals thru 2017 from BLS
APPENDIX
(FPL's Management ]
:t31
.--,
3ildr
Ai
d
I
i
!-'tF.tr.orr.
Docket No. 20200071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX C (Page 1 of 2)
APPENDIXC
(FPL' s 2020-2029 Estimated SPP Costs)
2020-2029 FPL SPP Program Costs/Activities
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX C (Page 2 of 2)
Distribution - Pole lnspections
Operating Expenses
Capital Expenditures
Total
# of Pole lnsPections
Transmission - lnspections
Operating ExPenses
Capital Expenditures
Total
# of Structure lnspections
Distribution - Feeder Hardenins (1) (2)
Operating ExPenses
capital Expenditures
Total
# of Feeders (3)
Distribution Lateral Hardenins (1) (2)
Operating Expenses
capital Expenditures
Total
# of Laterals (3)
Transmission - Replacinq Wood Structures
Operating Expenses
Capital Expenditures
Total
# of Structures to be RePlaced
Distribution - Vesetation Management
Labor ' Contractor
Labor - FPL
Equipment - Contractor
Equipment - FPL
Total
# of Miles Maintained
Transmission - Vegetation Manasement
Labor - Contractor
Labor - FPL
Equipment - Contractor
Equipment - FPL
Total
# of Miles Maintained
Substation Storm surse/Flood Mitisation
Operating Expenses
Capital Expenditures
Total
# of Substations
50.7 54.1
in mil
3.8 s 3.8 5
ss.3 s ss.3 ssg.os s9.r.5 60.3
r.54,000 1s4,000 154,000
1.0 s 1.0 s
67.s s s4.6 50g.ss ss.6s s3.o
68,000 58,000 68,000
573.3 474.5 200.0
474.5 2oo.o s
3.9
56,4
3.9
57.4
4.0
s9.3
4.1
60.8
54.5
r.50,000
35.8
68,000
57.9
r.50,000
32.2
68,000
s7.9
154,000
28.9
68,000
7,000
5r..8
154,000
63.3
1"54,000
64.9
154,000
3.9
s6.6
1.0
48_9
s
0.2 s
5 5 4.2
62.3
s 39.1 s
s55.x s56.ss 60s.2s 60.s
r-54,000
ss1.3 s
34.s s
1.0
3r.2
1.0
27.9
1.0
52.O
s 1.0
54.6
1.0
56.0
s
55.7
58,000
647.2 663.4
800-900 800-900
r.o 5
s7.4 s
s7.o s s8.4 s
68,000 58,000
lo.s s
489.0 s
s 117.9
s 453.7 s
s 14.7 s
s 11s.9 s
1.0
53.3
5 5
54.3
68,000
s
663.4 679.9 696.9
499.s s s0.0
534.3
3,20s.8 534.3
510.1
695.9 5,101.4 s 510.1
800-900
628.r 564.9 s 654.9
628.r-s 664.9s 664.9
300-3s0 300-3s0 300-3s0
s
s573.3
300-350 250-350
r20.4 2a2.5
s r2o.4 5 212.s
220-230 300-350
342.8 475.6 631.4 5 631.4 S 647.2
342.8
400-500
47s.6s 631.4s 63r.4
600-700 800-900 800-900
679.9
800-900
s
s
s
5
s
s
1.5
0.r.L.40.1
s
s
s
5.3
t,4
1.7
)
s23.O
s
s
s
s
5
0.2
42.7
47.8
1_.4
L2.O
0.1
6.7 s
0.s s
1.7 s
M.6
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Total SPP Costs
(1") Project level detail for 2020 in Appendix
(2) Costs include previous year(s) projects carried over to current year's project costs and future year's preliminary project costs (e.9., engineering)
(3) # of feeders or lateral to be initiated in the current year
Total SPP Annual
Costs Average Cost2023,FPL 5PP Programs 202520222024 2026 2027 2028 20292023 2024
Docket No. 20200071-El
FPL'9 2O2O-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 1 of 14)
APPENDIXD
(FPL's Hardening Design Guidelines)
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX D (Page 2 ot 14)
@FPL
Distribution Design G uidelines
The following guidelines will be used to standardize the design of FPL's overhead distribution
facilities when practical, feasible, and cost effective.
General
1. FPL has made a change to adopt Extreme Wind loading (EWL) as the design criteria for:
(1) new pole line construction, (2) pole line extensions, (3) pole line relocations, (4)
feeder pole replacements on multi-circuit pole lines, and (5)feeder pole replacements on
Top-ClF feeders. Reference the Pole Sizing section (pg. 7) for the guidelines to
determine the necessary pole class and type for all work. Refer to the Distribution
Engineering Reference Manual Addendum for calculating pole sizes for specific framing
under extreme wind loading conditions.
2. For maintenance, existing non-top-ClF pole lines may be evaluated using NESC combined
ice and wind loading with Grade B construction. This represents the loading prior to the
adoption of extreme wind loading. lf the pole must be replaced, refer to the Pole Sizing
section for the minimum class pole to be installed. Refer to the Distribution Engineering
Reference Manual (DERM) Section 4 for calculating pole sizes for specific framing under
the NESC combined ice and wind loading conditions.
3. Every attempt should be made to place new or replacement poles in private easements
or as close to the front edge of property (right of way line) as practical.
4. Overhead pole lines should be placed in front lot lines or accessible locations where
feasible.
5. \Nhen replacing poles, the new pole should be set as close as possible to the existing
pole to avoid the creation of a new pole location.
6. Poles are not to be placed in medians.
7. Concrete poles are not to be placed in inaccessible locations or locations that could
potentially become inaccessi ble.
8. Please reference the minimum setting depth charts located in DCS D-3.0.0 which shows
the increased setting depths for concrete poles.
g. Every effort should be made not to install poles in sidewalks. lf a pole must be placed in
a sidewalk, a minimum unobstructed sidewalk width of 32" must be maintained to comply
with the American Disabilities Act (ADA) requirements.
10. lf concrete poles are required by the governing agency as a requirement of the permit,
and if the work is being done solely for FPL purposes (feeder tie, etc.), then the concrete
Docket No. 20200071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 3 of 14)
poles are installed with no differential charges. lf the concrete poles are required as a
condition of the permit, and the work is being done at the request of a customer (and fall
outside the Pole Sizing Guidelines) to provide seruice to the customer or relocation by
request of the customer, then the customer is charged a differential cost for the concrete
poles.
11. When installing new OH secondary spans, multiplexed cable should be used instead of
open wire secondary. When reconductoring or relocating existing pole lines containing
open wire secondary, replace the open wire with multiplexed cable whenever possible.
The system neutral should not be removed when replacing open wire secondary with
multiplexed cable if primary wire is present. lt is necessary to maintain a separate
system neutral for operational continuity of the system.
12. U/hen designing overhead facilities where secondary and service crossings exist across
major roadways, the engineer should take into consideration placing these secondary
street crossings underground. Operations Director Approval is required.
13. V/henever extending a feeder, reconductoring a feeder section, or attaching a device to a
feeder, always reference the nearest existing disconnect switch number on the
construction drawing and show the dimension to the switch. This will aid the Control
Centers in updating their switching system and will aid AMG in updating AMS, as well as
provide the Productioh Lead and Distribution Tech information needed for switching and
RC Off requests.
14. When an overhead feeder crosses any obstacle to access (i.e. - water bodies such as
rivers, canals, swamps; limited access RA// such as interstate highways, turnpikes, and
expressways; etc.) disconnect switches should be placed on both sides of the obstacle in
order to isolate the crossing in the event of a wiredown situation. See the example in the
Crossing Multi-Lane Limited Access Highways section (pg. 5).
15. Projects that affect or extend feeder conductors should always be coordinated with
Distribution Planning to ensure optimization of the distribution grid. Taking into account
future feeder plans such as, feeder boundary changes, sectionalizing devices, integration
of automation and remotely controlled protection.
As always, good engineering judgment, safety, reliability, and cost effectiveness should be
considered. ln addition to these guidelines, all distribution facilities shall be engineered to meet
the minimum requirements set forth in all applicable standards and codes including but not
limited to the National Electrical Safety Code (NESC), Utility Accommodation Guide, and FPL
Distribution Construction Standards. Please contact a Distribution Construction Services (DCS)
analyst with any questions.
@
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection PIan
Exhibit MJ-1, APPENDIX D (Page 4 of 14)
FPL
New Construction
When installing a new feeder, lateral, or service pole, reference the Pole Sizing section for
the guidelines to determine the necessary pole class and type to meet Extreme Wind
Loading (EWL) for the wind zone region (105, 130, or 145 MPH).
2. Modified Vertical is the preferred framing for accessible locations. Post-top (single phase) or
Cross Arm (multi-phase) is the preferred framing for inaccessible locations.
3. During the design of new pole lines in developed areas, field visits should be conducted to
ensure the design would cause minimum impact to the existing property owners.
4. Overhead pole lines should not be built on both sides of a roadway unless agreed to by the
customer nor should multi-circuit pole lines be created. When designing main feeder routes
allviable options must be reviewed (including alternative routes) and consideration should
be given to constructing the line underground. lf undergrounding is chosen and it is no!-the
leait cost option, approval is required from the Engineering & Technical Services Director
and the Operations Director. ln addition, priorto proceeding with any pole lines on both
sides of a street or any multi-circuit feeder design recommendations, Operations Director
approval is required.
5. When there is an existing pole line in the rear easement, every effort should be made not to
build a second pole line along the right of way.
6. When installing a pole line within a transmission line, accessible distribution poles should be
concrete. Distribution concrete poles should not be installed in inaccessible locations.
7. lf concrete distribution poles are installed in a concrete transmission line, there is no
additional charge to the customer (the concrete poles are FPL's choice and not requested by
the customer). boordination between the transmission and distribution design is critical and
consideration should be given to a design with alltransmission poles versus distribution
intermediate poles. This approach will reduce the overall number of poles.
B. When transmission is overbuilding (concrete structures), along an existing distribution
corridor, if the distribution wood poles are in good condition, do not replace. lf wood poles
need to be changed out or relocated, replace with concrete poles to match the transmission
pole type. Coordination between the transmission and distribution design is critical and
consideration should be given to a design with alltransmission poles versus distribution
intermediate poles. This approach will reduce the overall number of poles.
1
Docket No. 2O20O071-EI
FPL'9 2020-2029 Storm Protection PIan
Exhibit MJ-1, APPENDIX D (Page 5 of 14)
FPL
Existing / Maintenance
1. When installing and/or replacing a feeder, lateral, or service pole on an existing pole line,
reference the Pole Sizing section for the guidelines to determine the necessary pole class
and type.
2. When installing or replacing a feeder pole on a feeder that serves a Top-ClF customer,
ensure the new pole will meet extreme wind loading (versus just a minimum class 2 or lllH
pole) so that it will not have to be replaced when the feeder is hardened as a hardening
project. Please reference the Storm Secure Hardening SharePoint Site: Distribution >
Central Maintenance > Central Contractor Services > Hardening > Reports > Feeder
Prioritization-xxxxxx Snapshot for the list of Top-ClF feeders within the Prioritization File.
3. When extending pole lines, the existing pole type should be used as a guide for the new
pole type. lf concrete poles are requested by the customer or are required as a condition of
the permit and fall outside the Pole Sizing Guidelines, the customer will pay a differential
charge for the concrete poles.
4. \Nhen replacing pole(s) and anchor(s) with larger self-supporting concrete poles, caution
should be used, as the property owners in the vicinity of the pole will not necessarily
perceive this concrete pole as a better choice.
5. When replacing poles on a multi-circuit feeder the replacement pole should be designed for
Extreme Wind Loading using Pole Foreman to calculate the wind loading.
Relocations
1. When relocating a pole line, reference the Pole Sizing section for the guidelines to determine
the necessary pole class and type to meet Extreme \Mnd Loading (EWL) for the wind zone
region (105, 130, or 145 MPH).
2. When relocating either a concrete or wood pole line for a highway improvement project, the
existing pole line 'type' should be used as a guide for the pole type replacements. There is
no additional charge for concrete poles if the existing poles being relocated are concrete
(like for like relocation). lf the customer requests an "upgrade" to concrete poles, a
differential is charged.
3. Reimbursable relocations will equal the cost to relocate the line built to Extreme Wind
Loading (plus removal of old), including indirect cost.
4. Agency relocation projects should be coordinated with Distribution Planning to ensure
optimization of the distribution grid and to take into account future feeder plans and potential
feeder boundary changes.
@
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX D (Page 6 of 14)
@FPL
Grossing Multi-Lane Limited Access Highways
The following guidelines are to be used when an overhead feeder crosses any obstacle to
access (i.e. -limited access RA/r/ such as interstate highways, turnpikes, and expressways,
etc.). Similar consideration can be given to water bodies such as rivers, canals, swamps.
1. Underground installation is the preferred design for all new crossings (1,2,3 phase) of multi-
lane limited access highways & hardening of existing crossings; reference Fig 1. Limited
Access Highway Crossing Schematic (Preferred). lf underground construction is not
feasible, reference Fig 2. Limited Access Highway Crossing Schematic (Alternate).
2. Underground crossing for 1 & 2 phases should be designed for potential three phase feeder
size cible. Ensure riser poles meet or exceed extreme wind design for the designated
region. For further information, please contact the CMC Hardening Group.
3. For accessible overhead crossings, use concrete poles (lll-H or greater square concrete
pole) for the crossing poles and minimum Class 2 wood poles for the intermediate poles. For
inaccessible overhead crossings, minimum Class 2 wood poles should be used for the
crossing and intermediate poles. All poles installed should meet or exceed EWL for the
designated region.
4. Every attempt should be made to install storm guys & back guys for the highway crossing
poles. Storm guys are not required on the adjacent poles.
5. Frame the highway crossing pole double dead-end (See LOC 2 & 3 Fig 2 below)'
6. lnstall disconnect switches on adjacent poles on both sides of the crossing (or as required
by field conditions) to isolate the feeder section for restoration. Switches are to be installed
in accessible locations that can be reached with readily available aerial equipment.
Switches should be installed at -42 Above Grade (AG), with a maximum pole size of 50'
wood or 55' concrete. lf there is no load between the nearest existing switch and the
crossing, an additionalswitch is not required.
7. Checkforupliftonallpoles. RefertoDERMSection 4.2.3Page4of 16&DCSE4.0'2and
E-4.0.3. Back guys should be installed at the adjacent pole if required for uplift.
B. Ensure to maintain proper clearance above or under all highways as dictated by the owner
of the RAff & DCS 8-3.0.1.
g. Any conductors crossing the highway that have splices should be replaced with a continuous
conductor (NESC 261H2a). See Fig 2 below for additional notes on the use of splices on
adjacent spans. One additional set of dead-end insulators at the highway oossing pole may
bs used if this eliminates the need for splices when installing a new pole.
Docket No. 2020O071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 7 of 14)
@trtrL
10. Engineers must conduct a pre-design meeting with the Production Lead to ensure the
feasibility of the proposed design.
11. As always, use good engineering judgment to produce a quality, cost-effective design
Fig 1. Limited Access Ilighway Crossing Schematic (Preferred)
Fig 2. Limited Access Highway Crossing Schematic (Alternate)
INSTALL ACCESSIBLE
DISCONNECT SWTCHES
REMOVE OH &INSTAI.L ACCESSIBLE
DISCONNECTSWTCHESDIRECNONAL
3 #5687-23rO/ &3/0T-N
ItF -
FNc -{lF -o
a o o--BIoroouo
ouF
=J
a
DOWNGUY FOR OEAOEND
OUTSIDE OF LIMITED
ACCESS HIGHUIAY. ADJUST
LOCATION OF POLE FOR
FIELO CONDITIONS
ALTERNATE LOCATION FOR
RISER POLE TO PREVENT
DOWN GUY IN LIMITED
ACCESS R/W
DISC SW @ -.t2'AG
MAX POLE SIZE:
50'wooD, 55' coNcRETE
INSTALL ACCESSIBLE
DISCONNECTSWITCHES NO SPLICES INSTALL ACCESSIBLE
DISCONNECT SWTCHES
3 #568T-231C/ & 568T-N
CHECK FOR UPLIFT A
INSTALL DOWN GUYS IF T
I
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t
!
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IL
J
J
REQUIRED
o ---J F--(---g
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auE
=
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a-\
-a 4 a
J DISC SW @ -,12' AG
MAX POLE SIZE:
50'wooD, 55'coNcRETE
(swTcH LocAnoN MAY
VARY BASED ON FIELD
CONO''7OA'S. REFERENCE
D'STRIBUT'ON DESIGN
GUTDELTNES)
&
INSTALL IMTERMEOIATE POLE IN
EFFORT TO REDUCE SPANS
INSTALLSTORM
GIJYS & SACK
GUY
1
Christopher T. Wright
Senior Attorney - Regulatory
Florida Power & Light Company
700 Universe Blvd
Juno Beach, FL 33408-0420
Phone: (561) 691-7144
E-mail: Christoper.Wri ght@fpl.com
Florida Authorized House Counsel;
Admitted in Pennsylvania
April10,2020
VA ELECTRONIC FILING
Mr. Adam Teitzman
Division of the Commission Clerk and Administrative Services
Florida Public Service Commission
2540 Shumard Oak Blvd.
Tallahassee, FL 32399-0850
Re: Docket No. 20200071-EI
Review of 2020-2029 Storm Protection Plan pursuant to Rule 25-6.030, F.A.C.,
Florida Power & Lieht Companv
Dear Mr. Teitzman:
Enclosed for electronic filing in the above-referenced docket, please find Florida Power & Light
Company's Petition for Approval of the 2020-2029 Storm Protection Plan pursuant to Rule 25-
6.030, F.A.C., together with the Direct Testimony of FPL witness Michael Jaro and Exhibit MJ-
1. Copies of this filing will be provided as indicated on the enclosed Certificate of Service.
If you or your staff have any question regarding this filing, please contact me at (561) 691-7144.
Respectfully submitted,
s/Christopher Wrisht
Christopher T. Wright
Authorized House Counsel No. 1007055
Enclosure
FF'L-
Florida Power & Light Company
700 Universe Boulevard, Juno Beach, FL 33408
Page | L
BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
Review of 2020-2029 Storm Protection Plan pursuant
to Rule 25-6.030, F.A.C., Florida Power & Light
Company
Docket No. 2020007l-EI
Filed: April 10,2020
PETITION OF FLORIDA POWER & LIGHT COMPAi\Y
F'OR APPROVAL OF THE STORM PROTECTION PI,A,N
L INTRODUCTION
Florida Power &Light Company ("FPL" or the 'oCompany") hereby files this petition (the
"Petition") requesting that the Florida Public Service Commission ("Commission") approve the
proposed Transmission and Distribution ("T&D") Storm Protection Plan for the years 2020-2029
(hereinafter, the "SPP") pursuant to Section 366.96, Florida Statutes ("F.S.") and Rule 25-6.030,
Florida Administrative Code ("F.A.C."). FPL's SPP is, in large parI, a continuation and expansion
of its previously approved and successful storm hardening and storm preparedness programs. FPL
submits that the storm hardening and storm preparedness programs included in its SPP are
appropriate and necessary to achieve the legislative objectives of Section366.96, F.S., to protect
and strengthen T&D infrastructure from extreme weather conditions, reduce outage times and
restoration costs, and improve overall service reliability to customers.l In support of this Petition,
FPL states as follows:
1. The name and address of the Petitioner is:
Florida Power & Light Company
700 Universe Blvd
Juno Beach, FL 33408
1 The recovery of costs associated with the SPP, as well as the actual and projected costs to be included in
FPL's Storm Protection Plan Cost Recovery Clause, will be addressed in subsequent and separate Storm
Protection Plan Cost Recovery Clause dockets pursuant to Rule 25-6.031, F.A.C. The Commission has
opened Docket No. 20200092-El to address Storm Protection Plan Cost Recovery Clause petitions to be
filed the third quarter of 2020.
1
2. FPL is a corporation organized and existing under the laws of the State of Florida
and is an electric utility as defined in Sections 366.02(2) and366.96, F.S. FPL provides generation,
transmission, and distribution seryice to nearly five million retail customer accounts.
3. Any pleading, motion, notice, order or other document required to be served upon
the petitioner or filed by any party to this proceeding should be served upon all of the following
individuals:
John T. Burnett
Vice President and Deputy General Counsel
Christopher T. Wright
Senior Attorney
Florida Power & Light Company
700 Universe Boulevard
Juno Beach, FL 33408-0420
Phone: 56I-69I-7144
Fax: 561-691-7135
Email: iohn.t.burnett@.fol.com
Email : christopher.wri ght@fpl.com
4. The Commission has jurisdiction pursuant to Section 366.96, F.S., and Rule 25-
6.030, F.A.C.
5. This Petition is being filed consistent with Rule 28-106.201, F.A.C. The agency
affected is the Commission, located at2540 Shumard Oak Boulevard, Tallahassee, Florida32399.
This case does not involve reversal or modification of an agency decision or an agency's proposed
action. Therefore, subparagraph (c) and portions ofsubparagraphs (b), (e), (0 and (g) ofsubsection
(2) of Rule 28-106.201, F.A.C., are not applicable to this Petition. ln compliance with
subparagraph (d) of Rule 28-106.201 , F.A.C., FPL states that it is not known which, if any, of the
issues of material fact set forth in the body of this Petition may be disputed by any others who may
plan to participate in this proceeding. The discussion below demonstrates how the petitioner's
substantial interests will be affected by the agency determination.
2
Kenneth A. Hoffman
Vice President, Regulatory Affairs
Florida Power & Light Company
215 South Monroe Street, Suite 810
Tallahassee,FL 32301
Phone: 850^521-3919
Fax: 850-521-3939
Email : ken.hoffman@fpl.com
II.BACKGROUND ND OVERVIEW
6. On June 27,2079, the Governor of Florida signed CS/CS/CS/SB 796 addressing
Storm Protection Plan Cost Recovery, which was codified in Section 366.96, F.S. Therein, the
Florida Legislature found that it was in the State's interest to "strengthen electric utility
infrastructure to withstand extreme weather conditions by promoting the overhead hardening of
electrical distribution and transmission facilities, the undergrounding of certain electrical
distribution lines, and vegetation management," and for each electric utility to "mitigate restoration
costs and outage times to utility customers when developing transmission and distribution storm
protection plans." Section 366.96(I), F.S. The Florida Legislature directed the Commission to
adopt rules to specify the elements that must be included in each utility's SPP. Section 366.96(l),
F.S.
7. Rule 25-6.030, F.A.C., requires each utility to file an updated SPP at least every
three years that covers the utility's immediate ten-year planning period. Rule 25-6.030, F.A.C.,
also specifies the information to be included in each utility's SPP. Consistent with these
requirements, FPL is herein submitting its SPP for the ten-year period of 2020-2029, which is
provided as Exhibit MJ-1.
8. FPL's SPP is largely a continuation and expansion of its existing storm hardening
and storm preparedness programs, which were most recently approved in FPL's 2019-2021 Storm
Hardening Plan.2 These existing hardening and storm preparedness programs have already
demonstrated that they have and will continue to increase T&D infrastructure resiliency, reduce
restoration times, and reduce restoration costs when FPL's system is impacted by extreme weather
2 See In re: Petitionfor Approval of Florida Power & Light Company's 2019-2021 Storm Hardening Plan
pursuant to Rule 25-6.0342, F.A.C.,DocketNo. 20180144-EI, OrderNo. PSC-2019-0364-CO-EI (Fla. PSC
Aug. 27 , 20 1 9) (making Order No. PSC-20 I 9-03 0 I -PAA-EI issued on July 29 , 2019, effective and final).
J
events. FPL performed an analysis of Hurricanes Matthew and Irma that indicated the restoration
construction man-hours ("CMH"), days to restore, and storm restoration costs for these storms
would have been significantly higher without FPL's storm hardening programs.3
9. While FPL's nation-leading initiatives have made significant progress toward
strengthening FPL's infrastructure, FPL must continue its T&D storm hardening and storm
preparedness plans and initiatives. Storms remain a constant threat and Florida is the most
hurricane-prone state in the nation. With the significant coast-line exposure of FPL's system, and
the fact that the majority of FPL's customers live within twenty miles of the coast, a robust storm
protection plan is critical to maintaining and improving grid resiliency and storm restoration as
contemplated by the Legislature in Section 366.96.
10. As part of its SPP, FPL will continue the previously approved storm hardening and
storm preparedness programs to achieve the legislative objectives of promoting the overhead
hardening of T&D facilities, the undergrounding of distribution lines, and vegetation management
to reduce restoration costs and outage times to customers and improve the overall service reliability
for customers. In addition, FPL proposes to implement a new substation storm surge/flood
mitigation program. FPL submits that the SPP will continue and expand the benefits of hardening,
including improved day-to-day reliability, to all customers throughout FPL's system.
11. Submitted herewith and in support of FPL's SPP is the Direct Testimony of Michael
Jarro and Exhibit MJ-l, which includes FPL's SPP for the period of 2020-2029 and supporting
schedules.
3 ,See FPL's Third Supplemental Response to Staffs First Data Request No. 29 ("Third Supplemental
Amended") in Docket No. 20170215-EI, which is provided as Appendix A to Exhibit MJ-l.
4
III. STORM PROTECTION PLAI\
A. Description of the SPP Programs
12. FPL's SPP is largely a cbntinuation and expansion of the following previously
approved storm harde;:H.;ffi
J;,::;;
Structures/Other Equipment Inspections - Transmission Program
Feeder Hardening (EWL) - Distribution Program
Lateral Hardening (Undergrounding) - Distribution Program
Wood Structures Hardening (Replacing) - Transmission Program
Vegetation Management - Distribution Program
Vegetation Management - Transmission Program
In addition, FPL proposes to implement a new Substation Storm Surge/Flood Mitigation-Program
to protect T&D substations and equipment that are susceptible to storm surge or flooding during
extreme weather events. These SPP programs are summarized below and a detailed description
of each SPP program, consistent with Rule 25-6.030(3Xd), F.A.C., is provided in Section IV of
Exhibit MJ-l.
13. The Pole Inspection - Distribution Program will continue FPL's existing
Commission-approved distribution pole inspection program, which is an eight-year pole
inspection cycle for all distribution poles that targets approximately 1/8 of the system annually
(theactualnumberofpolesinspected canvary somewhatfromyeartoyear). Withapproximately
1.2 million distribution poles as of year-end 2019, FPL expects to inspect approximately 150,000
poles annually. The estimated 2020-2029 annual average cost for the Pole Inspection -
Distribution Program is approximately $61 million per year, which is consistent with historical
5
costs for the existing distribution pole inspection program.a A detailed description of the Pole
Inspection - Distribution Program is provided in Section IV(A) of Exhibit MJ-1.
14. The Structures/Other Equipment Inspections - Transmission Program will continue
FPL's current Commission-approved transmission inspection program which requires: (a)
transmission circuits and substations and all associated hardware to be inspected on a six-year
cycle; (b) wood structures to be visually inspected from the ground on an annual basis and climbing
or bucket truck inspections to be conducted on a six-year cycle; and (c) steel and concrete
structures to be visually inspected on an annual basis and climbing or bucket truck inspections to
be conducted on a ten-year cycle. FPL expects to inspect approximately 68,000 transmission
structures annually. The estimated 2020-2029 annual average cost for the Structures/Other
Equipment Inspections - Transmission Program is approximately $50 million per year, which is
consistent with historical costs for the existing transmission inspection program.s A detailed
description of the Structures/Other Equipment Inspections - Transmission Program is provided in
Section IV(B) of Exhibit MJ-1.
15. The Feeder Hardening (EWL) - Distribution Program will continue FPL's existing
Commission*approved approach to harden existing feeders and certain critical distribution poles,
as well as FPL's initiative to design and construct new pole lines and major planned work to meet
the extreme wind loading ("EWL") criteria set forth in the National Electric Safety Code. FPL
a Note, the2020-2029 program costs shown above are projected costs estimated as of the time of this filing.
Subsequent projected and actual costs could vary by as much as l}ohto l5o/o. The annual projected costs,
actual/estimated costs, actuals costs, and true-up of actual costs to be included in FPL's Storm Protection
Plan Cost Recovery Clause will all be addressed in subsequent and separate Storm Protection Plan Cost
Recovery Clause filings pursuant to Rule 25-6.031, F.A.C. The Commission has opened Docket No.
20200092-EI to address Storm Protection Plan Cost Recovery Clause petitions to be filed the third quarter
of2020.
5 ,See footnote 4.
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expects to harden approximately 280-350 feeders annually, with 100% of FPL's feeders expected
to be hardened or underground by year-end 2024 and with the final costs of the program to be
incurred in 2025. The estimated average annual cost for the Feeder Hardening (EWL) -
Distribution Program to be incurred over the period of 2020-2025 is approximately $534 million
per year, which is consistent with historical costs for the existing distribution feeder hardening
program.6 A detailed description of the Feeder Hardening (EWL) - Distribution Program is
provided in Section IV(C) of Exhibit MJ-1.
16. The Lateral Hardening (Undergrounding) - Distribution Program includes
completing FPL's existing three-year Storm Secure Underground Program Pilot ("SSUP Pilot") in
2020 and expanding the application of the SSUP to the implementation of the system-wide Lateral
Hardening (Undergrounding) - Distribution Program for the period of 2021-2029. The SSUP Pilot
is a program that targets certain overhead laterals that were impacted by recent storms and have a
history ofvegetation-related outages and other reliability issues for conversion from overhead to
underground. As part of its SPP, FPL will incorporate, continue, and expand the SSUP during the
ten-year SPP period to provide the benefits of underground lateral hardening throughout its system.
After completing the SSUP Pilot in 2020,FPL estimates that it will convert approximately 300-
700 laterals annually in2021-2023 and approximately 800-900 laterals annually in2024-2029.
The estimated 2020-2029 annual average cost for the Lateral Hardening (Undergrounding) -
Distribution Program is approximately $510 million per year.7 A detailed description of the
Lateral Hardening (Undergrounding) - Distribution Program is provided in Section fV@) of
Exhibit MJ-l.
6 See footnote 4
7 See footnote 4
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17. The Wood Structures Hardening (Replacing) - Transmission Program is a
continuation of FPL's existing transmission hardening program to replace all wood transmission
structures with steel or concrete structures. As of year-end 2019, 96% of FPL's transmission
structures, system-wide, were steel or concrete, with less than 2,900 (or 4%) wood structures
remaining to be replaced. FPL expects to replace the 2,900 wood transmission structures
remaining on its system by year-end2022. The estimated2020-2022 annual average cost for the
Wood Structure Hardening (Replacing) - Transmission Program is approximately $39 million per
year, which is a decrease from the historical costs for the existing transmission hardening
program.s A detailed description of the Wood Structure Hardening (Replacing) - Transmission
Program is provided in Section IV(E) of Exhibit MJ-1.
18. The Substation Storm Surge/Flood Mitigation Program is the only new storm
hardening program that FPL proposes to implement as part of its SPP. The Substation Storm
Surge/Flood Mitigation Program will implement measures to protect certain T&D substations and
equipment that are susceptible to storm surge or flooding due to extreme weather events.
Specifically, FPL will raise the equipment at certain substations above the flood level and construct
flood protection walls around other substations that arc susceptible to storm surge or flooding
during extreme weather events. The Storm Surge/Flood Mitigation - Transmission and
Distribution Program will reduce customer outages due to flooding and the need to de-energize
substations that are impacted by storm surge or flooding, as well as reduce flood damage and
restoration costs at these targeted substations. At this time, FPL has identified between 8-10
substations where it initially plans to implement storm surge/flood mitigation measures over the
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next three years (2020-2022). The estimated 2020-2022 annual average cost for the new
Substation Storm SurgeiFlood Mitigation Program is approximately $8 million per year.e A
detailed description of the Substation Storm Surge/Flood Mitigation Program is provided in
Section IV(F) of Exhibit MJ-1.
19. The Vegetation Management - Distribution Program is a continuation of FPL's
existing, Commission-approved distribution vegetation management program. FPL's currently
approved distribution vegetation program, includes the following system-wide vegetation
inspection and management activities: three-year cycle for feeders; mid-year cycle targeted
trimming for certain feeders; six-year cycle for laterals; and continued education of customers
through its Right Tree, Right Place initiative. FPL plans to inspect and maintain, on average,
approximately 15,200 miles annually, which is consistent with the historic miles inspected and
trimmed annually. The estimated2020-2029 average annual cost for the Vegetation Management
- Distribution Program is approximately $60 million per year, which is consistent with historical
costs for the existing distribution vegetation management program.l0 A detailed description of the
Vegetation Management - Distribution Program is provided in Section IV(G)of Exhibit MJ-1.
20. The Vegetation Management - Transmission Program is a continuation of FPL's
existing transmission vegetation management program, which includes visual and aerial
inspections of all transmission line conidors, LiDAR inspections of North American Electric
Reliability Corporation transmission line corridors, developing and executing annual work plans
to address identified vegetation conditions, and identifying and addressing priority andhazardtree
conditions prior to and during storm season. FPL plans to inspect and trim, on average,
e See footnote 4.
10 See footnote 4.
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approximately 7,000 miles of transmission lines annually, which is consistent with the historic
miles inspected and trimmed annually. The estimated 2020-2029 averuge annual cost for the
Vegetation Management - Transmission Program is approximately $10 million per year, which is
consistent with historical costs for the existing transmission vegetation management program.ll A
detailed description of the Vegetation Management - Transmission Program is provided in Section
IV(H) of Exhibit MJ-1.
B. Additional Details for First Three Years of the SPP
21. The following additional project level information required by Rule 25-
6.030(3)(e)(1), F.A.C., for the first year of the SPP (2020) is provided in Appendix E to Exhibit
MJ-l: (a) the actual or estimated construction start and completion dates; (b) a description of the
affected existing facilities, including number and type(s) of customers served, historic service
reliability performance during extreme weather conditions, and how this data was used to prioritize
the storm protection project; and (c) a cost estimate including capital and operating expenses. A
description of the criteria used to select and prioritize storm protection projects is included in the
description of each SPP program provided in Section IV of Exhibit MJ-i.
22. Pursuant to Rule 25-6.030(3)(eX2), F.A.C., FPL has also provided the estimated
number and costs of projects under each specific program for the second and third years (2027-
2022) of the SPP. This information is provided in Appendix C to Exhibit MJ-l.
23. The following additional information required by Rule 25-6.030(3)(f), F.A.C., for
the first three years (2020-2022) of the vegetation management activities under the SPP is provided
in Sections IV(G) and IV(H) of Exhibit MJ-l and Appendix C to Exhibit MJ-l: (a) the projected
frequency (trim cycle); (b) the projected miles of affected transmission and distribution overhead
ll See footnote 4.
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facilities; and (c) the estimated annual labor and equipment costs for both utility and contractor
personnel. Descriptions of how the vegetation management activities will reduce outage times
and restoration costs due to extreme weather conditions are provided in Sections IV(G) and IV(H)
of Exhibit MJ-1.
C. Estimated Revenue Requirements and Rate Impacts
24. Pursuant to Rule 25-6.030(3)(9), F.A.C., the estimated annual jurisdictional
revenue requirements of FPL's SPP for the ten-year period of 2020-2029 are provided in Section
VI of Exhibit MJ-1. While FPL has provided estimated costs by program as of the time of this
filing and associated total revenue requirements in its SPP, consistent with the requirements of
Rule 25-6.030, F.A.C., subsequent projected and actual program costs submitted for cost recovery
through the Storm Protection Plan Cost Recovery Clause (per Rule 25-6.031, F.A.C.,) could vary
by as much as 10-l5o/o, which variations would also impact the associated estimated revenue
requirements and rate impacts.
25. FPL anticipates the programs included in the SPP will have zero bill impacts on
customer bills during the first year of the SPP and only minimal bill increases for years two and
three of the SPP. An estimate of hypothetical overall rate impacts forthe firstthree years of the
SPP (2020-2022) based on the total program costs reflected in this filing, without regard for the
fact that FPL remains under a general base rate freeze pursuant to a Commission-approved
settlement agreement through December 37, 2021, are provided in Section VII of Exhibit MJ-l.
The annual jurisdictional revenue requirements and the estimated rate impacts are based on the
total estimated costs, as of the time of this filing, for all programs included in the SPP regardless
of whether those costs will be recovered in FPL's Storm Protection Plan Cost Recovery Clause or
through base rates. In addition, under FPL's Commission-approved rate case settlement
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agreement, any incremental base rate adjustment may not take place until FPL's base rates are
established by the Commission in FPL's next base rate proceeding."
26. FPL is not seeking Commission approval, through this petition, to recover any of
the estimated costs associated with the SPP in this filing. The projected costs, actual/estimated
costs, actual costs, and true-up of actual costs to be included in FPL's Storm Protection Plan Cost
Recovery Clause, including whether these costs are included in current base rates, will all be
addressed in subsequent and separate Storm Protection Plan Cost Recovery Clause filings pursuant
to Rule 25-6.031, F.A.C. The Commission has opened Docket No. 202000gz-Elto address Storm
Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
D. FPL's SPP is in the Public Interest and Should Be Approved
27. Sections 366.96(4)-(5), F.S., provide that the Commission shall review each
utility's SPP and, within 180 days from filing, determine whetherthe SPP is inthepublic interest.13
28. As explained above, the programs included in the SPP are largely a continuation
and expansion ofFPL's already successful and ongoing storm hardening and storm preparedness
programs previously approved by the Commission, as well as a new storm hardening program to
t2 See In re: Petitionfor rate increase by Florida Power & Light Company, Docket No. 160021-EI, Order
No. PSC-16-0560-AS-EI (Fla. PSC Dec. 15, 2016).
13 In reaching this determination, the Florida Legislature has directed the Commission to consider the
following:
(a) The extent to which the plan is expected to reduce restoration costs and outage times associated with
extreme weather events and enhance reliability, including whether the plan prioritizes areas of lower
reliability performance.
(b) The extent to which storm protection of transmission and distribution infrastructure is feasible,
reasonable, or practical in certain areas of the utility's service territory, including, but not limited to,
flood zones and rural areas.
(c) The estimated costs and benefits to the utility and its customers of making the improvements
proposed in the plan.
(d) The estimated annual rate impact resulting from implementation of the plan during the first 3 years
addressed in the plan.
See Section 366.96(4), F.S.
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protect T&D substations and equipment from storm surge and flooding due to extreme weather
events. These SPP programs will continue to provide increased T&D infrastructure resiliency,
reduced restoration times, and reduced restoration costs when FPL's system is impacted by
extreme weather events.
29. In DocketNo.20170215-EU, the Commission reviewed the electric utilities' storm
hardening and storm preparedness programs and found the following:
Florida's aggressive storm hardening programs are working;
The length of outages was reduced markedly from the 2004-2005 storm
season;
Hardened overhead distribution facilities performed better than non-
hardened facilities;
Underground facilities performed much better compared to overhead
facilities; and
The primary causes ofpower outages came from outside the utilities' rights-
of-way including falling trees, displaced vegetation, and other debris.
See Review of Florida's Electric Utility Hurricane Preparedness and Restoration Actions 2018,
Docket No. 201 7021 5-EU (July 24,20 1 8).14
30. The estimate of cumulative reductions in restoration costs and outage times
associated with the SPP will be directly affected by how frequently storms hit FPL's service
territory. Of course, no one is in a position to know for sure how frequently FPL's service territory
will be impacted by strong hunicanes. However, consistent with historical results, FPL expects
that the storm hardening and storm preparedness programs included in its SPP will result in a
reduction in storm as well as non-storm (day-to-day) restoration costs. See FPL's Third
Supplemental Response to Staffls First Data Request No. 29 ("Third Supplemental Amended") in
ta Available athttp:llwww.psc.state.fl.usllibrarylfilingsl2}l8l04847-2018104847-2018.pdf.
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Docket No. 20170215-EI, which is provided as Appendix A to Exhibit MJ-1.
31. FPL's storm hardening and storm preparedness programs have also provided and
will continue to provide increased levels of day-to-day reliability. For example, FPL has
previously submitted reports to the Commission that show hardened feeders have performed
approximately 40Yo better (i.e., fewer outages) on a day-to-day basis than non-hardened feeders.
32. A detailed summary of the benefits of FPL's SPP is provided in Section II of
Exhibit MJ-I, and the benefits and costs associated with each program is provided in Section IV
of Exhibit MJ-1.
33. FPL's SPP meets the objectives of Section 366.96, F.S., satisfies the requirements
of Rule 25-6.030, F.A.C., is in the public interest, and should be approved.
IV CONCLUSION
34. As explained above and in further detail in Exhibit MJ-l and the supporting Direct
Testimony of FPL witness Michael Jarro, FPL's SPP provides a systematic approach to achieve
the legislative objectives of reducing restoration costs and outage times associated with extreme
weather events and enhancing reliability. FPL's SPP appropriately and effectively maintains and
builds on FPL's commitment to provide safe and reliable electric service to customers, consistent
with our customers' needs and expectations .
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WHEREFORE, FPL respectfully requests that the Commission find FPL's proposed SPP,
provided as Exhibit MJ-l, is in the public interest and approve the SPP for the years2020-2029.
Respectfully submitted this 1Oth day of April,2020,
John T. Burnett
Vice President and Deputy General Counsel
Christopher T. Wright
Senior Attorney
Florida Power & Light Company
700 Universe Boulevard
Juno Beach, FL 33408-0420
Phone: 561-691-7144
Fax: 561-691-7135
Email : j ohn.t.burnett@fpl.com
Email: christopher.wright@fpl.com
By:s/Christopher T. Wrisht
Christopher T. Wright
Fla. Auth. House Counsel No. 1007055
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CERTIFICATE OF' SERVICE
I HEREBY CERTIFY that a true and correct copy of Florida Power & Light Company's
Petition for Approval of the 2020-2029 Storm Protection Plan in Docket No. 2020007t-EI, along
with the Direct Testimony of Michael Jaro and Exhibit MJ-l, has been furnished by Electronic
Mail to the following parties of record this 1Oth day of April,2020:
s/ Christopher T. Wrisht
Christopher T. Wright
Fla. Auth. House Counsel No. 1007055
Fla. Auth. House Counsel No. 1017875
Florida Power &Light Company
700 Universe Boulevard (JB/LAW)
Juno Beach, Florida 33408
Attorneyfor Florida Power & Light Company
Charles Murphy, Esquire
Rachael D zie chciarz, Esquire
Florida Public Service Commission
2540 Shumard Oak Boulevard
Tallahassee,FL 32399
rdziechc@psc.state. fl .us
cmurphy@nsc.state.fl .us
Office of Public Counsel
J.R.Kelly
Patricia A. Christensen
c/o The Florida Legislature
111 West Madison Street, Room 812
Tallahassee, FL 32399 -7 400
kellyjr@.le g.state.fl .us
christensen.patty@ le g. state.fl .us
BEFORE THE FLORIDA PUBLIC SERYICE COMMISSION
FLORIDA POWER & LIGHT COMPANY
2020-2029 STORM PROTECTION PLAII
DOCKET NO. 202000071-Er
DIRECT TESTIMONY OF
MICHAEL JARRO
APRrL 10,2020
TABLE OF CONTENTS
I. INTRODUCTION .3
UI. DESCRIPTION OF'EACH SPP PROGRAM.......... ................7
IV. ADDITIONAL DETAILS FOR FIRST THREE YEARS OF'THE SPP....................16
EXHIBIT MJ-l - FPL's 2020-2029 Storm Protection PIan
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I. INTRODUCTION
Please state your name and business address.
My name is Michael Jarro. My business address is Florida Power & Light Company, 15430
Endeavor Drive, Jupiter, FL, 3347 8.
By whom are you employed and what is your position?
I am employed by Florida Power & Light Company ("FPL" or the "Company") as the Vice
President of Distribution Operations.
Please describe your duties and responsibilities in that position.
My curent responsibilities include the operation and maintenance of FPL's approximately
68,000 miles of distribution infrastructure, including 42,000 miles of overhead and 26,000
miles of underground, that safely, reliably, and efficiently deliver electricity to more than five
million customers in FPL's service temitory covering approximately 28,000 square miles. I am
responsible for the oversight of more than 1,600 employees in a control center and sixteen
management areas. The functions and operations within my area are quite diverse and include
distribution operations, major projects and construction services, power quality, meteorology,
and other operations that together help provide the highest level of service to FPL's customers.
Please describe your educational background and professional experience.
I graduated from the University of Miami with a Bachelor of Science Degree in Mechanical
Engineering and Florida International University with a Master of Business Administration. I
joined FPL in 1997 and have held several leadership positions in distribution operations and
customer service, including serving as distribution reliability manager, manager of distribution
operations for south Miami-Dade area, control center general manager, director of network
operations, senior director ofcustomer strategy and analytics, senior director ofpower delivery
central maintenance and construction, and vice-president of transmission and substations.
What is the purpose of your direct testimony?
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The purpose of my testimony is to present and provide an overview of FPL's proposed 2020-
2029 Storm Protection Plan ("SPP" or "the Plan"), which is attached to my direct testimony as
Exhibit MJ-l, and demonstrate that FPL's SPP is in compliance with Section 366.96, Florida
Statutes ("F.S.") and Rule 25-6.030, Florida Administrative Code ("F.A.C."). I will provide a
description ofeach storm protection program included in FPL's SPP and how it is expected to
reduce restoration costs and outage times. I will also describe the estimated start/completion
dates, estimated costs, and criteria used to select and prioritize the projects in each program.
Finally, I will describe the additional detail provided for the first three years of FPL's SPP
pursuant to Rule 25-6.030(3)(e)-(f), (h), and (i), F.A.C.
Are you sponsoring any exhibits in this case?
Yes. I am sponsoring Exhibit MJ-l - FPL's Storm Protection Plan 2020-2029.
II. OVERVIEW OF FPL'S SPP
What is the purpose of FPL's SPP?
On June 27,2079, the Governor of Florida signed into law the Storm Protection Plan Cost
Recovery legislation, which was codified in Section 366.96, F.S. As part of the new law, the
Florida Legislature expressly found that it is in the State's interest: (a) "to strengthen electric
utility infrastructure to withstand extreme weather conditions by promoting the overhead
hardening of electrical transmission and distribution facilities, the undergrounding of certain
electrical distribution lines, and vegetation management;" and (b) oofor each electric utility to
mitigate restoration costs and outage times to utility customers when developing transmission
and distribution storm protection plans." ,9ee Sections 366.96(1)(c)-(d), F.S. Based on these
findings, the Florida Legislature directed each electric utility to file a SPP with the Florida
Public Service Commission ("Commission") covering the immediate ten (10) year planning
period. See Section 366.96(3), F.S. Consistent with this legislative requirement, FPL is
submitting its SPP for the ten-year period of 2020-2029.
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FPL's SPP is a systematic approach to achieve the legislative objectives of reducing restoration
costs and outage times associated with extreme weather events and enhancing reliability. As
required by Rule 25-6.030, F.A.C., FPL's SPP includes, among other things, a description of
each proposed storm protection program, including: (a) how each program will enhance the
existing system to reduce restoration costs and outage times; (b) applicable start and completion
dates for each program; (c) a cost estimate for each program; (d) a comparison of the costs and
benefits for each program; and (e) a description ofhow each program is prioritized. The SPP
also provides an estimate of the annual jurisdictional revenue requirement for each year of the
SPP and additional details on each program for the first three years ofthe SPP (2020-2022),
including estimated rate impacts.
What programs are included in FPL's SPP?
FPL's SPP is, in large part, a continuation and expansion of its previously approved storm
hardening and storm preparedness programs, and includes the following SPP programs:
o Pole Inspections - Distribution Program
o Structures/Other Equipment Inspections - Transmission Program
r Feeder Hardening - Distribution Program
o Lateral Hardening (Undergrounding) - Distribution Program
. Wood Structures Hardening (Replacing) - Transmission Program
. Vegetation Management - Distribution Program
r Vegetation Management - Transmission Program
In addition, FPL proposes to implement a new Substation Storm Surge/Flood Mitigation
Program to protect T&D substations and equipment that are susceptible to storm surge or
flooding during extreme weather events.
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With the exception of the new storm surge/flood mitigation program, the majority of these
programs have been in place since 2007. As demonstrated by recent storm events, these
programs have been successful in reducing restoration costs and outage times following major
storms, as well as improving dayto-day reliability. FPL submits that continuing these
previously approved storm hardening and storm preparedness programs in the SPP, together
with the new storm surge/flood mitigation program, is appropriate and necessary to meet the
requirements of Section 366.96, F.S., and Rule 25-6.030, F.A.C. These programs will address
the expectations of FPL's customers and other stakeholders for increased storm resiliency, and
will result in fewer outages, reduced restoration costs, and prompt service restoration. The SPP
will continue and expand the benefits of hardening, including improved day-to-day reliability,
to all customers throughout FPL's system.
Please provide an overyiew of the benefits of FPL's SPP.
The major benefit of FPL's SPP is to provide increased resiliency and faster restoration to the
electric infrastructure that FPL's five million customers and Florida's economy rely on for their
electricity needs. Safe and reliable electric service is essential to the life, health, and safety of
the public, and has become a critical component of modern life. Florida remains the most
hurricane-prone state inthe nation and, with the significant coast-line exposure of FPL's system
and the fact that the vast majority of FPL's customers live within 20 miles of the coast, a robust
storm protection plan is critical to maintaining and improving grid resiliency and storm
restoration as contemplated by the Legislature in Section 366.96.
FPL's SPP programs have already demonstrated that they have provided and will continue to
provide increased Transmission and Distribution ("T&D") infrastructure resiliency, reduced
restoration time, and reduced restoration cost when FPL is impacted by extreme weather
events. FPL performed an analysis of Huricanes Matthew and Irma that indicated the
restoration construction man-hours ("CMH"), days to restore, and storm restoration costs for
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these storms would have been significantly greater without FPL's storm hardening programs.
In the case of Hurricane Matthew, FPL estimated that without hardening, restoration would
have taken two additional days (50% longer), and resulted in additional restoration costs of
$i05 million (36%higher than actual costs). In the case of Hurricane Irma, FPL estimated that
without hardening, restoration would have taken four additional days (40% longer), and
resulted in additional restoration costs of$496 million (40% higherthan actual costs). A copy
of FPL's analysis is provided in Appendix A to Exhibit MJ-l.
A detailed summary of the benefits of FPL's SPP is provided in Section II of the SPP, and the
benefits ofeach program are provided in Section IV ofthe SPP.
Does FPL's SPP address recovery of the costs associated with the SPP?
No. FPL anticipates the programs included in the SPP will have zero bill impacts on customer
bills during the first year of the SPP and only minimal bill increases for years two and three of
the SPP. However, the recovery of the actual costs associated with the SPP, as well as the costs
to be included in FPL's Storm Protection Plan Cost Recovery Clause, will be addressed in
subsequent and separate Storm Protection Plan Cost Recovery Clause dockets pursuant to Rule
25-6.031, F.A.C. The Commission has opened Docket No. 20200092-EI to address Storm
Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
III. DASCRIPTION OF EACH SPPPROGRAM
Has FPL provided the information required by Rule 25-6.030(3Xd) for each program
included in its SPP?
Yes. FPL's SPP provides the information required by the Rule 25-6.030(3Xd) for each
program. If applicable, each program description included in FPL's SPP includes: (l) a
description of how each program is designed to enhance FPL's existing transmission and
distribution facilities including an estimate of the resulting reduction in outage times and
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restoration costs due to extreme weather conditions; (2) identification of the actual or estimated
start and completion dates of the program; (3) a cost estimate including capital and operating
expenses; (4) a comparison ofthe costs and the benefits; and (5) a description ofthe criteria
used to select and prioritize proposed storm protection programs. Each of the above listed
descriptions is provided in Section IV of FPL's SPP. Below, I will provide a brief overview
of each program included in FPL's SPP.
Please provide a summary of FPL's Pole Inspection - Distribution Program included in
the SPP.
The Pole Inspection - Distribution Program included in the SPP is a continuation of FPL's
existing Commission-approved distribution pole inspection program. FPL's existing,
Commission-approved distribution pole inspection program is an eight-year pole inspection
cycle for all distribution poles that targets approximately 1/8 of the system annually (the actual
number of poles inspected can vary somewhat from year to year). To ensure inspection
coverage throughout its service territory, FPL established nine inspection zones (based on
FPL's management areas and pole population) and annually performs pole inspections of
approximately 1/8 of the distributionpoles in each of these zones, as well as any necessary
remediation as a result of such inspections. As explained in the SPP, recent storm events
demonstrate that FPL's existing distribution pole inspection program has contributed to the
overall improvement in distribution pole performance during storms, resulting in reductions in
storm damage to poles, days to restore, and storm restoration costs.
With approximately 1.2 million distribution poles as of year-end 2019, FPL expects to inspect
approximately 150,000 poles annually (spread throughout its nine inspection zones) during the
2020-2029 SPP period. The total estimated costs for the Pole Inspection - Distribution
Program for the ten-year period of 2020-2029 is $605 million with an annual average cost of
approximately $61 million, which is consistent with historical costs for the existing distribution
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pole inspection program.l A detailed description of the Pole Inspection - Distribution Program
is provided in Section IV(A) of FPL's SPP.
Please provide a summary of FPL's Structures/Other Equipment Inspections -
Transmission Program included in the SPP.
The Structures/Other Equipment Inspections - Transmission Program included in the SPP is a
continuation of FPL's existing Commission-approved transmission inspection program. The
SPP will continue FPL's current, Commission-approved transmission inspection program
which requires: (a) transmission circuits and substations and all associated hardware to be
inspected on a six-year cycle; (b) wood structures to be inspected visually from the ground on
an annual basis and climbing or bucket truck inspections to be conducted on a six-year cycle;
and (c) steel and concrete structures to be inspected visually on an annual basis and climbing
or bucket truck inspections to be conducted on a ten-year cycle. As explained in the SPP, the
performance of FPL's transmission facilities during recent storm events indicates FPL's
transmission inspection program has contributed to the overall storm resiliency of the
transmission system and provided savings in storm restoration costs.
FPL expects to inspect approximately 68,000 structures annually during Ihe 2020-2029 SPP
period. The total estimated costs for the Structures/Other Equipment Inspections -
Transmission Program for the ten-year period of 2020-2029 is $500 million with an annual
average cost of approximately $50 million, which is consistent with historical costs for the
lNote, the2020-2029 program costs shown above are projected costs estimated as of the time of this filing.
Subsequent projected and actual costs could vary by as much as l0%o to l5Yo. The annual projected costs,
actual/estimated costs, actuals costs, and true-up ofactual costs to be included in FPL's Storm Protection Plan
Cost Recovery Clause will all be addressed in subsequent and separate Storm Protection Plan Cost Recovery
Clause filings pursuant to Rule 25-6.031., F.A.C. The Commission has opened Docket No. 20200092-EIIo
address Storm Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
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existing transmission inspection program.2 A detailed description of the Structures/Other
Equipment Inspections - Transmission Program is provided in Section IV(B) of FPL's SPP.
Please provide a summary of FPL's Feeder Hardening (EWL) - Distribution Program
included in the SPP.
The Feeder Hardening (EWL) - Distribution Program included in the SPP is a continuation of
FPL's existing Commission-approved approach to harden existing feeders and certain critical
distribution poles, as well as FPL's initiative to design and construct new pole lines and major
planned work to meet the National Electrical Safety Code's ("NESC") extreme wind loading
criteria ("EWL"). During the period 2006-2019, FPL hardened over 1,300 existing feeders, the
vast majority being Critical Infrastructure Function ("ClF") feeders (i.e., feeders that serve
hospitals, 911 centers, police and fire stations, water treatment facilities, county emergency
operation centers) and Community Project feeders (i.e., feeders that serve other key community
needs like gas stations, grocery stores and pharmacies) throughout FPL's service teritory.
Additional feeders were hardened as a result of FPL's Priority Feeder Initiative, a reliability
program that targeted feeders experiencing the highest number of interruptions and/or customers
intenupted. FPL also applied EWL to the design and construction of new pole lines and major
planned work, including pole line extensions and relocations and certain pole replacements.
As provided in previous FPL Annual Reliability Report filings and three-year Storm Hardening
Plan filings (per Rule 25-6.0342, F.A.C.), hardened feeders perform better than non-hardened
feeders, both in day-to-day reliability performance and during severe storms. Additionally, upon
review of the electric utilities' storm hardening and storm preparedness programs, the
Commission found that for Hurricane Irma, hardened feeders performed significantly better than
2,See footnote 1
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non-hardened feeders with respect to outage rates, pole failures, and CMH required to restore
power
FPL expects to harden approximately 250-350 feeders annually, with 100% of FPL's feeders
expected to be hardened or underground by year-end 2024 and with the final costs of the
program to be incurred in2025. The total estimated costs for the Feeder Hardening (EWL) -
Distribution Program for the period of 2020-2025 is $3,206 million with an annual average cost
of approximately $534 million, which is consistent with historical costs for the existing
distribution feeder hardening program.a A detailed description of the Feeder Hardening (EM-)
- Distribution Program is provided in Section IV(C) of FPL's SPP.
Please provide a summary of FPL's Lateral Hardening (Undergrounding) - Distribution
Program included in the SPP.
The Lateral Hardening (Undergrounding) - Distribution Program included in the SPP is a
continuation and expansion ofFPL's existing three-year Storm Secure Underground Program
Pilot ("SSUP Pilot") implemented in 2018. The SSUP Pilot is a program that targets certain
overhead laterals that were impacted by recent storms and have a history of vegetation-related
outages and other reliability issues for conversion from overhead to underground. As part of its
proposed SPP, FPL will complete its existingthree-year SSIIP Pilot in2020 and expandthe
application of the SSUP during 2021-2029 to the implementation of the system-wide Lateral
Hardening (Undergrounding) - Distribution Program to provide the benefits of underground
lateral hardening throughout its system. As explained in the SPP, the proposal to continue and
expand the application of the SSUP under the SPP is based on the performance of the
3 See Review of Florida's Electric Utility Hurricane Preparedness and Restoration Actions 2018, Docket No.
2017 0215 -EU (J uly 24, 201 8).
4 See footnote 1.
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underground facilities as compared to overhead facilities and the extensive damage to the
overhead facilities caused by vegetation during Hurricanes Matthew and Irma.
By the end of 2020, the third and final year of the SSUP Pilot, FPL expects to have converted
a total of 220-230laterals from overhead to underground, which is consistent with the SSUP
Pilot plan most recently approved in July 20L9 in FPL's most recent storm hardening plan
docket, Docket No. 20180144-EI. After completing the SSTIP Pilot in 2020,FPL estimates
that it will convert approximately 300-700 laterals annually in202l-2023 and approximately
800-900 laterals annually in2024-2029. The total estimated costs for the Lateral Hardening
(Undergrounding) - Distribution Program for the ten-year period of 2020-2029 is $5,101
million with an annual average cost of approximately $510 million.5 A detailed description of
the Lateral Hardening (Undergrounding) - Distribution Program is provided in Section IV(D)
of FPL's SPP.
Please provide a summary of FPL's Wood Structures Hardening (Replacing) -
Transmission Program included in the SPP.
The Wood Structure Hardening (Replacing) - Transmission Program included in the SPP is a
continuation of FPL's existing transmission hardening program to replace all wood transmission
structures with steel or concrete structures. As explained in the SPP, the performance of FPL's
transmission facilities during recent storm events indicates FPL's transmission hardening
program has contributed to the overall storm resiliency ofthe transmission system and provided
savings in storm restoration costs.
As of year-end 2019, 960A of FPL's transmission structures, system-wide, were steel or
concrete, with less than2,900 (or 4%:o) wood structures remaining to be replaced. FPL expects
5 See footnote I
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to replace the 2,900 wood transmission structures remaining on its system by year-end 2022.
The total estimated costs for the Wood Structure Hardening (Replacing) - Transmission
Program for the period of 2020-2022 is $118 million with an annual average cost of
approximately $39 million, which is a decrease from the historical costs for the existing
transmission hardening program.6 A detailed description of the Wood Structure Hardening
(Replacing) - Transmission Program is provided in Section IV(E) of FPL's SPP.
Please provide a summary of FPL's Substation Storm Surge/Flood Mitigation Program.
The Substation Storm Surge/Flood Mitigation Program is the only new storm hardening
program that FPL proposes to implement as part of its SPP. The Storm Surge/Flood Mitigation
- Transmission and Distribution Program will implement measures to protect T&D substations
and equipment that are susceptible to storm surge or flooding due to extreme weather events.
Historically, several FPL distribution and transmission substations have been impacted by
storm surge and/or flooding as a result of extreme weather conditions. While proactively de-
energizing those substations impacted by storm surge and/or flooding helps reduce damage to
substation equipment, FPL is still required to implement both temporary flood mitigation
efforts and repairs to substation facilities and equipment that become flooded as a result of
extreme weather conditions. Further, flooding and the need to proactively de-energize
substations located in areas susceptible to storm surge and flooding can result in significant
customer outages. To prevent/mitigate future substation equipment damage and customer
outages due to storm surge and flooding, FPL's new Storm Surge/Flood Mitigation Program
will raise the equipment at certain substations above the flood level and construct flood
protection walls around other substations to prevent/mitigate future damage due to storm surge
and flooding.
6,See footnote I
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At this time, FPL has identified between 8-10 substations where it initially plans to implement
storm surge/flood mitigation measures over the next three years (2020-2022). The total
estimated costs for the new Substation Storm Surge/Flood Mitigation over this three-year
period is approximately $23 million with an annual average cost of approximately $8 million
per year.1 A detailed description of the Storm Surge/Flood Mitigation - Transmission and
Distribution Program is provided in Section IV(F) of FPL's SPP.
Please provide a summary of FPL's Vegetation Management - Distribution Program
included in the SPP.
The Vegetation Management - Distribution Program included in the SPP is a continuation of
FPL's existing, Commission-approved distribution vegetation management program. FPL's
cunently-approved distribution vegetation program, includes the following system-wide
vegetation management activities: three-year cycle for feeders; mid-year cycle targeted
trimming for certain feeders; six-year cycle for laterals; and continued education of customers
through its Right Tree, Right Place initiative. In approving FPL's current distribution vegetation
management cycles, the Commission indicated that FPL's distribution vegetation management
cycles were cost-effective and would provide savings to customers. Additionally, as explained
in the SPP, recent storm events demonstrate that FPL's existing distribution vegetation
management program has contributed to the overall improvement in the resiliency of
distribution system during storms, resulting in reductions in storm damage to poles, days to
restore, and storm restoration costs.
Under the SPP, FPL plans to trim, on average, approximately 15,200 miles annually, including
approximately 11,400 miles for feeders (cycle and mid-cycle) and 3,800 miles for laterals,
which is consistent with the historic miles trimmed annually. The total estimated costs for the
7 See footnote I
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Vegetation Management - Distribution Program for the ten-year period of 2020-2029 is $596
million with an annual average cost of approximately $60 million, which is consistent with
historical costs for the existing distribution vegetation management program.8 A detailed
description of the Vegetation Management- Distribution Program is provided in Section IV(G)
of FPL's SPP.
Please provide a summary of FPL's Vegetation Management - Transmission Program
included in the SPP.
The Vegetation Management - Transmission Program included in the SPP is a continuation of
FPL's existing transmission vegetation management program. The key elements of FPL's
transmission vegetation management program are to inspect the transmission right-of-ways,
document vegetation inspection results and findings, prescribe a work plan, and execute the
work plan. In its SPP, FPL will continue its current transmission vegetation management plan,
which includes visual and aerial inspections of all transmission line corridors, Light Detection
and Ranging ("LiDAR") inspections of North American Electric Reliability Corporation's
("NERC") transmission line corridors, developing and executing annual work plans to address
identified vegetation conditions, and identiffing and addressing priority and hazard tree
conditions prior to and during storm season. As explained in the SPP, the execution of FPL's
transmission vegetation management plan has been and is a significant factor in mitigating
damage to transmission facilities and avoiding transmission-related outages.
Under the SPP, FPL plans to inspect and maintain, on average, approximately 7,000 miles of
transmission lines annually, including approximately 4,300 miles for NERC transmission line
corridors and 2,700 miles for non-NERC transmission line corridors. This is comparable to
the approximately 7,000 miles inspected and maintained annually, on average for 2011-2019.
8 See footnote 1
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The total estimated costs for the Vegetation Management - Transmission Program for the ten-
year period of 2020-2029 is $96 million with an annual average cost of approximately $10
million, which is consistent with historical costs for the existing transmission vegetation
management program.e A detailed description of the Vegetation Management - Transmission
Program is provided in Section IV(H) of FPL's SPP.
IV. ADDITIONALDETAILS FORFIRST THREE YEARS OF THE SPP
Has FPL provided additional project-level details and information for the first year
Q020) of the SPP?
Yes. The following additional information required by Rule 25-6.030(3Xe)(1), F.A.C., for the
firstyear(2020)oftheSPPisprovidedinAppendixEtoFPL'sSPP: (1)theactualorestimated
construction start and completion dates; (2) a description of the affected existing facilities,
including number and type(s) of customers served, historic service reliability performance
during extreme weather conditions, and how this data was used to prioritize the proposed storm
protection project; and (3) a cost estimate including capital and operating expenses.
Additionally, a description ofthe criteria used to select and prioritize proposed storm protection
projects is included in the description ofeach proposed SPP program provided in Section IV
of the SPP.
Does FPL's SPP provide sufficient detail to develop preliminary estimates of the rate
impacts for the second and third years (2021-2022) of the SPP?
Yes. As required by Rule 25-6.030(3Xe)(2), F.A.C., FPL has provided the estimated number
and costs of projects under each specific SPP program, which information was used to develop
the estimated rate impacts for2027-2022. This information is provided in Appendix C to FPL's
SPP.
a.
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e See footnote I
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Did FPL provide a description of its vegetation management activities under the SPP for
the first three years (2020-2022) of the SPP?
Yes. The following additional information required by Rule 25-6.030(3X0, F.A.C., for the
first three years (2020-2022) of the vegetation management activities under the SPP is provided
in Sections IV(G) and IV(H) of FPL's SPP and Appendix C to FPL's SPP: the projected
frequency (trim cycle); the projected miles of affected transmission and distribution overhead
facilities; and the estimated annual labor and equipment costs for both utility and contractor
personnel. Additionally, descriptions of how the vegetation management activities will reduce
outage times and restoration costs due to extreme weather conditions are provided in Sections
IV(G) and IV(H) of FPL's SPP.
Has FPL provided the annual jurisdictional revenue requirements for the 2020-2029
SPP?
Yes. Pursuant to Rule 25-6.030(3Xg), F.A.C., FPL has provided the estimated annual
jurisdictional revenue requirements in Section VI of the SPP. While FPL has provided
estimated costs by program as of the time of this filing and associated total revenue
requirements in its SPP, consistent with the requirements of Rule 25-6.030, F.A.C., subsequent
projected and actual program costs submitted for cost recovery through the Storm Protection
Plan Cost Recovery Clause (per Rule 25-6.031, F.A.C.) could vary by as much as 10-15o/o,
which variations would also impact the associated estimated revenue requirements and rate
impacts. The projected costs, actuall estimated costs, actuals costs, and true-up ofactual costs
to be included in FPL's Storm Protection Plan Cost Recovery Clause will all be addressed in
subsequent filings in separate Storm Protection Plan Cost Recovery Clause dockets pursuant
to Rule 25-6.03 I,F.A.C. ro
Has FPL estimated the rate impacts for each of the first three years of the SPP?
o.
A.
10 The Commission has opened Docket No. 20200092-EIto address Storm Protection Plan Cost Recovery Clause
petitions to be filed the third quarter of 2020 .
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FPL anticipates the programs included in the SPP will have zero bill impacts on customer bills
during the first year of the SPP and only minimal bill increases for years two and three of the
SPP. An estimate of the hypothetical overall rate impacts for the first three years of the SPP
(2020-2022) based on the total program costs reflected in this filing, without regard for the fact
that FPL remains under a general base rate freeze pursuant to a Commission-approved
settlement agreement through December 3 1, 2021 , arc provided in Section VII of the SPP. The
projected costs, actual/estimated costs, actuals costs, and true-up ofactual costs to be included
in FPL's Storm Protection Plan Cost Recovery Clause will all be addressed in subsequent
filings in separate storm protection plan cost recovery clause dockets pursuant to Rule 25-
6.031, F.A.C.11
V. CONCLUSION
Does FPL believe that its SPP will achieve the legislative objectives of Section 366.96, F.S.,
to reduce costs and outage times associated with extreme weather events by promoting
the overhead hardening of electrical transmission and distribution facilities, the
undergrounding of certain electrical distribution linesn and vegetation management?
Yes. While no electrical system can be made completely resistant to the impacts of hunicanes
and other extreme weather conditions, FPL's SPP provides a systematic approach to achieve
the legislative objectives of reducing restoration costs and outage times associated with extreme
weather events and enhancing reliability. As explained above and in further detail in the SPP,
FPL's SPP programs are largely a continuation and expansion of FPL's already successful and
ongoing storm hardening and storm preparedness programs previously approved by the
Commission, as well as a new storm hardening program to protect T&D substations and
equipment from storm surge and flooding due to extreme weather events. These SPP programs
lrSee footnote 10.
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will continue to provide increased T&D infrastructure resiliency, reduced restoration time, and
reduced restoration costs when FPL's system is impacted by exheme weather events. FPL's
SPP appropriately and effectively maintains and builds on FPL's commitment to provide safe
and reliable electric service to customers, and to meet the needs and expectations of our
customers, today and for many years to come.
Does this conclude your direct testimony?
Yes.
l9
Docket No. 2O200O71-E\
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 1 of 48
Florida Power & Light Gompany
Storm Protection Plan
2020-2029
(Rule 25-6.030, F.A.C.)
Docket No. 20200071-El
April 10, 2020
TABLE OF GONTENTS
l. Executive Summary..
il The 2020-2029 SPP will Strengthen FPL's Infrastructure to
Withstand Extreme Weather Conditions and will Reduce
Restoration Costs and Outage Times....
Description of Service Area and T&D Facilities ..........
lV. 2020-2029 SPP Programs
A. Pole lnspections - Distribution Pro9ram.............
1. Description of the Program and Benefits............
2. Actual/Estimated Start and Completion Dates ...
B.
3. CostEstimates..........
4. Comparison of Costs and 8enefits.............
5. Criteria used to Select and Prioritize the Program
Structures/Other Equipment Inspections - Transmission
Program
1. Description of the Program and Benefits.............
2. Actual/Estimated Start and Completion Dates
3. CostEstimates..........
4. Comparison of Costs and Benefits
5. Criteria used to Select and Prioritize the Program
C. Feeder Hardening (EWL) - Distribution Program .............
1. Description of the Program and 8enefits.............
2. Actual/Estimated Start and Completion Dates
D
3. CostEstimates..........
4. Comparison of Costs and 8enefits.............
5. Criteria used to Select and Prioritize the Program .....
Lateral Hardening (Undergrounding) - Distribution Program
L Description of the Program and 8enefits....................
2. Actual/Estimated Start and Completion Dates
3. CostEstimates..........
4. Comparison of Costs and 8enefits.............
5. Criteria used to Select and Prioritize the Program .....
Docket No. 20200071-El
F PL's 2O20-2O29 Storm Protection Plan
Exhibit MJ-1, Page 2 of 48
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1
Docket No. 2O200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 3 of 48
E. Wood Structures Hardening (Replacing) - Transmission
Program
1. Description of the Program and 8enefits..............
2. Actual/Estimated Staft and Completion Dates .....
F
5. Criteria used to Select and Prioritize Projects
G. Vegetation Management - Distribution Program
L Description of the Program and Benefits.
2
3
4
5
H
3
4
5. Criteria used to Select and Prioritize the Programs..
Detailed lnformation on the First Three Years of the SPP (2020-
2022)
A. Detailed Description for the First Year of the SPP (2020)...
B. Detailed Description of the Second and Third Years of the
sPP (2021-2022)
C. Detailed Description of the Vegetation Management
Activities for the First Three Years of the SPP (2020-2022)
Estimate of Annual Jurisdictional Revenue Requirements for the
3. CostEstimates.........
4. Comparison of Costs and 8enefits.............
5. Criteria used to Select and Prioritize the Program
Substation Storm Surge/Flood Mitigation Program
1. Description of the Program and 8enefits..............
2. Actual/Estimated Start and Completion Dates .....
3. CostEstimates.........
4. Comparison of Costs and 8enefits.............
26
26
28
28
29
29
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..30
Actual/Estimated Start and Completion Dates ......
Cost Estimates .........
Comparison of Costs and Benefits.............
Criteria Used to Select and Prioritize the Program
Vegetation Management - Transmission Program
1. Description of the Program and 8enefits.............
2. Actual/Estimated Start and Completion Dates
Cost Estimates .........
Comparison of Costs and Benefits
...32
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31
31
32
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36
37
37
39
39
40
40
V
41
41
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42
vl.
2020-2029 SPP
ii
Vll. Estimated Rate lmpacts for First Three Years of the SPP (2020-
2022)
Conclusion......
Docket No. 2O200071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1, Page 4 of 48
FPL's Third Supplemental Response to Staffs First Data
Request No. 29 ("Third Supplemental Amended") in Docket No.
2017021s-El
FPL Management Areas and Customers Served
FPL 2020-2029 SPP Estimated Annual Costs and Estimated
Number and Costs of Projects
FPL Distribution Design Guidelines
Project Level Detail for First Year of the SPP (2020)
43
44vlil
Appendices:
Appendix A -
Appendix B -
Appendix C -
Appendix D -
Appendix E -
iii
Docket No. 2O2O0071-E\
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-'l , Page 5 of 48
Florida Power & Light Gompany
2020-2029 Storm Protection Plan
L Executive Summary
Pursuant to Section 366.96, Florida Statutes ("F.S."), and Rule 25-6.030, Florida
Administrative Code ("F.A.C.'), Florida Power & Light Company ("FPL') submits its Storm
Protection PIan for the ten (10) year period 2020-2029 (hereinafter, the'SPP"). As
explained herein, the SPP is largely a continuation of FPL's successful storm hardening
and storm preparedness programs previously approved by the Florida Public Service
Commission ("Commission") over the last fourteen years. FPL anticipates the programs
included in the SPP will have zero bill impacts on customer bills during the first year of
the SPP and only minimal bill increases for years two and three of the SPP.1
Since 2006, FPL has been implementing Commission-approved programs to strengthen
its transmission and distribution ("T&D") infrastructure. These programs include multiple
storm hardening and storm preparedness programs, such as feeder hardening, replacing
wood transmission structures, vegetation management, and pole inspections. As
demonstrated by recent storm events, these ongoing storm hardening and storm
preparedness programs have resulted in FPL's T&D electricalgrid becoming more storm
resilient, experiencing less infrastructure damage and reduced restoration times, as
compared to non-hardened facilities. These programs have also provided significant
improvements in dayto-day reliability.
The success of FPL's storm hardening and storm preparedness programs has been
achieved through the development and implementation of FPL's forward-looking storm
hardening, grid modernization, and reliability initiatives and investments, combined with
the use of cutting-edge technology and strong employee commitment. Under the SPP,
FPL remains committed to continue these successful and industry-leading programs to
1 The recovery of the costs associated with the SPP, as well as the actual and projected costs to
be included in FPL's Storm Protection Plan Cost Recovery Clause, will be addressed in a
subsequent and separate Storm Protection Plan Cost Recovery Clause docket pursuant to Rule
25-6.031, F.A.C.
1
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1, Page 6 of 48
further strengthen its T&D infrastructure, mitigate restoration costs and outage times,
continue to provide safe and reliable electric service to customers, and meet future
increasing needs and expectations.
As stated previously, FPL's SPP is, in large pad, a continuation and expansion of its
previously approved storm hardening and storm preparedness programs, and includes
the following SPP programs:
. Pole lnspections - Distribution Program
. Structures/Other Equipment lnspections - Transmission Program
. Feeder Hardening (EWL) - Distribution Program
. Lateral Hardening (Undergrounding) - Distribution Program
o Wood Structures Hardening (Replacing) - Transmission Program
. Vegetation Management - Distribution Program
. Vegetation Management - Transmission Program
ln addition, FPL will implement a new Substation Storm Surge/Flood Mitigation Program
to harden certain targeted substations that, based on prior experience, are susceptible to
storm surge or flooding during extreme weather events.
With the exception of the new storm surgeiflood mitigation program, the majority of the
programs included in the SPP have been in place since 2007. As demonstrated by recent
storm events, these programs have been successful in reducing restoration costs and
outage times following major storms, as well as improving day-to-day reliability. FPL
submits that continuing these previously approved storm hardening and storm
preparedness programs in the SPP, together with the new storm surge/flood mitigation
substation program, is appropriate and necessary to address the mandates set forth in
Section 366.96, F.S., and Rule 25-6.030, F.A.C., as well as the expectations of FPL's
customers and other stakeholders for increased storm resiliency and will result in fewer
2
Docket No. 20200071-El
FPL's 2o2o-2029 Storm Protection Plan
Exhibit MJ-1 , Page 7 of 48
outages, reduced restoration costs, and prompt service restoration.2 The SPP will
continue and expand the benefits of hardening, including improved day-to-day reliability,
to all customers throughout FPL's system.
The following sections provide information and details on FPL's SPP as required by and
in compliance with Rule 25-6.030, F.A.C. For the reasons explained below, FPL submits
that implementing the SPP is necessary and appropriate to achieve the goals and
requirements expressed by the Florida Legislature in Section 366.96, F.S., to reduce
restoration costs and outage times associated with extreme weather events and improve
overall service reliability to customers and the State of Florida by promoting the overhead
hardening of electrical transmission and distribution facilities, the undergrounding of
certain electrical distribution lines, and vegetation management.
ll. The 2020-2029 SPP will Strenqthen FPL's lnfrastructure
to Withstand Extreme Weather Gonditions and will
Reduce Restoration Gosts and Outaqe Times
Pursuant to Rule 25-6.030(3)(a), F.A.C., this section provides an overview of how the
SPP will strengthen FPL's electric utility infrastructure to withstand extreme weather
conditions by promoting the overhead hardening of electrical transmission and distribution
facilities, the undergrounding of certain electrical distribution lines, and vegetation
management. Consistent with Rule 25-6.030(3Xb), F.A.C., this section also provides a
summary of how the SPP is expected to further reduce restoration costs and outage times
associated with extreme weather conditions and, therefore, improve overall service
reliability.
To date, significant progress has been made toward strengthening FPL's infrastructure.
For example, at year-end 2019, approximately 54o/o of FPL's distribution feeders have
been either hardened or placed underground, and approximately 960/o of FPL's
transmission structures are either steel or concrete. Also, since 2006, FPL has completed
multiple system-wide cycles of distribution and transmission pole inspections and
2 As explained below, a couple of the programs included in the SPP are expected to be completed
within the next several years.
3
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page B of 48
vegetation management. Within the next few years several significant milestones are
also expected to be reached, including replacement of all wood transmission structures
with steel or concrete structures by year-end 2022 and for all feeders to be hardened or
placed underground by year-end 2024.
FPL also implemented a three-yearStorm Secure Underground Program Pilot in 2018
('SSUP Pilot") that converts certain targeted overhead laterals - laterals that have been
impacted by recent storms and have a history of vegetation-related outages and other
reliability issues - to underground laterals. At year-en d 2020, the final year of the SSUP
Pilot, FPL expects 220-230 of these targeted laterals to be converted from overhead to
underground. ln addition, FPL's Design Guidelines incorporate and apply extreme wind
loading ("EWL') criteria to the design and construction of all new overhead pole lines and
major planned work, including pole line extensions, relocations, and certain pole
replacements.
FPL's SPP programs have already demonstrated that they have and will continue to
provide increased T&D infrastructure resiliency, reduced restoration time, and reduced
restoration costs when FPL's system is impacted by severe weather events. ln FPL's
Third Supplemental Response to Staff's First Data Request No. 29 ("Third Supplemental
Amended") in Docket No. 20170215-E1,3 FPL prepared and submitted an analysis of
Hurricanes Matthew and lrma that indicated the restoration construction man-hours
("CMH"), days to restore, and storm restoration costs for these storms would have been
significantly higher without FPL's storm hardening programs. Below is a summary of the
results of FPL's analysis:
Without Hardeni Hurricane Matthew Hurricane lrma
3 The Commission opened Docket No. 20170215-El to review electric utility preparedness and
restoration actions and to identify potential areas where infrastructure damage, outages, and
recovery time for customers could be minimized in the future.
Additional CMH (%)93,000 (36%)483,000 (40o/o)
Additionaldays to restore (%)2 (50o/o)4 (40o/o)
Additional restoration costs
($millions) (%)
$105 (36%)$4e6 (40%)
4
Docket No. 20200071-El
FPL'9 2O2O-2O29 Storm Protection Plan
Exhibit MJ-1, Page I of 48
A copy of FPL's Third Supplemental Amended Response in Docket No.20170215-El,
including the analysis referenced above, is provided in Appendix A. Based on a 40-year
net present value analysis, the savings achieved from storm hardening would equate to
$653 million (for a storm occurring once every three years) and $406 million (for a storm
occurring once every five years) for a storm similar to Hurricane Matthew and $3.1 billion
(for a storm occurring once every three years) and $1.9 billion (for a storm occurring once
every five years) for a storm similar to Hurricane lrma.
These programs have also provided increased levels of day{o-day reliability. For
example, FPL has previously submitted reports to the Commission that show hardened
feeders have pedormed approximately 40% better (i.e., fewer outages) on a day-to-day
basis than non-hardened feeders.a Further details on the benefits of the SPP programs
are provided throughout the remaining sections of this SPP.
Although FPL's storm preparedness and hardening programs to date have produced a
more storm resilient and reliable T&D electrical grid, FPL must continue its efforts to
storm-harden its T&D electrical grid consistent with the findings, conclusions, and
objectives of the Florida Legislature in Section 366.96, F.S. lndeed, Florida remains the
most hurricane-prone state in the nation and, with the significant coast-line exposure of
FPL's system and the fact that the vast majority of FPL's customers live within 20 miles
of the coast, a robust storm protection plan is critical to maintaining and improving grid
resiliency and storm restoration.
Safe and reliable electric service is essential to the life, health, and safety of the public,
and has become a critical component of modern life. lmportantly, as evidenced by the
significant numbers of Florida's workforce that are working remotely during the COVID-
19 pandemic, today's digital society, economy, national security, and daily life are more
dependent on reliable electric service than ever before. While no electrical system can
be made completely resistant to the impacts of hurricanes and other extreme weather
conditions, the programs included in FPL's SPP have already demonstrated that they
5
a See Appendix A.
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-'l , Page 10 of 48
mitigate and will continue to mitigate the impacts of future storms.s While FPL's nation-
leading initiatives have made significant progress toward strengthening FPL's
infrastructure, continuing these previously approved storm hardening and storm
preparedness programs in the SPP, together with the new storm surge/flood mitigation
substation program, is appropriate and crucial to further mitigate restoration costs and
outage times, continue to provide safe and reliable electric service to customers, and
meet current and future needs and expectations of customers, today and for many years
to come.
lll. Description of Service Area and T&D Facilities
Pursuant to Rule 25-6.030(3)(c), F.A.C., this section provides a description of FPL's
service area, including areas prioritized for enhancement, if any, and any areas where
FPL has determined that enhancement of its existing T&D facilities would not be feasible,
reasonable, or practical at this time.
Today, FPL's service territory consists of approximately 28,000 square miles. To serve
its more than 5 million customers, FPL has constructed a T&D electric grid that contains
approximately 75,000 miles of electrical lines, including:
. Approximately 42,000 miles of overhead distribution lines;
. Approximately 26,000 miles of underground distribution lines;
. Approximately 7,000 miles of high-voltage transmission lines;
. Approximately 1.2 million distribution poles; and
. Approximately 68,000 transmission structures.
FPL's service territory is divided into sixteen (16) distribution management areas. A map
depicting FPL's service territory and distribution management areas (with the number of
customers served within each management area) is provided in Appendix B.
At this time, FPL has not identified any areas of its service territory where its SPP
programs would not be feasible, reasonable, or practical. While all of FPL's SPP
5 lt is important to note that despite the implementation of these storm hardening and storm
preparedness programs, outages will still occur when severe weather events impact Florida.
6
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection PIan
Exhibit MJ-1 , Page 11 of 4B
programs are currently system-wide initiatives, annual activities are prioritized based on
ceftain factors such as last inspection date, last trim date, reliability performance, and
efficient resource utilization.6 At this time, there is no area specifically targeted or
prioritized for enhanced performance based on its geographical location.
IV. 2020-2029 SPP Proqrams
Pursuant to Rule 25-6.030(3XcXd), F.A.C., this section provides a description of each
program included in FPL's SPP. lf applicable, each program description below includes:
(1) a description of how each program is designed to enhance FPL's existing transmission
and distribution facilities including an estimate of the resulting reduction in outage times
and restoration costs due to extreme weather conditions; (2) identification of the actual or
estimated start and completion dates of the program; (3) a cost estimate including capital
and operating expenses; (4) a comparison of the costs and the benefits; and (5) a
description of the criteria used to select and prioritize storm protection programs.
A. Pole lnspections - Distribution Program
1. Description of the Proqram and Benefits
The Pole lnspection - Distribution Program included in the SPP is a continuation of FPL's
existing Commission-approved distribution pole inspection program. Below is an
overview of FPL's existing distribution inspection program and its associated benefits.
a. Overview of the Distribution Pole lnspection Proqram
ln response to the 2004-2005 storm seasons and, in particular, the "large number of poles
throughout Florida that required replacement," the Commission required investor-owned
utilities ("lOUs") to implement an eight-year pole inspection cycle for allwood distribution
poles.T FPL's plan was approved in September 20068 and modified in January 2007.s
6 The criteria and factors used to select and prioritize projects within each SPP program are
described below.
7 See Order No. PSC-06-0144-PAA-EI.
8 See Order No. PSC-06-0778-PAA-EU.
e See Order No. PSC-07-0078-EU.
7
Docket No. 2O200071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1, Page 12 of 48
Subsequently, FPL expanded its distribution pole inspection plan to also include concrete
poles.
FPL's eight-year pole inspection cycle for all distribution poles targets approximately 1/8
of the system annually (the actual number of poles inspected can vary somewhat from
year to year). To ensure inspection coverage throughout its service territory, FPL
established nine (9) inspection zones (based on FPL's management areas and pole
population) and annually performs pole inspections of approximately 1/8 of the distribution
poles in each of these zones, as well as any necessary remediation as a result of such
inspections. FPL utilizes Osmose Utilities Services, lnc. ("Osmose"), an industry-leading
pole inspection contractor, to perform the system-wide inspection of its distribution poles.
FPL's strength and loading calculations for its distribution poles and pole inspections are
based on the National Electrical Safety Code's ("NESC') Grade B construction standard,
as outlined by Table 261-1A section 26 of the NESC. Osmose utilizes mobile computing
technology to record inspection data and to calculate strength and loading. The loading
calculation, span lengths, attachment heights, and wire sizes are recorded in the mobile
computer to determine whether the remaining pole strength capacity meets or exceeds
NESC requirements. This data is then transferred to FPL's Geographic lnformation
System ("GlS'). Pole locations inspected by Osmose are also randomly audited by FPL
to verify that inspections are completed and meet inspection standards.
lnspections include a visual inspection of all distribution poles from the ground-line to the
top of the pole to identify visual defects (e.9., woodpecker holes, split tops, decayed tops,
cracks, etc.). lf, due to the severity of the defects, the poles are not suitable for continued
service, the poles are designated for replacement.
Wood poles that pass the above-ground visual inspection are excavated to a depth of 18"
(where applicable), and sounded and bored to determine the internal condition of the
pole. Poles encased in concrete or asphalt are not excavated, but are sounded and bored
to determine their internal condition using a standard industry-accepted inspection
process called "Shell Boring." All suitable wood poles receive external and/or internal
preservative treatment or, if not suitable, are replaced. Strength calculations are also
8
Docket No. 2O2OO071-E\
FPL's 2020-2029 Storm Protection PIan
Exhibit MJ-1, Page 13 of 48
performed on wood poles to determine compliance with NESC requirements. The poles
that are not suitable for continued service are designated for replacement or remediation.
ln 2014, FPL obtained Commission approval to: (1) exempt the loading assessment
during the second eighlyear cycle for any pole that had less than 80% of full load during
FPL's initialeight-year cycle; and (2) excavate Chromium CopperArsenate ("CCA") poles
every 28 years (extended from 16 years originally approved by the Commission).10 To
ensure that these exceptions to the standard eight-year inspection cycle do not
compromise existing safety and storm hardening programs, FPL conducts annualtesting
on 1o/o of the exempted poles.
b. Benefits of the Distribution Pole lnspection Proqram
The Commission has previously found that "efforts to maintain system components can
reduce the impact of hurricanes and tropical storms upon utilities' transmission and
distribution systems," and noted that an "obvious key component in electric infrastructure
is the transmission and distribution poles.'11 The Commission has also previously
identified multiple benefits of and reasons for justifying pole inspections cycles for electric
utilities, including, but no limited to: the likelihood of increased hurricane activity in the
future; the high probability for equipment damage if a pole fails during a storm; the
likelihood that failure of one pole often causes other poles to fail; the fact that deteriorated
poles are more prone to fail when exposed to high winds; the fact that Florida electric
utilities replaced nearly 32,000 poles during the 2004 storm restoration efforts; and the
fact that restoration times increase significantly when a large number of poles fail, which
limits the electric utilities' ability to respond quickly to widespread outages.l2
ln addition to the benefits discussed above that underlie the creation of the Commission's
mandated pole inspection requirements, recent storm events indicate that FPL's
distribution pole inspection program has contributed to the overall improvement in
distribution pole performance during storms, resulting in reductions in storm damage to
poles, days to restore, and storm restoration costs. The table below compares distribution
10 See Order No. PSC-14-0594-PAA-El
11 See Order No. PSC-06-0144-PAA-E.
12 See id.
I
Docket No. 202OO071-EI
F PL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1 , Page '14 of 48
pole performance for Hurricane Wilma, which occurred in 2005 before FPL implemented
its current distribution pole inspection program, and Hurricane lrma, which occurred in
2017 after FPL implemented its current distribution pole inspection program:
Hurricane Wilma Hurricane lrma
Hurricane Strength (Category)3 4
Customer Outages (Millions)3.2 4.4
Distribution Poles Replaced >12,400 <2,90013
Total Days to Restore 18 10
Average Days to Restore 5.4 2.1
FPL's Commission-approved distribution pole inspection program has facilitated the
replacement and/or strengthening of over 140,000 distribution poles since it was first
implemented in 2006 and has directly improved and will continue to improve the overall
health and storm resiliency of its distribution pole population.
2. Actual/Estimated Start and Completion Dates
The SPP will continue FPL's ongoing Commission-approved distribution pole inspection
program described above. With approximately 1.2 million distribution poles as of year-
end 2019, FPL expects to inspect approximately 150,000 poles annually (spread
throughout its nine inspection zones) during the 2020-2029 SPP period.
3. Cost Estimates
Estimated/actual annual distribution pole inspection costs are a function of the number of
inspections estimated to be/actually completed and the number of poles estimated to
be/actually remediated/replaced as a result of the annual inspections. Although costs to
inspect the poles are operating expenses, the vast majority of pole inspection program
costs are capital costs resulting from remediation/replacement of poles that fail
inspection.
13 Approximately 99% of distribution poles replaced after Hurricane lrma were non-hardened
poles.
10
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page '15 of 48
The table below provides a comparison of the 2017-2019 total actual distribution pole
inspection costs with the 2020-2022 (first three years of the SPP) total estimated
distribution pole inspection costs and the 2020-2029 total estimated distribution pole
inspection costs:
Total Program Costs Annual Average Program
illions Gosts illions
Further details regarding SPP estimated distribution pole inspection costs, including
estimated annual capitalexpenditures and operating expenses, are provided in Appendix
c.14
4. Comparison of Costs and Benefits
As provided in Section (lV)(A)(3) above, during 2020-2029, total costs for FPL's Pole
lnspection - Distribution Program are expected to average approximately $61 million per
year. Benefits associated with FPL's Pole lnspection - Distribution Program, discussed
in Sections ll and |V(AX1)(b) above, include a more storm resilient pole population that
will result in reductions in pole failures and poles needing to be replaced during storms,
fewer storm-related outages and reductions in storm restoration costs.
5. Criteria used to Select and Prioritize the Proqram
Poles to be inspected annually are selected/prioritized within each of the nine (9)
inspection zones established throughout FPL's service territory based on the last cycle's
inspection dates, to ensure that poles are in compliance with FPL's established eight-year
1a Note, lhe 2020-2029 program costs shown above are projected costs estimated as of the time
of this filing. Subsequent projected and actual costs could vary by as much as 10oh to 15%. The
annual projected costs, actual/estimated costs, actuals costs, and true-up of actual costs to be
included in FPL's Storm Protection Plan Cost Recovery Clause will all be addressed in
subsequent and separate Storm Protection Plan Cost Recovery Clause filings pursuant to Rule
25-6.031, F.A.C. The Commission has opened Docket No.20200092-El to address Storm
Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
2017-2019 $1 52 $st
2020-2022 $1 70 $sz
2020-2029 $605 $61
11
Docket No. 2O2OO071-EI
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , Page 16 of 48
cycle. As such, approximately 1/8 of the distribution poles in each inspection zone are
inspected annually.
At this time, FPL has not identified any areas where the Pole lnspection - Distribution
Program would not be feasible, reasonable or practical.
Structures/Other Equipment lnspections Transmission
Program
1. Description of the Proqram and Benel[s
The Structures/Other lnspections - Transmission Program included in the SPP is a
continuation of FPL's existing Commission-approved transmission inspection program.
Below is an overview of FPL's existing transmission inspection program and the
associated benefits.
a. Overview of the Transmission lnspection Proqram
ln 2006, as part of its Storm Preparedness lnitiative No. 3, the Commission required
electric utilities to develop and implement plans to fully inspect alltransmission structures,
substations, and all hardware associated with these facilities on a six-year cycle.
Consistent therewith, FPL implemented a Commission-approved transmission inspection
plan in 2006 and has continued that plan to date.
Under its Commission-approved transmission inspection plan, FPL inspects its
transmission circuits, substations, and other equipment on a six-year cycle. Additionally,
all of FPL's transmission structures are visually inspected from the ground each year.
Finally, FPL performs climbing or bucket truck inspections on all wood transmission
structures on a six-year cycle and all steel and concrete structures on a ten-year cycle.
lnspections for wood structures include an overall assessment of the condition of the
structures, as well as other pole/structure components including the foundation, all
attachments, insulators, guys, cross-braces, cross-arms, and bolts. lf a wood
transmission structure does not pass visual inspection, it is designated for replacement
with a concrete or steel transmission structure.
B
12
Docket No. 2020O071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 17 of 48
For steel and concrete structures, the visual inspection includes an overall assessment
of the structure condition (e.9., cracks, chips, exposed rebar, and rust) as well as other
pole/structure components including the foundation, all attachments, insulators, guys,
cross-braces, cross-arms, and bolts. lf a concrete or steel pole/structure fails the
inspection, it is designated for repair or replacement.
The SPP will continue FPL's current transmission inspection program which requires: (a)
transmission circuits and substations and all associated hardware to be inspected on a
six-year cycle; (b) wood structures to be inspected visually from the ground each year
and climbing or bucket truck inspections to be conducted on a six-year cycle; and (c) steel
and concrete structures to be inspected visually each year and climbing or bucket truck
inspections to be conducted on a ten-year cycle.
b. Benefits of the Transmission lnspection Proqram
As noted in Section lV(A)(1)(b) above, the Commission has found numerous benefits and
reasons justifying inspections of electrical utility facilities, including transmission facilities.
lmportantly, the transmission system is the backbone of the electric grid. While outages
associated with distribution facilities (e.9., a transformer, lateral orfeeder) can result in
an outage affecting anywhere from a few customers up to several thousands of
customers, a transmission related outage can affect tens of thousands of customers.
Additionally, an outage on a transmission facility could cause cascading (a loss of power
at one transmission facility can trigger the loss of power on another interconnected
transmission facility, which in turn can trigger the loss of power on another interconnected
transmission facility, and so on) and result in the loss of service for hundreds of thousands
of customers. As such, it is imperative that transmission facilities be properly inspected
using appropriate cycles and standards to help ensure they are prepared for storms.
Further, the performance of FPL's transmission facilities during recent storm events
indicates FPL's transmission inspection program has contributed to the overall storm
resiliency of the transmission system and provided savings in storm restoration costs.
The table below compares the performance of FPL's transmission system for Hurricane
Wilma, which occurred in 2005 before FPL implemented its current transmission
13
Docket No. 2O2O0071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 1B of 48
inspection program, and Hurricane lrma, which occurred in 2017 after FPL implemented
its current transmission inspection program:
Transmission Facilities Hurricane Wilma Hurricane lrma lm ent
As shown above, the impacts on FPL's transmission facilities associated with Hurricane
lrma were significantly reduced from those experienced with Hurricane Wilma, even
though Hurricane lrma's winds were stronger and its path impacted substantially more of
FPL's facilities. As reflected in the Commission's reasoning for mandating transmission
facility inspections, FPL submits that its systematic transmission inspection program is a
key factor for this improved performance.
2. Actual/Estimated Start and Comnletion Dates
The SPP will continue FPL's ongoing Commission-approved transmission inspection
program described above. This requires FPL to inspect: (a) transmission circuits and
substations and all associated hardware on a six-year cycle; (b) wood structures to be
visually inspected from the ground each year and conduct climbing or bucket truck
inspections on a six-year cycle; and (c) steel and concrete structures visually each year
and conduct climbing or bucket truck inspections on a ten-year cycle.
3. Cost Estimates
Estimated/actual annual transmission inspection costs are a function of the number of
inspections estimated to be/actually completed and the transmission facilities estimated
to be/actually remediated/replaced as a result of those annual inspections. Although the
inspection costs are operating expenses, the vast majority of the transmission inspection
program costs are capital costs resulting from remediation/replacement of facilities that
fail inspection.
The table below provides a comparison of the 20'17-2019 total actual transmission
inspection costs with the 2020-2022 (first three years of the SPP) total estimated
Line Section Outages 345 215 38o/o
Substation Outages 241 92 620/o
5 95%Structures Failed 100
14
Docket No. 2020007|-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 19 of 4B
transmission inspection costs and the 2020-2029 totalestimated transmission inspection
costs:
Total Program Gosts Annual Average Program
millions Gosts millions
Further details regarding the SPP estimated transmission inspection costs, including
estimated annual capitalexpenditures and operating expenses, are provided in Appendix
c.15
4. Comparison of Costs and Benefits
As provided in Section |V(BX3) above, during 2020-2029, total costs for FPL's
Structures/Other lnspections - Transmission Program are expected to average
approximately $50 million per year. Benefits associated with the Structures/Other
lnspections - Transmission Program discussed in Sections ll and |V(BX1)(b) above,
include avoiding outages that can affect tens of thousands of customers and, in pafticular,
cascading outages where the loss of service can affect hundreds of thousands of
customers.
5. Criteria used to Select and Prioritize the Program
As explained above, FPL visually inspects from the ground all transmission structures on
an annual basis. For the inspection of transmission circuits and substations and all
associated hardware, the facilities are selected/prioritized throughout FPL's service
territory based on the last cycle's inspection dates, to ensure that facilities are inspected
in compliance with the established six-year inspection cycle. Similarly, for bucket truck
or climbing inspections, structures are selected/prioritized throughout FPL's service
territory based on the last cycle's inspection dates, to ensure that structures are inspected
2017-2019 $1 28 $43
2020^2022 $ez $32
2020-2029 $500 $50
1s See footnote 14
15
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 20 of 48
in compliance with the established six-year (wood) and ten-year (steel and concrete)
cycles.
At this time, FPL has not identified any areas where the Structures/Other lnspections -
Transmission Program would not be feasible, reasonable or practical.
Feeder Hardening (EWL) - Distribution Program
1. Description of the Proqram and Benefits
The Feeder Hardening (EWL) - Distribution Program included in the SPP is a
continuation of FPL's existing Commission-approved approach (most recently approved
in Docket No.20180144-El) to harden existing feeders and certain critical distribution
poles, as well as FPL's initiative to design and construct new pole lines and major planned
work to meet the NESC's extreme wind loading criteria ("EWL'). FPL will continue the
distribution feeder hardening program unlil2024, when FPL expects 100% of its feeders
to be hardened or underground. Below is an overview of FPL's existing distribution feeder
hardening program and the associated benefits.
a. Overview of the Distribution Feeder Hardening Program
The foundation for FPL's distribution feeder hardening program was the extensive
forensic and other analyses that FPL conducted after Hurricane Wilma.16 These analyses
concluded that "wind only" (as opposed to, for example, trees or other flying debris) was
the predominant root cause of distribution pole breakage. This data, together with the
overall performance of FPL's transmission poles that were already built to the NESC EWL
standards and the performance of hardened feeders during Hurricanes Matthew and
lrma, formed the basis for FPL's feeder hardening strategy.
The SPP will continue FPL's previously approved approach to apply EWL criteria to
harden existing distribution feeders and certain critical poles. The NESC extreme wind
map for Florida will continue to be applied to FPL's system by dividing the application of
16 These analyses were conducted either directly by FPL or with the aid of external resources
(e.9., KEMA, lnc.).
c
16
Docket No. 202OO071-E\
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 21 ol 48
EWL into three wind regions, corresponding to expected extreme winds of 105, 130 and
145 mph, as shown below.
FPL Extreme Wind Reqions - mph (meter/sec)
I s0(ct)105 mph
130 mph
145 mph
r.o(G3)
By evaluating each of the counties served by FPL, including each county's applicable
wind zones, FPL determined that utilizing three extreme wind regions of '105, 130 and
145 mph for its service territory was appropriate for the following reasons:
A smaller number of wind regions generate advantages through efficiency of
work methods, training, engineering and administrative aspects (e.9.,
standards development and deployment); and
Using 105, 130 and 145 mph wind zones is a well balanced approach that
recognizes differences in the EWL requirements in the counties within each
region.
a
a
The SPP will also continue to utilize FPL's Design Guidelines and processes that apply
EWL criteria to the design and construction of new pole lines and major planned work,
including pole line extensions and relocations and certain pole replacements. Depending
on the scope of the work that is pedormed in a particular project, this could result in the
EWL hardening of an entire circuit (in the case of large-scale projects) or in EWL
hardening of one or more poles (in the case of small projects) so that the affected circuit
will be in a position to be fully EWL hardened in the future. The Design Guidelines are
17
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1, Page 22 of 48
primarily associated with changes in pole class, pole type, and desired span lengths to
be utilized. The Design Guidelines standardize the design and construction of new pole
lines and major planned work to ensure that these projects align with FPL's hardening
strategy.
FPL's current pole sizing guidelines provide for a minimum installation of: Class 2 wood
poles for all new feeder and three-phase lateral work; Class 3 wood pole for two-phase
and single-phase lateral work; and Class 3 wood pole for service and secondary work.
For critical poles, FPL's current pole sizing guidelines provide for the installation of
concrete poles at accessible locations. These guidelines significantly increase the wind
ratings (up to nearly 50 percent) from the Design Guidelines in place prior to 2007. FPL's
current Distribution Design Guidelines are provided in Appendix D.
To determine how an existing overhead circuit or critical pole will be hardened, a field
survey of the circuit facilities is performed. By capturing detailed information at each pole
location, such as pole type, class, span distance, attachments, wire size, and framing, a
comprehensive wind-loading analysis can be performed to determine the current wind
rating of each pole, and ultimately the circuit itself. This data is then used to identify
specific pole locations on the circuit that do not meet the desired wind rating. For all poles
that do not meet the applicable EWL, FPL develops recommendations to increase the
allowable wind rating of the pole.
FPL plans to continue to utilize its "design toolkit" that focuses on evaluating and using
cost-effective hardening options for each location, including:
Storm Guying - lnstalling a guy wire in each direction perpendicular to the line,
which is a very cost-effective option but is dependent on proper field conditions;
Equipment Relocation - Moving equipment on a pole to a stronger pole near-
by;
lntermediate Pole - lnstalling an additionalsingle pole within Iong span lengths,
which reduce the span length and increases the wind rating of both adjacent
poles;
a
a
a
18
Docket No. 202O4071-El
FPL's 2O2O-2029 Storm Protection Plan
Exhibit MJ-'l, Page 23 of 48
Upgrading Pole Class - Replacing the existing pole with a higher class pole to
increase the pole's wind rating; and;
Undergrounding Facilities - Evaluated on a case-by-case basis using site-
specific factors and conditions.
These options are not mutually exclusive and, when used in combination with sound
engineering practices, provide cost-effective methods to harden a circuit. FPL's design
recommendations also take into consideration issues such as hardening, mitigation
(minimizing damage), and restoration (improving the efficiency of restoration in the event
of failure). Since multiple factors can contribute to losing power after a storm, utilizing
this multi-faceted approach to pole design helps to reduce the amount of work required
to restore power to a damaged circuit.
b. Benefits of the Distribution Feeder Hardeninq Program
Distribution feeders are the backbone of the distribution system and are critical
component to providing safe and reliable electric service to FPL's customers. Thus,
improving the storm resiliency of distribution feeders logically provides substantial
benefits for customers. Therefore, hardening distribution feeders has been and continues
to be one of FPL's highest storm hardening priorities.
During the period 2006-2019, FPL hardened over 1,300 existing feeders, the vast majority
being Critical lnfrastructure Function ("ClF") feeders (i.e., feeders that serve hospitals,
911 centers, police and fire stations, water treatment facilities, county emergency
operation centers) and Community Project feeders (r.e., feeders that serve other key
community needs like gas stations, grocery stores, and pharmacies) throughout FPL's
service territory. Additional feeders were hardened as a result of FPL's Priority Feeder
lnitiative, a reliability program that targeted feeders experiencing the highest number of
interruptions and/or customers interrupted. As of year-end 2019, approximately 54% of
FPL's feeders were either hardened or placed underground. Additionally, FPL has
hardened '125 highway crossings and over 300 "01" switches (first pole out of a substation
with a feeder switch). FPL also applied EWL to the design and construction of new pole
a
a
19
Docket No. 202O0071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 24 of 48
lines and major planned work, including pole line extensions and relocations and certain
pole replacements.
As provided in previous FPL Annual Reliability Report filings and three-year Storm
Hardening Plan filings (per Rule 25-6.0342, F.A.C.) hardened feeders perform better than
non-hardened feeders. This has been demonstrated in-day-to-day reliability performance
and during severe storms. For example, when comparing day-to-day reliability
performance, hardened feeders have performed 40% better than non-hardened feeders.
Also, during Hurricanes Matthew and lrma, hardened feeders performed better than non-
hardened feeders.
Additionally, in Docket No. 20170215-EU, the Commission reviewed the electric utilities'
storm hardening and storm preparedness programs and found for Hurricane lrma that:
(1) outage rates were nearly 20% less for hardened feeders than non-hardened feeders;
(2) CMH to restore hardened feeders were 50% less than non-hardened feeders
(primarily due to hardened feeders experiencing less damage than non-hardened
hardened feeders); and (3) hardened feeders had significantly less pole failures as
compared to non-hardened feeders.lT
2. ActualiEstimated Start and Completion Dates
FPL initiated its feeder hardening initiative in 2006. As of year-end 2019, there are
approximately 1,600 feeders remaining to be hardened or placed underground. FPL
expects to harden approximately 250-350 feeders annually, with 100% of FPL's feeders
expected to be hardened or underground by year-end 2024 and with the final costs of the
program to be incurred in 2025.
17 See Review of Florida's Electric Utility Hurricane Prepared ness and Restoration Actions 2018,
Docket No. 20170215-EU (July 24,2018), available at
http:i/www. psc. state.fl. us/librarvifilin ssl201 B I 04847 -201 B I 04847 -20 1 B. pdf.
20
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection PIan
Exhibit MJ-1 , Page 25 of 4B
3. Cost Estimates
Estimated distribution feeder hardening costs are determined utilizing the length of each
feeder, the average historical feeder hardening cost per mile, and updated cost
assumptions (e.9., labor and materials).
The table below provides a comparison of the 2017-2019 total actual distribution feeder
hardening costs with the 2020-2022 (first three years of the SPP) total estimated
distribution feeder hardening costs and the total estimated distribution feeder hardening
costs to be incurred over the period of 2020-202518:
Total Program Costs Annual Average Program
millions Costs millions
Further details regarding the SPP distribution feeder hardening costs, including estimated
annual capital expenditures are provided in Appendix C.1e
4. Comparison of Costs and Benefits
As provided in Section lV(C)(3) above, during 2020-2025, total costs for FPL's Feeder
Hardening (EWL) - Distribution Program average approximately $534 million per year
through 2025. Benefits associated with the Feeder Hardening (EWL) - Distribution
Program discussed in Sections ll and |V(CX1Xb) above, include improved storm
resiliency as well as improved day-to-day reliability.
5. Criteria used to Select and Prioritize the Proqram
As explained above, there are approximately 1,600 feeders remaining to be hardened or
placed underground. FPL attempts to spread its annual projects throughout its service
territory. ln prioritizing the remaining existing feeders to be hardened each year,
18 lt is currently estimated that 100% of FPL's feeders will be hardened or underground by year-
end 2024, with the final costs to be incurred in 2025.
1s See footnote 14.
2017-2019 $1,492 $497
2020-2022 $1,958 $653
2020-2025 $3,206 $534
21
Docket No. 2020O071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1 , Page 26 of 48
considerations include the feeder's historical reliability performance, restoration
difficulties (e.9., environmentally sensitive areas, islands with no vehicle access, river
crossings, etc.), on-going or upcoming internal/external projects (e.9., FPL maintenance
or system expansion projects, municipal overhead/underground conversion project or
municipal road project) and geographic location.
At this time, FPL has not identified any areas where the Feeder Hardening (EWL) -
Distribution Program would not be feasible, reasonable or practical.
Lateral Hardening (Undergrounding) - Distribution Program
1. Description of the Proqram and Brenelils
ln 2018, FPL implemented a three-year Commission-approved SSUP Pilot. The SSUP
Pilot is a program that targets certain overhead laterals for conversion from overhead to
underground. As part of its SPP, FPL will expand undergrounding laterals in 2021-2029.
Below is an overview of FPL's Lateral Hardening (Undergrounding) - Distribution
Program and the associated benefits.
a Overuiew of the Distribution Lateral Hardenin o Prooram
As part of the SPP, FPL will complete its existing approved three-year SSUP Pilot (in
2020) and expand the application of the SSUP during 2021-2029 to the implementation
of the system-wide Lateral Hardening (Undergrounding) - Distribution Program. The
SSUP Pilot targeted certain overhead laterals that were impacted by recent storms and
that have a history of vegetation-related outages and other reliability issues for conversion
from overhead to underground. Key objectives of the SSUP Pilot included validating
conversion costs and identifying cost savings opportunities, testing different design
philosophies, better understanding customer impacts and sentiments, and identifying
barriers (e.9., obtaining easements, placement of transformers, and attaching entities'
issues).
Two design options are being utilized when FPL converts overhead laterals to
underground, referred to as the North American and the European designs. The North
American design currently is the predominant design, but both undergrounding designs
eliminate all overhead lateral and service wire. The North American design generally
22
D
Docket No. 2O200071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 27 o( 4B
utilizes more primary conductor and a greater number of smaller-sized transformers, with
less customers per transformer, and is better suited for front lot construction and service.
The European design utilizes more secondary conductor, and a smaller number of larger-
sized transformers, with more customers per transformer, and is better suited for rear lot
construction and service. Where practical, FPL attempts to relocate existing facilities from
the rear of to the front of customers' premises; however, there are instances where that
option is not available (e.9., FPL is unable to obtain easements in front of customers'
premises). FPL's standard design is the North American design (front lot construction),
but FPL is gaining important experience and knowledge from its utilization of the
European design (rear lot construction), which it can then better utilize for future projects
as appropriate.
As part of the conversion process, FPL is also installing meter base adaptors that allow
underground service to be provided to the customer by utilizing the existing meter and
meter enclosure. The meter base adaptors minimize the impact on customer-owned
equipment and facilities. For example, in certain situations, overhead to underground
conversions of electric service can trigger a local electrical code requirement that
necessitates a customer upgrade of the home's electric service panel. This can cost the
customer thousands of dollars. However, by utilizing a meter base adaptor, overall costs
are reduced and customers are able to avoid the need and expense to convert their
electrical service panels.
b. Benefits of the Distribution Lateral Hardeninq Proqram
Laterals make up the majority of FPL's distribution system. For example, system-wide,
there are over 180,000 laterals (including laterals with multi-stage fusing), in contrast to
approximately 3,300 feeders, and there are 1.8 times as many miles of overhead laterals
as there are overhead feeders (approximately 23,000 miles vs. 13,000 miles,
respectively). Additionally, while feeders are predominately located in the front of
customers' premises, many laterals are "rear of' or behind customers' premises. This is
especially the case in older neighborhoods located throughout FPL's service territory.
Generally, facilities in the rear of customers' premises take longer to restore than facilities
in front of customers' premises because rear-located facilities are more difficult to access
23
Docket No. 2O2O0071-E\
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 2B of 48
and are more likely to be near vegetation. This results in a greater amount of CMH being
devoted to laterals during storm restoration.
The basis for FPL's SSUP Pilot and the proposal to expand upon the Pilot under the SPP
is the performance of the underground facilities as compared to overhead facilities and
the extensive damage to the overhead facilities caused by vegetation during Hurricanes
Matthew and lrma. This performance was demonstrated by the results of FPL's analysis
referenced above in Section |V(AX1)(b) and contained in the Commission's Review of
Florida's Electric Utility Hurricane Preparedness and Restoration Actions in 2018,20 which
is summarized in the table below:
Storm and Faci Laterals Out Total Laterals % Out
Finally, it is important to note that underground facilities also perform better than overhead
facilities on a dayto-day basis. For example, based on the reliability performance metrics
for overhead and underground facilities provided to the Commission in FPL's February
28,2020 Annual Reliability Report filing, the System Average lnterruption Duration lndex
("SAlDl') for underground facilities is significantly betterthan hybrid facilities (combination
of overhead and underground) or overhead facilities as shown in the table below:
sAlD12l
Year UG OHH brid
20 See footnote 17.
21 See pages 93-97 of FPL's February 28, 2020 Annual Reliability Report filing for more details
on day-to-day reliability performance - overhead vs. underground.
Matthew OH 3,473 82,729 4o/o
Matthew UG 238 101,892 O.2o/o
24o/olrma OH 20,341 84,574
lrma UG 3,767 103,384 4o/o
21.4 102.4 60.02015
2016 17.2 80.4 57.6
2017 17.7 89.6 55.5
2018 21.2 89.0 54.2
2019 30.3 87.4 49.4
24
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 29 of 4B
2. Actual/Estimated Start and Completion Dates
FPL's SSUP Pilot was initiated in 2018. By the end of 2020, the third and final year of
the SSUP Pilot, FPL expects to have converted a total of 220-230laterals from overhead
to underground, which is consistent with the SSUP Pilot's plan most recently approved in
Docket No. 20180144-El. As part of its SPP, FPL will incorporate, continue, and expand
the SSUP to provide the benefits of underground lateral hardening throughout its system.
After completing the SSUP Pilot in 2020, FPL estimates it will convert 300-700 laterals
annually. ln 2024-2029 FPL estimates it will convert 800-900 laterals annually.
3. Cost Estimates
Estimated lateral undergrounding costs are determined utilizing the length of each lateral,
the average historical lateral undergrounding cost per mile, and updated cost
assumptions (e.9., labor and materials). The table below provides a comparison of the
2018-2019 total actual costs for the SSUP Pilot with the 2020-2022 (first three years of
the SPP) total estimated distribution lateral hardening program costs and the 2020-2029
total estimated distribution lateral hardening program costs:
Total Annual Average
P ram Gosts millions P ram Costs illions
Further details regarding the SPP estimated distribution lateral hardening program costs,
including estimated annual capital expenditures are provided in Appendix C.23
4. Comparison of Costs and Benefits
As provided in Section lV(D)(3) above, during 2020-2029, total costs for FPL's Lateral
Hardening (Undergrounding)- Distribution Program average approximately $510 million
per year. Benefits associated with the Lateral Hardening (Undergrounding) - Distribution
22The Storm Secure Underground Program Pilot was initiated in 2018.
23 See footnote 14.
2018-201922 $76 $38
2020-2022 $676 $225
2020-2029 $5,101 $51 0
25
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 30 of 4B
Program discussed in Sections ll AND |V(DX1)(b) above, include improved storm
resiliency as well as improved day-to-day reliability.
5. Criteria used to Select and Prioritize the Proqram
FPL will select/prioritize future laterals for conversion to undergrounding based on an
overall feeder performance methodology. Rather than selecting individual "stand-alone"
laterals, FPL will underground all the laterals on a feeder such that when a hardened
feeder that has experienced an outage is restored, all associated underground laterals
would also be restored (unless the underground lateralwas damaged).
On average, there are currently 20-30 overhead laterals on a feeder. The selection and
prioritization of the laterals to be converted will be based on a methodology that considers.
(a) all of the overhead laterals on each feeder; (b) outage experience during the recent
Hurricanes Matthew and lrma; (c) the number of vegetation-related outages experienced
over the most recent 10 years; and (d) the total number of lateral and transformer outages
experienced over the most recent 10 years. These overhead lateral factors are totaled
for each feeder, and the feeders are ranked based on these totals. All laterals on the
feeders will then be hardened according to the ranking of each feeder.
ln order to optimize resources and provide lateral hardening throughout FPL's system,
lateral hardening projects will be performed annually in all sixteen (16) of FPL's
management areas. At this time, FPL has not identified any areas where the Lateral
Hardening (Undergrounding) - Distribution Program would not be feasible, reasonable,
or practical. However, in areas that are more prone to flooding or storm surge, FPL will
consider alternative construction methods (e.9., elevating transformer pads).
E Wood Structures Hardening (Replacing) Transmission
Program
1. Description of the Proqram and Benefits
The Wood Structure Hardening (Replacing) - Transmission Program included in the SPP
is a continuation of FPL's existing transmission hardening program through the end of
2022, when FPL expects that 100% of its transmission structures will be steel or concrete.
26
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 31 of 48
Below is an overview of FPL's existing transmission wood structure hardening program
and the associated benefits.
a. Overview of the Transmission Hardeninq Proqram
Wf ite FPL's transmission facilities were affected by the 2004 and 2005 storms, the
damage experienced was significantly less than the damage sustained by distribution
facilities. A primary reason for this resulted from the fact that transmission structures were,
at that time, already constructed to meet EWL consistent with Florida Statute 366.04 and
the National Electrical Safety Code, Rule 250 C.
Based on the forensic data collected from the 2004 and 2005 storms, FPL implemented a
Commission-approved transmission storm hardening initiative to replace all wood
transmission structures, which accounted for nearly 70 percent of all transmission
structures replaced during the2004-2005 storm seasons, with steelor concrete structures.
As explained below, this initiative is ongoing and expected to be completed by the end of
2022. As part of its SPP, FPL will continue its initiative to replace allwood transmission
structures with steel or concrete structures.
b. Benefits of the Transmission Hardeninq Proqram
While an outage associated with distribution facilities (e.9., a transformer, lateral, or
feeder) can impact up to several thousands of customers, a transmission-related outage
can result in an outage affecting tens of thousands of customers. Additionally, an outage
on a transmission facility could cause cascading (a loss of power at one transmission
facility can trigger the loss of power on another interconnected transmission facility, which
in turn can trigger the loss of power on Another interconnected transmission facility, and
so on) and result in the loss of service for hundreds of thousands of customers. As a
result, the prevention of transmission-related outages is essential. As discussed earlier,
while transmission facilities performed significantly better than distribution facilities during
the 2004 and 2005 storms, there were several opportunities for improvement identified,
including the replacement of wood transmission structures. As a result of its transmission
inspection programs and its replacement of wood transmission structures, FPL's
transmission facilities have demonstrated to be more storm resilient.
27
Docket No. 202OO071-E\
FPL's 202O-2O29 Storm Protection Plan
Exhibit MJ-'l, Page 32 of 48
The table below compares the performance of FPL's transmission system for Hurricane
Wilma, which occurred in 2005 before FPL implemented its current transmission
hardening program, and Hurricane lrma, which occurred in 2017 after FPL implemented
its current transmission hardening program:
Hurricane Wilma Hurricane
lrma
% Line Section Outages 37o/o 17o/o
Transmission Structure Failures 100 5
(all non-hardened)
Transmission Substations De-energized 241 92
Days to Restore Substation Outages 5 1
As shown above, the impacts on FPL's transmission facilities associated with Hurricane
lrma were significantly reduced from those experienced with Hurricane Wilma, even
though Hurricane lrma's winds were stronger and its path impacted substantially more of
FPL's facilities.
2. Actual/Estimated Start and Completion Dates
FPL implemented its transmission hardening program in 2007. As of year-end 2019,960/o
of FPL's transmission structures, system-wide, were steel or concrete, with less than
2,900 (or 4o/o) wood structures remaining to be replaced. FPL expects to replace the
2,900 wood transmission structures remaining on its system by year-end 2022.
3. Cost Estimates
Estimated/actual annual transmission hardening costs are a function of the number of
poles to be replaced, actual historical replacement costs, and updated cost assumptions
(e.9., labor and materials). The vast majority of the transmission hardening program costs
are capital costs resulting from replacement of the wood transmission structures.
28
Docket No. 2O200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 33 of 48
The table below provides a comparison of the 2017-2019 total actual transmission
hardening costs with the 2020-2022 (first three years of the SPP) total estimated
transmission hardening costs:24
Total Annual Average
P ram Costs millions ram Costs millions
Further details regarding the SPP estimated transmission hardening costs, including
estimated annualcapital expenditures and operating expenses, are provided in Appendix
c.25
4. Comparison of Costs and Benefits
As provided in Section lV(E)(3) above, during 2020-2022, total costs for FPL's Wood
Structure Hardening (Replacing) - Transmission Program average approximately $39
million per year. Benefits associated with the Wood Structure Hardening (Replacing) -
Transmission Program discussed in Sections ll and lV(E)(1)(b) above, include improved
storm resiliency.
5. Criteria used to Select and Prioritize the Program
The annual prioritization/selection criteria for the remaining wood structures to be
replaced includes proximity to high wind areas, system importance, customer counts, and
coordination with other storm initiatives (e.9., distribution feeder hardening). Other
economic efficiencies, such as opportunities to perform work on multiple transmission line
sections within the same transmission corridor, are also considered.
At this time, FPL has not identified any areas where the replacement of the remaining
wood transmission structures under the Wood Structure Hardening (Replacing) -
Transmission Program would not be feasible, reasonable or practical.
24 FPL expects that 100o/o of the remaining wood transmission structures in its system will be
replaced by year-end 2022.
25 See footnote 14.
2017-2019 $162 $s+
2020-2022 $1 18 $3s
29
Docket No. 2O200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 34 of 4B
F. Substation Storm Surge/Flood Mitigation Program
1. Description of the Proqram and Benefits
The Substation Storm Surge/Flood Mitigation Program is the only new program included
in FPL's SPP. As explained below, Substation Storm Surge/Flood Mitigation Program is
a new program to mitigate damage at several targeted distribution and transmission
substations that are susceptible to storm surge and flooding during extreme weather
events.
Historically, several FPL distribution and transmission substations have been impacted
by storm surge and/or flooding as a result of extreme weather conditions. For example,
as a result of flooding caused by Hurricanes Matthew and lrma, FPL's St. Augustine
substation was required to be proactively de-energized (r.e., shut down before water
reached levels that would cause significant damage to powered substation equipment).
Another example is FPL's South Daytona substation that was proactively de-energized
during Hurricane lrma as a result of flooding. While proactively de-energizing those
substations impacted by storm surge and/or flooding helps reduce damage to substation
equipment, FPL is still required to implement both temporary flood mitigation efforts and
repairs to substation facilities and equipment that become flooded as a result of extreme
weather conditions.
An outage associated with distribution substations can impact up to several thousands of
customers, and an outage associated with a transmission substation can result in an
outage affecting tens of thousands of customers. Flooding and the need to proactively
de-energize substations located in areas susceptible to storm surge and flooding can
result in significant customer outages. For example, the flooding and de-energization of
St. Augustine and South Daytona during Hurricane lrma resulted in more than 8,000
customer outages. Therefore, the prevention of outages at transmission and distribution
substations due to storm surge or flooding is essential.
To prevent/mitigate future substation equipment damage and customer outages due to
storm surge and flooding, FPL's new Substation Storm Surge/Flood Mitigation Program
will target and harden certain substations located in areas throughout FPL's service
30
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection PIan
Exhibit MJ-'1 , Page 35 of 48
territory that are susceptible to storm surge or flooding during extreme weather events.
Specifically, FPL plans to raise the equipment at certain substations above the flood level
and construct flood protection walls around other substations to prevent/mitigate future
damage due to storm surge and flooding.
2. Actual/Estimated Start and Completion Dates
At this time, FPL has identified between 8-10 substations where it initially plans to
implement storm surge/flood mitigation measures over the next three years (2020-2022).
FPL plans to initiate construction in late summeriearly fall 2020 to raise the equipment at
the St. Augustine substation, which is expected to be completed in 2021. ln 2021 and
early 2022, FPL also plans to begin construction on flood protection walls for the other 7-
9 substations identified for mitigation, which is expected to be completed by 2022.
3. Cost Estimates
The storm surge/flood mitigation costs associated with St. Augustine substation (raising
substation equipment) are estimated to be approximately $10 million in total (2020 and
2021). Estimated storm surge/flood mitigation costs for the remaining 7-9 substations
identified at this time (constructing surrounding flood walls) are estimated to be
approximately $13 million in total (2021 and2022). See the table below the estimated
annual program costs:
Total Annual Average
P ram Costs millions ram Costs millions
Further details regarding the SPP estimated storm surge/flood mitigation costs, including
estimated annual capitalexpenditures and operating expenses, are provided in Appendix
c.26
4. Comparison of Costs and Benefits
As provided in Section IV(FX3) above, during 2020-2022, totalcosts for FPL's Substation
Storm Surge/Flood Mitigation Program average approximately $8 million per year.
2020-2022 $23 $a
26 See footnote 14
31
Docket No. 2O200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 36 of 4B
Benefits associated with this program discussed in Section |V(FX1) above, include
improved storm resiliency (avoiding storm surge/flood damage), reduced customer
outages and storm restoration costs.
5. Criteria used to Select and Prioritize Proiects
The annual prioritization/selection criteria for the targeted substations is based on FPL's
historical storm surge/flood experience, in particular, Hurricanes Matthew and lrma. At
this time, for the targeted substations, FPL has not identified any areas where the
upgrades would not be feasible, reasonable or practical.
c. Vegetation Management - Distribution Program
1. Description of the Proqram and Benefits
The Vegetation Management - Distribution Program included in the SPP is a continuation
of FPL's existing Commission-approved Vegetation Management - Distribution Program.
Below is an overview of FPL's existing Vegetation Management - Distribution Program
and the associated benefits.
a Overuiew of the Veoetation A/leneocmen t Disfribufion
Proqram
Prior to 2006, FPL's Vegetation Management - Distribution Program consisted of
inspecting and maintaining its feeders on a three-year average trim cycle and performing
targeted trimming on certain feeders more frequently (e.9., targeting vegetation with faster
growth rates and palm trees) through its "mid-cycle" program. Lateral trimming was
prioritized based on reliability performance. Another important component of this program
was FPL's "Right Tree Right Place" initiative, which provided information to educate
customers on FPL's vegetation management program and practices, safety issues, and
the importance of placing trees in the proper location.
After the 2004-2005 storm seasons, the Commission determined that the "vegetation
management practices of the investor-owned electric utilities do not provide adequate
assurance that tree clearances for overhead distribution facilities are being maintained in
a manner that is likely to reduce vegetation related storm damage. We believe that
32
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 37 of 48
utilities should develop more stringent distribution vegetation management programs."27
As result, FPL proposed and the Commission approved the continuation of FPL's system-
wide three-year average trim cycle for feeders, mid-cycle targeted trimming for certain
feeders, and its Right Tree Right Place initiative, as well as the implementation of a new
six-year average trim cycle for laterals.2s These same initiatives, which have provided
storm and day-to-day reliability benefits, remain in place today.
Tree limbs and branches, especially palm fronds, are among the most common causes
of power outages and momentary interruptions during both day-to-day operations and
storm events. The primary objective of FPL's Vegetation Management - Distribution
Program is to clear vegetation in areas where FPL is permitted to trim from the vicinity of
distribution facilities and equipment in order to provide safe, reliable, and cost-effective
electric service to its customers. The program is comprised of multiple initiatives
designed to reduce the average time customers are without electricity as a result of
vegetation-related interruptions. These include preventive maintenance initiatives
(planned cycle and mid-cycle maintenance), corrective maintenance (trouble work and
service restoration efforts), customer trim requests, and support of system improvement
and expansion projects, which focus on long{erm reliability by addressing vegetation that
will impact new or upgraded overhead distribution facilities.
FPL's Vegetation Management Distribution Program's practices follow the NESC, the
American National Standards lnstitute ('ANSl") A-300, and all other applicable standards,
while considering tree species, growth rates, and the location of trees in proximity to FPL's
facilities. Danger or hazard trees (leaning, structurally damaged, or diseased/dead that
have a high likelihood to fail and impact FPL's facilities) located outside of right-of-way
("ROW'), which cannot be trimmed without approval from the property owner, are
identified as candidates for customer-approved removal.
Finally, a very important component of FPL's vegetation program is providing information
to customers to educate them on the company's trimming program and practices, safety
issues, and the importance of placing trees in the proper location - FPL's "Right Tree,
27 See Order No. PSC-06-0351-PAA-EI
28 See Order No. PSC-07-0468-FOF-El
33
Docket No. 20200071-El
FPL's 2O20-2O29 Storm Protection Plan
Exhibit MJ-1 , Page 38 of 48
Right Place" initiative. Right Tree, Right Place is a public education program based on
FPL's core belief that providing reliable electric service and sustaining the natural
environment can go hand-in-hand and is a win-win partnership between the utility and its
customers.
The SPP will continue FPL's currently-approved distribution vegetation program, which
includes the following system-wide vegetation management activities: three-year cycle
for feeders; mid-cycle targeted trimming for certain feeders; six-year cycle for laterals;
and continued education of customers through its Right Tree, Right Place initiative.
b Benefits of the Veqetation Manaoemenf Disfribution
Prog[am
ln Order No. PSC-07-0468-FOF-El, the Commission confirmed that FPL should continue
to implement three-year and six-year average cycles for its feeders and laterals because
the cycles complied with the Commission's storm preparedness objectives to increase
the level of trimming over historical levels, promote system reliability and reduce storm
restoration costs.2s Additionally, Commission's orders indicated that FPL's proposed
cycles: were cost-effective; would improve day-to-day "tree SAlFl" from 0.22to 0.16 in
ten years;3o and would provide savings when comparing savings on a customers
interrupted ("C1") per storm basis. Further, dayto-day distribution tree SAIFI has
significantly improved as a result of FPL implementing its approved distribution vegetation
management program (from 0.20 prior to lhe 2004-2005 storm seasons to 0.08 at year-
end 2019).
Finally, another indication that the current program is providing benefits is that, while
forensic analysis indicated vegetation was the overwhelming primary cause for pole and
wire failures and a significant cause of outages during Hurricanes Matthew and lrma, the
vast majority of damage resulted from uprooted trees, broken trunks, and broken limbs
2s FPL's proposed three-year and six-year cycles were initially approved in Order No. PSC-06-
O7B1-PAA.EI.
30 The tree-related SAIFI has averaged less than 0.09 over the last few years.
34
Docket No. 2O200071-El
FPL's 2O2O-2029 Storm Protection Plan
Exhibit MJ-1, Page 39 of 48
that fell into distribution facilities from outside of right-of-way, i.e., beyond where FPL is
currently allowed trim without approvalfrom the property owner.
2. Actual/Estimated Start and Completion Dates
FPL's ongoing vegetation management plan was originally approved in 2007, and
remains in place today. Under the SPP, FPL plans to inspect and maintain, on average,
approximately 15,200 miles annually, including approximately 11,400 miles for feeders
(cycle and mid-cycle) and 3,800 miles for laterals. This is comparable to the
approximately 15,200 miles inspected and maintained annually, on average, for 2017-
2019.
3. Cost Estimates
The vast majority of vegetation management costs are associated with cycle and mid-
cycle trimming, which is performed by several FPl-approved contractors throughout
FPL's system. Other vegetation management costs include costs associated with day-
to-day restoration activities (e.9., summer afternoon thunderstorms), removals, debris
cleanup, and support (e.g., arborists, supervision, back office support). Costs associated
with vegetation management are generally operating expenses.
The table below provides a comparison of the 2017-2019 total actual distribution
vegetation management costs with the 2020-2022 (first three years of the SPP) total
estimated distribution vegetation management costs and the 2020-2029 total estimated
distribution vegetation management costs:31
Total
Costs
Annual Average
millions m Gosts millions
Further details regarding the SPP estimated distribution vegetation management costs,
31 The vegetation management costs shown in the table below exclude storm-related vegetation
management costs.
P
2017-2019 $1 8e $63
2020-2022 $1 83 $61
2020-2029 $5e6 $60
35
Docket No. 202O0071-El
FPL'I 2020-2029 Storm Protection PIan
Exhibit MJ-1 , Page 40 of 48
including estimated annualcapitalexpenditures and operating expenses, are provided in
Appendix C.32
4. Comparison of Costs and Benefits
As provided in Section lV(G)(3) above, during 2020-2029, totalcosts for FPL's Vegetation
Management - Distribution Program average approximately $60 million per year.
Benefits associated with the Vegetation Management - Distribution Program discussed
in Sections ll and |V(GXI)(b) above, include increased storm resiliency.
5. Criteria Used to Select and Prioritize the Proqram
The primary reason for maintaining feeders on a three-year average cycle, as opposed
to a six-year average cycle for laterals, is that a feeder outage can affect, on average,
approximately 1,500 customers as compared to an outage on a lateral line that can affect,
on average, approximately 35 customers. FPL enhances its approved feeder inspection
and trimming plan through its mid-cycle trimming program, which encompasses patrolling
and trimming feeders between planned maintenance cycles to address tree conditions
that may cause an interruption prior to the next planned cycle trim. Mid-cycle work units
typically have a trim age of 12 to 18 months and usually involve certain fast-growing trees
(e.g., palm trees) that need to be addressed before the next scheduled cycle trim date.
Additionally, customers often contact FPL with requests to trim trees around distribution
lines in their neighborhoods and near their homes. As a result of these discussions with
customers and/or a follow-up investigation, FPL either performs the necessary trimming
or determines that the requested trimming can be addressed more efficiently by
completing it through the normal scheduled cycle trimming.
Cycle trimming is prioritized annually to ensure compliance with cycle schedules. At this
time, FPL has not identified any areas where the Vegetation Management - Distribution
Program would not be feasible, reasonable or practical.
32 See footnote 14.
36
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 41 of 4B
Vegetation Management - Transmission Program
1. Description of the Proqram and Benefits
The Vegetation Management - Transmission Program included in the SPP is a
continuation of FPL's existing transmission vegetation management program. Below is
an overview of FPL's existing transmission vegetation management program and the
associated benefits.
a. Overuiew of the Veqetation Manaqement - Transmission
Proqram
The North American Electric Reliability Corporation's (NERC) vegetation management
standards/requirements serve as the basis for FPL's transmission vegetation
management program. The reliability objective of these standards/requirements is to
prevent vegetation-related outages that could lead to cascading by utilizing effective
vegetation maintenance while recognizing that certain outages such as those due to
vandalism, human errors, and acts of nature are not preventable. Transmission lines that
must conform with these standards/requirements include lines operated at or above 200
kV or any line that is either an element of the lnterconnection Reliability Operating Limit
(IROL) or the Western Electricity Coordinating Council (WECC).
For FPL, just over 4,300 miles of its transmission system (or nearly two-thirds of all of
FPL's total transmission system) are subject to NERC's vegetation management
standards/requirements. NERC's vegetation management standards/requirements
include annual inspection requirements, executing 100% of a utility's annual vegetation
work plan, and to prevent any encroachment into established minimum vegetation
clearance distances ("MVCD').
The key elements of FPL's transmission vegetation management program are to inspect
the transmission right-of-ways, document vegetation inspection results and findings,
prescribe a work plan, and execute the work plan.
FPL conducts ground inspections of all transmission corridors annually for work planning
purposes. During these inspections, FPL identifies vegetation capable of approaching
the defined Vegetation Action Threshold ('VAT"). VAT is a calculated distance from the
H
37
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibii MJ-1, Page 42 of 48
transmission line that factors in MVCD, conductor sag/sway potential, and a buffer. The
identified vegetation is given a work prescription and then prioritized and organized into
batches of work, which collectively become the annual work plan.
For transmission lines that are subject to NERC's vegetation management
standards/requirements, FPL also uses a technology called .L|DAR,' short for light
detection and ranging. LiDAR is a remote sensing technology that uses light in the form
of a pulsed laser to measure ranges (distances) to a target. For vegetation management
purposes, LiDAR is used to measure distance between vegetation and transmission lines.
L|DAR patrols are conducted annually for all NERC transmission corridors. Data
collected by the L|DAR patrols is then used to develop annual preventative and reactive
work plans.
ln its SPP, FPL will continue its current transmission vegetation management plan, which
includes visual and aerial inspections of all transmission line corridors, LiDAR inspections
of NERC transmission line corridors, developing and executing annual work plans to
address identified vegetation conditions, and identifying and addressing priority and
hazard tree conditions prior to and during storm season.
b. Benefits of the Veqetation Manaqement - Transmission
Proeram
The benefits of a Vegetation Management - Transmission Program are self-evident and
the consequences of not having a reasonable transmission vegetation management plan
can be extreme. As discussed previously, the transmission system is the backbone of
the electric grid. While outages associated with distribution facilities (e.9., a transformer,
lateral, or feeder) can result in an outage affecting anyruhere from a few customers up to
several thousands of customers, a transmission related outage can affect tens of
thousands of customers. Additionally, an outage on a transmission facility could cause
cascading and result in the loss of service for hundreds of thousands of customers. As
such, it is imperative that vegetation impacting transmission facilities be properly
maintained using reasonable and appropriate cycles and standards to help ensure they
are prepared for storms. For these reasons, it is no surprise that NERC has developed
38
Docket No. 2020OO71-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1 , Page 43 of 48
prescriptive vegetation management requirements for transmission facilities to help
prevent such damage from occurring.
FPL also notes that while vegetation-related damage and transmission line outages
occurred during Hurricanes Matthew and lrma, the vast majority of such
damages/outages were caused by vegetation located outside of the right-of-way, i.a.,
beyond where FPL is currently allowed to trim without approval from the property owner,
which further demonstrates that FPL's historical efforts in this area have been beneficial.
2. Actual/Estimated Start and Completion Dates
FPL's Vegetation Management - Transmission Program is an ongoing program, initiated
decades ago. Under the SPP, FPL plans to inspect and maintain, on average,
approximately 7,000 miles annually, including approximately 4,300 miles for NERC
transmission line corridors and 2,700 miles for non-NERC transmission line corridors.
This is comparable to the approximately 7,000 miles inspected and maintained annually,
on average , for 2017-2019.
3. Cost Estimates
The vast majority of vegetation management costs are associated with annual inspections
and the execution of planned work to address identified conditions, which is performed
by several FPL approved contractors throughout FPL's system. Other vegetation
management costs include costs associated with day-to-day restoration activities (e.9.,
summer afternoon thunderstorms), removals, debris cleanup, and support (e.9., arborists,
supervision, back office support). Costs associated with vegetation management are
generally operating expenses.
The table below provides a comparison of the 2017-2019 total actual transmission
vegetation management costs with the 2020-2022 (first three years of the SPP) total
estimated transmission vegetation management costs and the 2020-2029 total estimated
transmission vegetation management costs:s3
33 The vegetation management costs shown in the table below exclude storm-related vegetation
management costs.
39
2017-2019 $27 $e
$g2020-2022 $2t
2020-2029 $e6 $10
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 44 of 48
Total Annual Average
P ram Gosts millions ram Costs illions
Further details regarding the SPP estimated transmission vegetation management costs,
including estimated annualcapitalexpenditures and operating expenses, are provided in
Appendix C.3a
4. Comparison of Costs and Benefits
As provided in Section lV(H)(3) above, during 2020-2029, totalcosts for FPL's Vegetation
Management - Transmission Program average approximately $10 million per year.
Benefits associated with the Vegetation Management - Transmission Program discussed
in Sections ll and |V(HX1)(b) above, include increased storm resiliency. The execution
of FPL's Vegetation Management - Transmission Program is a significant factor in
mitigating damage to transmission facilities and avoiding transmission-related outages.
5. Criteria used to Select and Prioritize the Programs
Priority vegetation conditions and hazard tree conditions are completed annually prior to
storm season. Additionally, prior to and during the storm season, FPL conducts aerial
inspections of transmission corridors to identify hazard trees and any priority vegetation
locations. Priority vegetation conditions and hazard tree conditions identified through
aerial inspections are addressed as soon as possible.
At this time, FPL has not identified any areas where the Vegetation Management -
Transmission Program would not be feasible, reasonable or practical.
34 See footnote 14
40
Docket No. 20200071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , Page 45 of 48
V. Detailed lnformation on the First Three Years of the SPP
(2020-20221
A. Detailed Description for the First Year of the SPP (20201
The following additional information required by Rule 25-6.030(3)(e)(1), F.A.C., for the
first year of the SPP (2020) is provided in Appendix E. (1) the actual or estimated
construction start and completion datesi e) a description of the affected existing facilities,
including number and type(s) of customers served, historic service reliability performance
during extreme weather conditions, and how this data was used to prioritize the storm
protection projects; (3) a cost estimate including capital and operating expenses. A
description of the criteria used to select and prioritize the storm protection programs is
included in the description of each SPP program provided in Section lV.
Detailed Description of the Second and Third Years of the
sPP (2021-20221
B-
Additional details required by Rule 25-6.030(3XeX2), F.A.C., for the second and third
years of the SPP (2021-2022), including the estimated number and costs of projects
under every program, is provided in in Appendix C.
Detailed Description of the Vegetation Management
Activities for the First Three Years of the SPP (2020-20221
The following additional information required by Rule 25-6.030(3X0, F.A.C., for the first
three years of the vegetation management activities under the SPP (2020-2022) is
provided in n Sections lV(G) and IV(H) above and Appendix C: the projected frequency
(trim cycle); the projected miles of affected transmission and distribution overhead
facilities; the estimated annual labor and equipment costs for both utility and contractor
personnel. A description of how the vegetation management activities will reduce outage
times and restoration costs due to extreme weather conditions is provided in Sections
lV(G) and lV(H) above.
c
41
Docket No. 20200071-El
FPL's 2020-2029 Slorm Protection PIan
Exhibit MJ-1 , Page 46 of 48
Vl. Estimate of Annual Jurisdictional Revenue Requuementq
for the 2020-2029 SPP
Pursuant to Rule 25-6.030(3Xf), F.A.C., the table below provides the estimated annual
jurisdictional revenue requirements for each year of the SPP.
Estimated Annual
Revenue
Requirements
illions
While FPL has provided estimated costs by program as of the time of this filing and
associated total revenue requirements in its SPP, consistent with the requirements of
Rule 25-6.030, F.A.C., subsequent projected and actual program costs submitted for cost
recovery through the Storm Protection Plan Cost Recovery Clause (per Rule 25-6.031,
F.A.C.,) could vary by as much as 10-15%, which would then also impact associated
estimated revenue requirements and rate impacts. The projected costs, actual/ estimated
costs, actuals costs, and true-up of actual costs to be included in FPL's Storm Protection
2020 $257.6
2021 $369.1
2022 $494.3
2023 $625.5
2024 $760.e
2025 $878.1
2026 $963.7
2027 $1,037.1
2028 $1,110.9
$1 ,185.22029
42
Docket No. 20200071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 47 of 48
Plan Cost Recovery Clause will all be addressed in subsequent filings in separate storm
protection plan cost recovery clause dockets pursuant to Rule 25-6.031, F.A.C.35
Vll. Estimated Rate lmpacts for First Three Years of the SPP
(2020-20221
FPL anticipates the programs included in the SPP will have zero bill impacts on customer
bills during the first year of the SPP and only minimal bill increases for years two and
three of the SPP. An estimate of hypothetical overall rate impacts for the first three years
of the SPP (2020-2022), without regard for the fact that FPL remains under a general
base rate freeze pursuant to a Commission-approved settlement agreement through
December 31,2021, as stated in footnote 36 below are based on the total program costs
reflected in this filing.36 The projected costs, actual/estimated costs, actuals costs, and
true-up of actual costs to be included in FPL's Storm Protection Plan Cost Recovery
Clause will all be addressed in subsequent filings in Storm Protection Plan Cost Recovery
Clause dockets pursuant to Rule 25-6.031, F.A.C.37
Pursuant to Rule 25-6.031, F.A.C., FPL has not identified any reasonable implementation
alternatives that could mitigate the resulting rate impact for each of the first three years
of the SPP. As explained above, FPL's SPP is largely a continuation of existing
Commission-approved storm hardening programs and initiatives, which have already
demonstrated that they have and will continue to provide increased T&D infrastructure
resiliency, reduced restoration time, and reduced restoration costs when FPL's system is
impacted by severe weather events. Further, as explained above, the estimated costs
35 The Commission has opened Docket No. 20200092-El to address Storm Protection Plan Cost
Recovery Clause petitions to be filed the third quarter o'f 2020.
36 Pursuant to Rule 25-6.030(3)(h), F.A.C., the hypothetical rate impacts for FPL's typical
residential, commercial, and industrial customers for the first three years of the SPP (2020-2022)
without regard for the fact that FPL remains under a general base rate freeze pursuant to a
Commission-approved settlement agreement through December 31, 2021, are as follows for
2020, 2021, and 2022, respectively: Residential (RS-1) $0.00251/kwh, $0.00357/kwh, and
$0.00478/kWh; Commercial (GSD-1) $0.81/kW, $1.1s/kw, and $1.54/kW; and lndustrial
(GSLDT-3) $0.05/kW, $0.08/kW and $0.1O/kW. These rate impacts are for all programs included
in the SPP and are based on the total estimated costs as of the time of this filing, which could
vary by as much as 10% lo 15ok, regardless of whetherthose costswill be recovered in FPL's
Storm Protection Plan Cost Recovery Clause or through base rates.
37 See footnote 34.
43
Docket No. 2O200071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 48 of 48
for the programs included in FPL's SPP are consistent with the historical costs incurred
for the existing storm hardening and storm preparedness programs, which were most
recently approved in FPL's 2019-2021Storm Hardening Plan.
Vlll. Gonclusion
The Florida Legislature has determined that it is in the State's interest to "strengthen
electric utility infrastructure to withstand extreme weather conditions by promoting the
overhead hardening of distribution and transmission facilities, undergrounding of certain
distribution lines, and vegetation management," and for each electric utility to "mitigate
restoration costs and outage times to utility customers when developing transmission and
distribution storm protection plans." Section 366.96(1), F.S. Based on these findings, the
Florida Legislature concluded that it is in the State's interest for each electric utility to
develop and file a SPP for the overhead hardening and increased resilience of electric
T&D facilities, undergrounding of electric distribution facilities, and vegetation
management. See Sections 366.96(1)-(3).
FPL's SPP is a systematic approach to achieve the legislative objectives of reducing
restoration costs and outage times associated with extreme weather events and
enhancing reliability. As explained above, FPL's SPP is largely a continuation and
expansion of its existing and already successful storm hardening and storm preparedness
programs previously approved by the Commission, as well as a new storm hardening
program to harden certain targeted substations that are susceptible to storm surge or
flooding during extreme weather events. Based on the recent experiences of Hurricanes
Matthew and lrma, the existing storm hardening programs have a demonstrated and
proven track record of mitigating and reducing restoration CMH, outage times, and storm
restoration costs, as well as improving day-to-day reliability. FPL's SPP will continue and
expand these important benefits to customers and the State.
44
Docket No. 20204071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 1 of 18)
APPENDIXA
(FPL's 3rd Supplemental Amended Response to
Staffs lst Data Request)
Docket No. 20200071-El
F PL's 2o2o-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX A (Page 2 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page I of9
QUESTION
Please complete the table below summarizing hardened facilities that required repair or
replacement as a result of Hurricanes Matthew, Hermine, Irma, Maria, and Nate.
RESPONSE:
FPL does not maintain its accounting records at the level of detail required to provide the
requested information as they do not differentiate hardened facilities from non-hardened
facilities, nor do they track which assets were repaired. However, FPL does track certain assets,
at the total system level, that were requested and replaced during each hurricane as reflected in
the tables below. Note, FPL did not track storm repairs/replacements for Hurricanes Maria and
Nate as Hurricane Maria did not impact FPL's service territory and Nate had limited impact.
Also, Hurricanes Matthew and Irma capital details associated with follow-up work are not yet
available by plant account as these costs have not yet been unitized from account 106 to account
101 by plant account.
Hurricane Matthew Number of Facilities Requiring
Repair Replacement
Transmission
Structures N/A 0
Substations N/A 0
Total N/A 0
Distribution
Poles N/A 656
Substation N/A 0
Feeder OH N/A 0
Feeder UG N/A 0
Feeder Combined N/A 0
Lateral OH N/A N/A
Lateral UG N/A N/A
Lateral Combined N/A N/A
Total N/A N/A
Service
Service OH N/A N/A
Service UG N/A N/A
Service Combined N/A N/A
Total N/A N/A
Docket No. 20200071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 3 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page2 of9
Hurricane Hermine Number of Facilities Requiring
Repair Replacement
Transmission
Structures N/A 0
Substations N/A 0
Total N/A 0
Distribution
Poles N/A I9
Substation N/A 0
Feeder OH N/A 0
Feeder UG N/A 0
Feeder Combined N/A 0
Lateral OH N/A N/A
LateralUG N/A N/A
Lateral Combined N/A N/A
Total N/A N/A
Service
Service OH N/A N/A
Service UG N/A N/A
Service Combined N/A N/A
Total N/A N/A
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 4 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 3 of 9
Huruicane Irma Number of Facilities Requiring
Repair Replacement
Transmission
Structures N/A 0
Substations N/A 0
Total N/A 0
Distribution
Poles N/A 3 )5 62
Substation N/A 0
Feeder OH N/A 0
Feeder UG N/A 0
Feeder Combined N/A 0
Lateral OH N/A N/A
Lateral UG N/A N/A
Lateral Combined N/A N/A
Total N/A N/A
Service
Service OH N/A N/A
Service UG N/A N/A
Service Combined N/A N/A
Total N/A N/A
Notes:
For Hurricane Matthew, there is a difference of 248 poles between what is provided in this
discovery response for total poles replaced (656 poles) and what is provided in FPL's post-storm
forensic review report for Hunicane Matthew (provided in FPL's response to Staff s Second
Data Request No. 2 in this same docket) for poles that failed and needed to be replaced to restore
seruice (408 poles). The difference is associated with poles replaced during "follow-up" - i.e.,
poles that were damaged (e.g., a cracked pole) as a result of the storm and needed to be replaced
to restore the pole to its pre-storm condition - but did not fail during the storm and, thus, did not
need to be replaced to restore service. As mentioned above in FPL's response to this data
request, FPL's accounting records do not differentiate hardened facilities from non-hardened
facilities and FPL did not track or maintain forensic information on the 248 distribution poles
replaced as a result of follow-up work. As a result, FPL does not have a hardened vs. non-
hardened breakdown for the 248 distribution poles replaced during follow-up work.
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX A (Page 5 of 18)
X'lorida Power & Light Company
Docket No. 20170215-EU
Staff s First Data Request
Request No. 29 - Third Supplemental Amended
Page 4 of9
The distribution pole and transmission structure counts provided above represent the amount of
pole/structure replacements FPL has recorded on its books and records associated with Hurricane
Irma as of December 3 I , 20 I 7. These amounts should be considered prelimin ary at this time as
they are subject to change (e.g., the counts do not reflect poles that will be replaced during
follow-up work, which has yet to be completed).
N/A - Information is not available at this level of detail in FPL's accounting records
For substations and feeders, FPL has stated 0 since no entire substation or feeder was replaced.
However, these facilities consist of many pieces of equipment (e.g., wire, cable, breakers,
transformers, cross arms and arrestors) some of which may have been replaced.
20L 6/201 7 Hurricanes - FPL Restoration/Infrastructure Performance
FPL's infrastructure/restoration performance for Hurricanes Matthew (2016) and Irma (2017)
demonstrates that the implementation and execution of its FPSC-approved (1) ten storm
preparedness initiatives (which includes vegetation management): (2) pole inspection programs;
(3) storm hardening plans; and (4) tariffs to incent municipal overhead to underground
conversions have provided great benefits to FPL's customers and to the State of Florida.
During 2016 and 2017, FPL's service teruitory was threatened with massive Category 4 and 5
storms. The size and scale of these storms impacted FPL's infrastructure throughout its entire
service territory (which encompasses 35 counties in the State of Florida). For both Matthew and
Irma, FPL's infrastructure storm resiliency and smart grid investments resulted in improved
infrastructure resiliency performance and reduced restoration times.
2016/2017 Hurricanes - Restoration Performance
FPL saw significant improvements in overall restoration results. As can be seen in the table
below, restoration results for Hurricanes Matthew and Irma show significant improvement vs.
Hurricane Wilma. FPL attributes these significant improvements in restoration to the investments
made to make its system smarter and more storm-resilient as well as its well-tested restoration
processes. This includes FPL's distribution and transmission storm hardening and storm
preparedness initiatives, pole inspection programs, smart grid initiatives, vegetation management
programs and continuous efforts to improve its restoration processes.
Customer Outases 3.2M 1.2M 4.4M
% Restored / davs s0%ls 99%/2 s0% 17
All restored / davs 18 4 10
Avs. to restore / davs 5.4 <1"2.r
Docket No. 2020O071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 6 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 5 of 9
201612017 llurricanes -frasfrucfrr re Performance
To assess the effectiveness of FPL's infrastructure storm hardening investments, the Company
utilizes information collected through post-storm forensic data collection and various systems
(e.g., FPL's outage management system) to conduct post-storm infrastructure performance
analysis. These efforts and analysis allow FPL to quantify and assess its distribution and
transmission infrastructure performance including the performance of: hardened and non-
hardened facilities; overhead and underground facilities; and smart grid performance. For
distribution, this includes reviewing the storm performance of poles, feeders and laterals. For
transmission, this includes reviewing the storm performance of poles/structures, line sections
and substations. The data demonstrates that hardened infrastructure performed better than non-
hardened infrastructure, underground facilities performed better than overhead facilities and
smart grid devices prevented a significant number of outages from occurring.
Distribution/Transm ission les/ Strrrctrr res Performance
The performance of FPL's approximately 1.2 million distribution and transmission
poles/structures during Hurricanes Matthew and Irma was excellent, as hardened poles and
structures performed as expected by minimizing outages and reducing restoration times. The
total number of distribution/transmission poles that failed (i.e., had to be repaired/replaced in
order to restore service) during Hurricanes Matthew and Irma was a mere fraction of lo/o of the
1.2 million pole/structure pole population.
Additionally, hardened distribution and transmission pole performance was significantly better
than non-hardened pole performance, as hardened pole failures were either non-existent (e.g.,
Hurricane Matthew) or significantly less than non-hardened pole failures (e.9., during Huricane
Irma, hardened feeder poles had a 0.02o/o failure rate, while non-hardened feeder poles had a
0.20% failure rate). Also, total poles replaced (i.e., poles that failed * poles that were replaced
during follow-up work) were also a mere fraction of lYo of the total pole population and
significantly less than the number of poles replaced during Huricane Wilma.
FPL notes that for Hurricanes Matthew and Irma, while it did track hardened vs. non-hardened
pole performance during restoration, it did not track poles replaced (hardened vs. non-hardened)
during follow-up work, since these poles had accomplished their intended purpose of not failing
during the storms. Therefore, FPL cannot provide the number of hardened poles replaced during
follow up work in Hurricanes Matthew and lrma. Based on the performance of hardened poles
that failed during these storms (see table below), it is highly unlikely that there would be a
significant number of hardened poles, if any, that needed to be replaced during follow-up work.
However, going forward, should the Commission want FPL to track replacement of hardened
vs. non-hardened poles during follow-up work, FPL will begin to track this information.
FPL attributes this excellent pole performance to its FPSC-approved distribution and
transmission storm hardening plan initiatives (e.g., extreme wind load construction standards for
distribution poles and replacing wood transmission poles/structures) and its pole inspection
programs.
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX A (Page 7 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 6 of9
Distribution P oles l2l3 I I 17
TotalNumber
TotalHardened
1,188,202
124,518*
x This number is understated as it includes only poles hardened as a result of FPL's approved
hardening plan projects, as FPL does not track or maintain the number of hardened poles
installed as a result of new construction (e.g., new feeders or laterals) andlor daily work activities
(e.g., maintenance, pole line extensions, relocation projects). There are also other existing poles
throughout FPL's service territory that would currently meet the NESC's extreme wind loading
criteria and therefore qualif,, as a hardened pole, however, FPL does not currently track or
maintain that information.
Distribution Pole Failures*Hardened
Non-
Hardened Total
Matthew - 2016 0 408 408
lrma - 2Ot7 26 2834 2860
*Broken/Fallen poles that must be repaired/replaced to restore service
Transmission Pole/Structures 12l3 l/l 7
Total 66,685
Concrete 60,694 (91%)
Wood 5,991 (9%)
Transmission Pole Failures*Hardened
Non-
Hardened Total
Matthew - 2015 0 0 0
lrma -2Ot7 0 E 5
*Broken/Fallen poles that must be repaired/replaced to restore service
Distribution Feeders/Laterals Performance
As demonstrated below, FPL's hardened feeders performed significantly better than non-
hardened feeders and underground feeders/laterals performed significantly better than overhead
feeders/laterals. Performance was compared considering feeder and lateral outages that occurred
during Hurricanes Matthew and Irma. It is also important to note that during Hurricane Irma, the
Construction Man Hours ("CMH") to restore hardened feeders was 50% less than non-hardened
feeders, primarily due to hardened feeders experiencing less damage than non-hardened feeders.
It is important to note that the majority of outages for overhead facilities resulted from trees that
broke andlor fell into FPL's facilities. Many of these trees were outside of easements or public
rights of way where FPL is generally allowed to trim. As a result, no additional amount of
Docket No. 2020O071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-'l , APPENDIX A (Page B of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
PageT of9
traditional tree trimming would help mitigate this issue. Tree damage was particularly impactful
on FPL laterals.
The two tables below provide feeder and lateral outage performance statistics for Hurricanes
Matthew and hma.
Pop: Population; Lateral population includes laterals with multi-stage lusing
Pop: Population; Lateral population includes laterals witli rnulti-stage fusing
FPL notes that, overall, for Hurricane Irma, many more laterals experienced outages compared to
feeders, thus laterals required significantly more time to restore (871,000 CMH) compared to
feeders (170,000 CMH). FPL continues to promote its Right Tree Right Place initiative and
recommends there be changes to state laws and/or local ordinances to restrict the type and
location of trees and provide utilities additional trimming rights to address existing tree
conditions.l
Additionally, FPL notes that day-to-day, hardened feeders perform approximately 40%o better
than non-hardened feeders.
Transmission Line S hstafions Performance
The transmission system's performance was excellent during Hurricanes Matthew and Irma.
Equipment and conductor damage was minimal as a result of our investments in transmission
hardening and the installation of flood monitoring equipment in those substations located in
flood prone areas. Substations that experienced outages were restored in one day. During
Hurricanes Matthew and Inna, flood monitoring equipment operated as expected, providing
notification which allowed FPL to proactively de-energize three substations (one in Matthew and
two in Irma) and prevent potential serious damage from occurring at these substations.
I Whele municipalities ale not actively engaged in ensuring appropriate limitations on planting trees in public rights
of way, restoration efforts are impeded and made more costly. In fact,_one particular municipality is actively
planting "wrong trees in the wrong place," in spite of FPL's direct communications and efforts to encourage its
Right Tree Right Place initiative.
Matthew
Overhead non-Hardened
Overhead
Hardened Underground Total
Out Pop
Yo
Out Out Pop
%
Out Out Pop
%
Out Out Pop %Out
Distribution Feeders 280 2,031,1,4%68 t27 9o/o 1.1.493 359 3,245 13%
Distribution Laterals 3,473 82,729 4%N.A N.A.N.A.238 101,892 0.2o/o 3,711.1,84,621 2%
rRMA- 2017
Overhead Non-Hardened
Overhead
Hardened Underground Total
Out Pop
To
Out Out Pop
o/o
Out Out Pop
%
Out Out Pop
%
Out
Disfiibution Feeders 1,609 1,958 82%592 859 69%a(410 TB%2,286 3,281 t0%
Distribution Laterals 20,34r 84,574 24%N.A.N.A N.A.3,167 103,384 4%24,108 187,958 t3%
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page I of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 8 of9
The tables below provide substation line section outage performance for Hurricanes Matthew
and Irma.
* 2 sections were out because substation was proactively de-energized due to flooding** 4 sections were out because substations were proactively de-energized due to flooding
*** No underground section was damaged or failed causing an outage; however, the sections were out due to line
termination equipment in substations.
The table below compares substation outage and restoration performance - Irma vs, Wilma.
Smart Grid Performance
During Hurricane Matthew and Irma, smart grid devices prevented a significant amount of
customer outages, assisted with restoration efforts and reduced restoration time and costs.
Specifically, automated feeder switches avoided approximately 664,000 outages during
Hurricanes Matthew and Irma. Additionally, FPL's restoration crews are able to "ping" smart
meters before leaving an area to ensure that power is, in fact, restored. This prevents restoration
crews from leaving an area, thinking all power was restored, only to be called back when the
customer informs FPL that they are still without service. FPL is also enhancing an application,
first utilized during Huricanes Matthew and Irma, whereby it will be able to "bulk meter ping"
smart meters to confirm whether customers have service.
Trans, Line Sections 16 350 5%23*846 36/"0 49 0%39 1,245 3o/o
ciVr !tl il. ):i.'l
'l,irtit l,lrrl,:ri
:l
jl
I
l l:iii"lrrij:li'.]|!|t(:
',.i Iiii
li
ii
'r,.
(,Jr lrilt\ilrl\ t, r:1ir:tl .;lr:l lta,.( )fri :a.l!li
irii ii rl I
i
1a)r fi'l ,.;il
'1rlr1.11rii:1:ici llrjii ii t: :lililirilf
)tt
(lI r t,
T,,
a)rt/
')
titli l
'1 :'/.
Trans. Line Sections 60 306 20%r42**884 L6%13***51 25o/o 2r5 L24I t7%
:
lr!ii:lq I
'),,
'(,)t f
111ri1.r7if 11r-11 i t"iri"h'il,!.i,
, :.1
I ii trriilt,.lf,lJr tif il 'I r.1 itr Il
l:.il.yrLr\ i".l 1.1 .:r,,
,(:)r I i.i( )r,l i ''. |,i,).r)rt
'
(l! i :\ .r/( ir.i
,r r(:),rr.jf ii-tt:1,',t)ll.)il,l I ili'r
,{)rit, 'r :iJll
De-energized 24r 92
Restored (Davsl 5 7
Matthew - 2016 118,000
lrma - 2Ot7 546,000
'\ i r)r Li : i:' '. I t ;'.'iii ;. r'
il
..\v()i:.tf !tl
;'i-!t.Lii!tIrii!
Docket No. 2O200071-El
FPL'' 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 1 0 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 9 of 9
Estimate of Storm Restoration Cost Savinss Due to Hardenins hased on Storm Damase
Model Simulation
The attached analysis provides an estimate of transmission and distribution storm restoration
savings for Hurricanes Matthew and Irma that resulted from storm hardening completed by FPL
prior to the storms' impacts. To calculate these savings, FPL utilized its Storm Damage Model
(the same model FPL utilizes to estimate damage when a storm approaches FPL's service
teritory) to simulate damage that likely would have occured without hardening and determine
the associated required construction man hours (CMH) that would have been required to restore
service in the absence of hardening, days to restore in the absence of hardening and associated
incremental restoration costs. Additionally, FPL calculated the 4}-year net present value of these
savings for two scenarios - (1) a similar storm occurs every 3 years; and (2) a similar storm
occurs every 5 years.
As indicated on the attached analysis, the 4O-year net present values of the savings related to
storm hardening are significant. In the absence of hardening the estimated percentage increase in
CMHs for Hurricane Matthew and Hurricane Irma restoration would have been significantly
higher (36%o and 40o/o, respectively), days to restore would have been increased (50o/o and 40Yo,
respectively) and restoration costs would have been greater (36Yo and 400lo, respectively).
Florida Power & Light Company
Docket No. 2OI7O2L5-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No- 1
Tablof5
Docket No. 20200071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX A (Page 11 of 18)
Estimate of Storm Restoration Cost Savings Due to Hardenins based on Storm Damase Model Simulation
tll I2l I31
Cons-truction Man-Hours
t4l lsl I61 I7l
to Restore
l8l tel [10] [111
Storm Restoration Costs
lt2l
% Increase
without
Hardening
360/"
40%
Additional
Storm
Restoration
Costs
without
Hardenins
s105
s496
Modeled
System
without
Hardening
s39s
s7.722
Actual
s290
s7.226
[ 131
40 Yr NPV
[141
Storm
Matthew
lrma
% lncrease
without
Hardening
36%
40%
Additional
CMH
without
Hardening
93.000
483.000
Modeled
System
Without
Hardening
350.000
1.578.000
Actual
257.000
1.195.000
Notes:
All costs and CMH are Transmission and Distribution only, and exclusive of follow-up work
[ 1 I Calculated based on actual storm restoration requirements
[2] FPLstormdamagemodelsimulationresultsofCMHincurredwithouthardening
[ 3 I Additional CMH without hardening (Col. 2 - Col. 1]
[4] Percent increase in CMH without hardening (Col. 3/Col. 1)
[ 5 ] Actual days to restore service
[ 6 I Storm damage model simulation result ofthe days to restore seruice without hardening (assumes same restoration resources as actual)
[ 7 ] Additional days to restore without hardening (Col. 5 - Col. 5)
[ 8 I Percent increase in days to restore without hardening (Col.7/Col.5)
[ 9 I Actual cost of restoration._[Ml9gls_elellglilqil3ty
[ 10 I Storm damage model simulation result of restoration costs without hardening
[ 11 I Additional restoration costs without hardening (Col. 10 - Col.9)
[12] Percentincreaseinrestorationcostswithouthardening((Col.LL/Col.9)
[ 13 ] 40 year net present value savings assuming a similar storm everylhlee years (calculation details attached)
[ 14 I 40 year net present value savings assuming a similar storm everyjyqyears (calculation details attached)
Yo lncrease
without
Hardening
50%
40%
Additional
Days to
Restore
without
Hardening
z
4
Modeled
System
Without
Hardening
5
1,4
Actual
4
10 s1.91s
Savings Every
40 Yr NPV
5 Years
(2017s)
S4o6
53,082
40 Yr NPV
Savings Every
3 Years
(2017s)
s6s3
Docket No. 20200071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 12 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1
Tab2of5
Estimated Storm Restoration Costs Savings due to Hardening (SMM)
40-Year NPV (20175)
Matthew Savings
Everv 3 vears Everv 5 vears
$6s3 $406
Discount Rate = 7.76%
1
2
3
4
5
6
7
8
9
10
L1"
12
13
t4
15
1.6
L7
18
19
20
2L
22
23
24
25
26
27
$10s
$o
So
S113
5o
So
Srzr
So
So
$130
$o
So
s13e
So
So
slso
So
So
S161
$o
so
S173
so
So
$18s
$o
So
cPt
Multiplier
1.000
1.024
1.049
1.076
1.105
1124
1.152
1.179
1.206
1.233
1.260
1.288
1.317
1.346
1.375
1.404
1.434
1.464
1.495
1.526
1.558
1.590
1.623
1.656
1.691
1.727
1.763
Matthew
Slos
S107
S110
S113
S1ls
Si_i_8
Si-21
5r24
$127
$r.30
S133
Si.36
s13e
S143
S146
Si.so
Sl_s3
$1s7
Si-61
S16s
s16s
Si_73
5177
S181
Slss
Si.eo
Srg+
$510
Slso
$o
So
So
so
So
So
So
so
s]-so
$o
cPt
2.1%
2.4%
2.40/o
2.6%o
2.7%
L.7%
2.5%
2.4%
23%
2.2%
2.2%
2.2%
2.2%
2.2%
2.2%
2.1%
2.L%
2.r%
2.L%
2.L%
2.r%
2.L%
2.L%
2.1%
2.r%
2.r%
2.t%
$o
So
so
So
18
So
So
$o
SO
33
so
So
So
so
$r
s1
69$r
Year
Matthew Savings
Everv 3 vears Everv 5 vears
Docket No. 2O2OO071-E\
FPL'S 2O2O-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 13 of 1 B)
28
29
30
31
32
33
34
35
36
37
38
39
40
Si_e9
So
SO
Sztq
so
so
S23o
So
So
S24G
2.r%
2.2%
2.2%
2.r%
2.2%
2.L%
2.L%
2J%
2.1%
2.1%
21%
2.L%
2.t%
1.801
1.840
1.880
1.920
1.962
2.004
2.047
2.090
2.135
2.180
2.226
2.274
2.322
Slse
S204
S2os
S214
$zre
5224
s230
s23s
524L
5246
$2s2
$2s8
s26s
So
5o
so
$zM
So
So
So
So
So
$o
S26s
$24L
So
$o
So
So
NPV (2017s)S6s3 $406
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX A (Page 14 of 1B)
Florida Power & Light Company
Docket No. 201-70215-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1
Tab3of5
Estimated Storm Restoration Costs Savings due to Hardening (SMM)
40-Year NPV (2017S)
lrma Savings
Everv 3 vears Everv 5 vears
s3,082 51,915
Discount Rate =7.760/o
96s4T
2
3
4
5
6
7
8
9
10
TT
L2
13
t4
15
16
tl
18
t9
20
2L
22
23
24
25
26
2l
So
So
ss32
So
So
Ss71
$o
$o
S613
so
so
S6se
$o
So
S107
So
So
sTss
$o
$o
Ssls
$o
$o
s876
$o
So
s4e6
$o
So
$o
So
$sss
So
$o
$o
$o
s628
so
So
$o
So
5707
So
So
$o
$o
S7s6
So
So
So
$o
s8s7
So
cPl
Multiplier
1.000
1.024
1.049
1.076
1 .105
1.124
1.152
1.179
1.206
1.233
1.260
1.288
1.317
1.346
1.375
1.404
1.434
1.464
1.495
1.526
1.558
1.590
1.623
1.656
1.691
1.727
1.763
cPl lrma
s4e6
SsoT
Ss20
ss32
Ss4s
Sss8
$s71
Ssss
$ses
S613
s628
S643
$6se
5674
s6e1
5io1
5724
$742
$zsg
S77s
$7e6
Ssls
s83s
Ssss
$876
S8s7
Ss18
21%
2.4%
2.4%
2.6%
2.7%
1.7%
2.5%
2.4%
23%
2.2%
2.2%o
2.2%
2.2%
2.2%
2.2o/o
2.1%
2.L%
2.1%
2.1%
2.t%
2.r%
2.1%
2.1%
2.1%
2.L%
2.r%
2.1%
Year
Matthew Savings
Everv 3 vears Everv 5 vears
Docket No. 2O200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 15 of I B)
s1,
28
29
30
31
32
33
34
35
36
37
38
39
40
Ss4o
So
So
s1,oo9
So
So
S1,084
So
$o
So
so
$t,zso
2.r%
2.2%
2.2%
2.L%
2.2%
2.L%
2.L%
2.ro/o
2.1%
2.t%
2.r%
21%
2.I%
1.801
1.840
1.880
1.920
1.962
2.004
2.047
2.090
2.135
2.180
2.226
2.274
2.322
se4o
$963
se85
S1,oo9
Sr,og+
Si.,058
s1,084
$1,110
$1,136
s1,164
$L,192
5L,z2o
s1,2s0
5o
$o
So
s1,009
S1,136
So
so
So
5o
so
So
So
So
\64
NPV (2017$)S3,082 S1,gts
Docket No. 20200071-El
FPL'' 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 16 of 1B)
Florida Power & Light Company
Docket No. 2017021"5-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1
Tab4of5
FPL
WEIGHTED AVERAGE COST OF CAPITAL
STATE INCOME TAX
FEDERAL INCOME T
5.50%
21.jjo/o
COMPOSITE INCOME TAX RAT 25.35O/O
MODEL DATE 1 -Jan-1 8
Debt Cost Based on Blue Chip Corporate Aaa and Bbb Bonds
AFTERTAX PRETAX
SOURCE /VEIGHT(1) COST(2)/TD COST /TD COST /TD COST
DEBT
COMMON
4O.40o/o
59.60%
4.88o/o
10.55%
1.97o/o
6.29%
1.47%
6.290
1.97%
8.42%
TOTAL 100.00%8.260/o 7.76% 10.39%
AFTER-TAX WACC 7.760/r
Docket No. 2O2OOO71-E\
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 17 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No, L
Tab5of5
Consu mer Prices (1982-84=1.000) All-U rban
(Forecast adjusted to match budget assumptions)
lndex % Change
2009 2.L454
2010 2.1805 1.64%
20L1. 2.2494 3.1,6%
2012 2.2959 2.Ot%
2013 2.3296 1.46%
2014 2.3614 1,.62%
2015 2.3702 0.12%
2A16 2.4001. L26%
2077 2.4512 2.t3%
2018
20t9
2020
2021,
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
204L
2042
2043
2044
2045
2046
2.5100
2.5703
2.6311.
2.7083
2.7553
2.8231
2.8909
2.9569
3.0228
3.089s
3.1573
3.2270
3.2981
3.3693
3.44rt
3.51.42
3.5887
3.6642
3.7408
3.8187
3.8972
3.9719
4.0603
4.1449
4.2324
4.3226
4.41.s3
4.5t04
4.6077
2.40%
2.40%
2.60%
2.70%
L.73%
2.46%
2.40%
2.28%
2.23%
2.2I%
2.I9%
2.2L%
2.20%
2.1.6%
2.13%
2.r2%
2.12%
2.LO%
2.09%
2.08%
2.06%
2.O70/o
2.07%
2.O8%
2.It%
2.r3%
2.L5%
2.1.5%
2.1.6%
Budget Assumptions
2.40%
2.40%
2.60%
2.70%
Docket No. 2O200071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 18 of 1B)
2047
2048
4.7067
4.8099
2.ts%
219%
2049
2050
2051
2052
2053
2054
2055
20s6
2051
4.9122
5.0167
5.1233
5.2323
5.3435
5.4572
5.5732
5.6917
5.8128
2.13o/o
2.L3%
2.L3%
2.t3%
2.13o/o
2.r3%
2.t3%
2.13%
2.13%
Actuals thru 2OL7 from BLS
APPENDIX
(FPL's Management l
iGi)
iill !
I
I
I
:
f:!ll.nyr
t
AI
l-s-:
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-'l, APPENDIX C (Page 1 of 2)
APPENDIXC
(FPL' s 2020-2029 Estimated SPP Costs)
2O2O-2O29 FPL SPP Program Costs/Activities
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX C (Page 2 of 2)rnm
Distribution - Pole lnspections
Operating Expenses
Capital Expenditures
Total
# of Pole lnspections
Transmission - lnsDections
Opemting ExPenses
Capital Expenditures
Total
# of Structure lnsPections
Distribution - Feeder Hardening (1) (2)
Operating Expenses
Capital Expenditures
Total
# of Feeders (3)
Distribution Lateml Hardenins (1) (21
Operating Expenses
capital Expenditures
Total
# of taterals (3)
Transmission - ReDlacins Wood Structures
Operating Expenses
Capital Expenditures
Tota I
# of Structures to be RePlaced
Distribution - Vegetation Manasement
Labor - Contractor
Labor - FPL
Equipment - Contractor
Equipment - FPL
Total
# of Miles Maintained
Transmission - Vegetation Management
Labor - Contractor
Labor - FPL
Equipment - Contractor
Equipment - FPL
Total
# of Miles Maintained
Substation Storm surge/Flood Mitisation
Operating Expenses
Capital Expenditures
Total
# of Substations
$s5
5s
45.5
1.5
IL.4
nl
46.3
1.5
11.6
0.1
s
s
s
s
s
s
s
)
s
5
5
s
s
s
s
s
s
s
3.8
55.3
3.8
50.7
54.5
s
5
s
s
s
s
5
5
51,.7
6.7
0.5
L.7
0.1
3.0 10.010.0
7
54.7
3.8
54.7
3.8
55.3
s s 3.9
56.4
1.0
52.0
53.0
3.9
57.8
4.0
59.3
4.L
60.8
4.2
62.3
s 39.1
s56.1
3.9
56.6
5 s
s
s 57.9
r.50,000
3s.8 S 32.2
68,000 68,000
59.0 s
154,000
57.9
1,54,000
28.9
68,000
s9.1s 50.3s 61.8
s s4.3
58,000
63.3
154,000
68,000
154,000
57.0
58,000
66.s
r.54,000
58.4
68,000
64.9 605.2 s 50.s
499.s s s0.0
150,000 154,OOO 154,000 154,OOO
1.3 s
34.s s
1.0
37.2
L.0
27.9
1.0
67.5
1.0 s
s4.6 s
1.0
53.3
1.0
54.6
1.0
56.0
1.0
57.4
s 10.5
489.0
a.u
48.9
s
s
s s 5
5
68.s s ss.6 s
68,000 68,000
55.7
68,000
628.r 664.9 664.9 573.3 474.5 200.0 s
628.1s 564.9s 554.9s s73.3
300-350 300-350 300-350 300-350
474.5
250-350
200.0 5
534.3
s 3,20s.8 5 s34.3
51"0.1
510-1
r2o.4 s 212.5 342.8 475.6 b5l-4 631.4s647.2s663.4 679.9 696.9
47s.6 5 631.4 S 631.4 5 647.2 5 563.4
500-700 800-900 800-900 800-900 800-900
679.9 596.9 5,LOr.4
800-900 800-900
5 r2o.4 5 272.5
220-230 300-3s0
1,400-1,600
52.7
0.2 s 0.2 5
42.7 5
0.2 5
21.9 5
5 429 S 22.1- 5
900-1,100 300-600
342.8
400-500
s
s
s
s
ss2.9
7-8
0.6
1.9
0.1
s
5
s
s
5
s 5 s s I
s
s
s
s
s
s
$
5
5
s
s 117.9
0.5 s
117.3 s
463.7 5
r4.7 5
11s.9 s
o.z
39.1
47.7
1.3
11.9
0.1
47.8
4.4
!2.O
u.f
46.9
'J-.4
Lr.7
0.1
46-9
1.5
11,.7
0.1
47.L
1.5
11.8
0.1
47.1
1..6
l-1.8
0.1
44.6 5 43.8
1.s s 1.5
tt.2 5 r.1.0
0.1 s 0.1 1.4
39.3
46.4
1.5
1L.6
0.1.
59.6
7.2
0.5
1.8
0.1
61.1 s 61.3 s 60.2
15,200 15,200
60.2
L5,200
60.6
15,200
50.6 s s9.5 s s8.s s s7.4 s s6.4
15,200 rs,200 15,200 1s,200 15,200
0.6
1.8
0.1
595.7
77.7
5.3
17.9
1.4
15,200
5.7
0.5
0.1
9.0 s 8.9
7,000 7,000
6.5
0.5
'J-.7
0.1
6.7
0.5
1-.7
0.L
0.5
0.1
7.4 5
0.6 5
1.8 5
0.1 s
7.6
0.6
L.9
0_1
7.9
0.5
2.O
o.?
7.27.2 s
5
)
s
s
s
5
5
s
s
8.9
7,000
s.os 9.75 s.75 9.9S !o.2
7,000 7,000 7,000 7,oo0 7,000
10.4
7,OO0
to.7
7,OO0
96.4 s 9.6
5 s
s s s 23.0
23.O 7.7
7.7
5
s10.0 5 10.0 S
2 5to7
Total SPP Costs
(L) Project level detail for 2020 in Appendix
(2) Costs include previous year(s) projects carried over to current year's project costs and future year's preliminary project costs (e.9., engineering)
(3) # of feeders or lateral to be initiated in the current year
s s64.7 sx,o9o.7 s 1,19s.8 5!,245.6 S1,290.e S1,014.9 5 832.7 I 8s1.0 S 869.7 S 889.0 S10,24s.0 $ L,27r.r
Total SPP
Costs
An n ual
Average Cost2023FPL SPP Programs 20262025)o242022202L2420 2027 2028 2029
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX D (Page 1 of 14)
APPENDIXD
(FPL's Hardening Design Guidelines)
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 2 o'f 14)
@FPL
Distribution Design G uidelines
The following guidelines will be used to standardize the design of FPL's overhead distribution
facilities when practical, feasible, and cost effective.
General
1. FPL has made a change to adopt Extreme Wind loading (EWL) as the design criteria for:
(1) new pole line construction, (2) pole line extensions, (3) pole line relocations, (4)
feeder pole replacements on multi-circuit pole lines, and (5) feeder pole replacements on
Top-ClF feeders. Reference the Pole Sizing section (pg. 7) for the guidelines to
determine the necessary pole class and type for all work. Refer to the Distribution
Engineering Reference Manual Addendum for calculating pole sizes for specific framing
under extreme wind loading conditions.
2. For maintenance, existing non-top-ClF pole lines may be evaluated using NESC combined
ice and wind loading with Grade B construction. This represents the loading prior to the
adoption of extreme wind loading. lf the pole must be replaced, refer to the Pole Sizing
section for the minimum class pole to be installed. Refer to the Distribution Engineering
Reference Manual (DERM) Section 4 for calculating pole sizes for specific framing under
the NESC combined ice and wind loading conditions.
3. Every attempt should be made to place new or replacement poles in private easements
or as close to the front edge of property (right of way line) as practical.
4. Overhead pole lines should be placed in front lot lines or accessible locations where
feasible.
5. When replacing poles, the new pole should be set as close as possible to the existing
pole to avoid the creation of a new pole location.
6. Poles are not to be placed in medians.
7. Concrete poles are not to be placed in inaccessible locations or locations that could
potentially become inaccessi ble.
8. Please reference the minimum setting depth charts located in DCS D-3.0.0 which shows
the increased setting depths for concrete poles.
9. Every effort should be made not to install poles in sidewalks. lf a pole must be placed in
a sidewalk, a minimum unobstructed sidewalk width of 32" must be maintained to comply
with the American Disabilities Act (ADA) requirements.
10. lf concrete poles are required by the governing agency as a requirement of the permit,
and if the work is being done solely for FPL purposes (feeder tie, etc.), then the concrete
Docket No. 2O2O0071-E\
FPL's 2020-2029 Storm Protection PIan
Exhibit MJ-1, APPENDIX D (Page 3 of 14)
poles are installed with no differential charges. lf the concrete poles are required as a
condition of the petmit, and the work is being done at the request of a customer (and fall
outside the Pole Sizing Guidelines) to provide service to the customer or relocation by
request of the customer, then the customer is charged a differential cost for the concrete
poles.
1 1. V/hen installing new OH secondary spans, multiplexed cable should be used instead of
open wire secondary. When reconductoring or relocating existing pole lines containing
open wire secondary, replace the open wire with multiplexed cable whenever possible.
The system neutral should not be removed when replacing open wire secondary with
multiplexed cable if primary wire is present. lt is necessary to maintain a separate
system neutral for operational continuity of the system.
12. When designing overhead facilities where secondary and service crossings exist across
major roadways, the engineer should take into consideration placing these secondary
street crossings underground. Operations Director Approval is required.
13. V/henever extending a feeder, reconductoring a feeder section, or attaching a device to a
feeder, always reference the nearest existing disconnect switch number on the
construction drawing and show the dimension to the switch. This will aid the Control
Centers in updating their switching system and will aid AMG in updatlng AMS, as well as
provide the Productioh Lead and Distribution Tech information needed for switching and
RC Off requests.
14. When an overhead feeder crosses any obstacle to access (i.e. - water bodies such as
rivers, canals, swamps; Iimited access RAff such as interstate highways, turnpikes, and
expressways; etc.) disconnect switches should be placed on both sides of the obstacle in
order to isolate the crossing in the event of a wiredown situation. See the example in the
Crossing Multi-Lane Limited Access Highways section (pg. 5).
15. Projects that affect or extend feeder conductors should always be coordinated with
Distribution Planning to ensure optimization of the distribution grid. Taking into account
future feeder plans such as, feeder boundary changes, sectionalizing devices, integration
of automation and remotely controlled protection.
As always, good engineering judgment, safety, reliability, and cost effectiveness should be
considered. ln addition to these guidelines, all distribution facilities shall be engineered to meet
the minimum requirements set forth in all applicable standards and codes including but not
limited to the National Electrical Safety Code (NESC), Utility Accommodation Guide, and FPL
Distribution Construction Standards. Please contact a Distribution Construction Services (DCS)
analyst with any questions.
@
Docket No. 20200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 4 of 14)
FPL
New Construction
1. When installing a new feeder, lateral, or service pole, reference the Pole Sizing section for
the guidelines to determine the necessary pole class and type to meet Extreme Wind
Loading (EWL) for the wind zone region (105, 130, or 145 MPH).
2. Modified Vertical is the preferred framing for accessible locations. Post-top (single phase) or
Cross Arm (multi-phase) is the prefened framing for inaccessible locations.
3. During the design of new pole lines in developed areas, field visits should be conducted to
ensure the design would cause minimum impact to the existing propefty owners.
4. Overhead pole lines should not be built on both sides of a roadway unless agreed to by the
customer nor should multi-circuit pole lines be created. When designing main feeder routes
all viable options must be reviewed (including alternative routes) and consideration should
be given to constructing the line underground. lf undergrounding is chosen and it is no!-the
least cost option, approval is required from the Engineering & Technical Services Director
and the Operations Director. ln addition, prior to proceeding with any pole lines on both
sides of a street or any multi-circuit feeder design recommendations, Operations Director
approval is required.
5. When there is an existing pole line in the rear easement, every effort should be made not to
build a second pole line along the right of way.
6. When installing a pole line within a transmission line, accessible distribution poles should be
concrete. Distribution concrete poles should not be installed in inaccessible locations.
7. lf concrete distribution poles are installed in a concrete transmission line, there is no
additional charge to the customer (the concrete poles are FPL's choice and not requested by
the customer). Coordination between the transmission and distribution design is critical and
consideration should be given to a design with alltransmission poles versus distribution
intermediate poles. This approach will reduce the overall number of poles.
8. \Nhen transmission is overbuilding (concrete structures), along an existing distribution
corridor, if the distribution wood poles are in good condition, do not replace. lf wood poles
need to be changed out or relocated, replace with concrete poles to match the transmission
pole type. Coordination between the transmission qnd distribution design is critical and
consideration should be given to a design with alltransmission poles versus distribution
intermediate poles. This approach will reduce the overall number of poles.
@
Docket No. 20200071-El
FPL'S 2O2O-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 5 of 14)
FPL
Existing / Maintenance
1. When installing and/or replacing a feeder, lateral, or service pole on an existing pole line,
reference the Pole Sizing section for the guidelines to determine the necessary pole class
and type.
2. V/hen installing or replacing a feeder pole on a feeder that serves a Top-ClF customer,
ensure the new pole will meet extreme wind loading (versus just a minimum class 2 or lllH
pole) so that it will not have to be replaced when the feeder is hardened as a hardening
project. Please reference the Storm Secure Hardening SharePoint Site: Distribution >
Central Maintenance > Central Contractor Services > Hardening > Reports > Feeder
Prioritization_xxxxxx Snapshot for the list of Top-ClF feeders within the Prioritization File.
3. When extending pole lines, the existing pole type should be used as a guide for the new
pole type. lf concrete poles are requested by the customer or are required as a condition of
the permit and fall outside the Pole Sizing Guidelines, the customer will pay a differential
charge for the concrele poles.
4. V/hen replacing pole(s) and anchor(s) with larger self-supporting concrete poles, caution
should be used, as the property owners in the vicinity of the pole will not necessarily
perceive this concrete pole as a better choice.
5. When replacing poles on a multi-circuit feeder the replacement pole should be designed for
Extreme \Mnd Loading using Pole Foreman to calculate the wind loading.
Relocations
1. \Men relocating a pole line, reference the Pole Sizing section for the guidelines to determine
the necessary pole class and type to meet Extreme Wind Loading (EWL) for the wind zone
region (105, 130, or 145 MPH).
2. When relocating either a concrete or wood pole line for a highway improvement project, the
existing pole line 'type' should be used as a guide for the pole type replacements. There is
no additional charge for concrete poles if the existing poles being relocated are concrete
(like for like relocation). lf the customer requests an "upgrade" to concrete poles, a
differential is charged.
3. Reimbursable relocations will equal the cost to relocate the line built to Extreme Wind
Loading (plus removal of old), including indirect cost.
4. Agency relocation projects should be coordinated with Distribution Planning to ensure
optimization of the distribution grid and to take into account future feeder plans and potential
feeder boundary changes.
@
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 6 of 14)
trPL
Grossing Multi-Lane Limited Access Highways
The following guidelines are to be used when an overhead feeder crosses any obstacle to
access (i.e. -limited access RA// such as interstate highways, turnpikes, and expressways,
etc.). Similar consideration can be given to water bodies such as rivers, canals, swamps.
1. Underground installation is the preferred design for all new crossings (1, 2, 3 phase) of multi-
lane limited access highways & hardening of existing crossings; reference Fig 1. Limited
Access Highway Crossing Schematic (Preferred). lf underground construction is not
feasible, reference Fig 2. Limited Access Highway Crossing Schematic (Alternate).
2. Underground crossing for 1 & 2 phases should be designed for potential three phase feeder
size cable. Ensure riser poles meet or exceed extreme wind design for the designated
region. Forfurther information, please contact the CMC Hardening Group.
3. For accessible overhead crossings, use concrete poles (lll-H or greater square concrete
pole) for the crossing poles and minimum Class 2 wood poles for the intermediate poles. For
inaccessible overhead crossings, minimum Class 2 wood poles should be used for the
crossing and intermediate poles. All poles installed should meet or exceed EWL for the
designated region.
4. Every attempt should be made to install storm guys & back guys for the highway crossing
poles. Storm guys are not required on the adjacent poles.
5. Frame the highway crossing pole double dead-end (See LOC 2 & 3 Fig 2 below).
6. lnstall disconnect switches on adjacent poles on both sides of the crossing (or as required
by field conditions) to isolate the feeder section for restoration. Switches are to be installed
in accessible locations that can be reached with readily available aerial equipment.
Switches should be installed at -42 Above Grade (AG), with a maximum pole size of 50'
wood or 55' concrete. lf there is no load between the nearest existing switch and the
crossing, an additionalswitch is not required.
7. Check for uplift on all poles. Refer to DERM Section 4.2.3 Page 4 o'f 16 & DCS E-4.0.2 and
E-4.0.3. Back guys should be installed at the adjacent pole if required for uplift.
8. Ensure to maintain proper clearance above or under all highways as dictated by the owner
of the RA/V & DCS 8-3.0.1.
9. Any conductors crossing the highway that have splices should be replaced with a continuous
conductor (NESC 261H2a). See Fig 2 below for additional notes on the use of splices on
adjacent spans. One additional set of dead-end insulators at the highway crossing pole may
be used if this eliminates the need for splices when installing a new pole.
Docket No. 2O2OOO71-E\
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 7 of 14)
@trPL
10. Engineers must conduct a pre-design meeting with the Production Lead to ensure the
feasibility of the proposed design.
1 1. As always, use good engineering judgment to produce a quality, cost-effective design
Fig 1. Limited Access Highway Crossing Schematic @referred)
Fig 2. Limited Access Highway Crossing Schematic (Alternate)
INSTALL ACCESSIBLE
DISCONNECT SWTCHES
REMOVE OH &INSTALL ACCESSIBLE
DISCONNECTSWTCHES
3 #568T-23t(V &3/0T-N
lF
-
FNc -{lF -
o
o o o--
tsI
=6ou
o
oUF
E
e--o
DOWNGUY FOR DEADEND
OUTSIDE OF LIMITED
ACCESS HIGHWAY. AOJUST
LOCATION OF POLE FOR
FIELDCONDITIONS
ALTERNATE LOCATION FOR
RISERPOLE TO PREVENT
DOWN GUY IN LIMITED
ACCESS RIW
Dtsc sw @ -42'AG
MAX POLE SIZEr
50'wooD,55'coNcRETE
INSTALL ACC€SSIBLE
DISCONNECTSWITCHES NO SPLICES INSTALL ACCESSIBLE
DISCONNECTSWITCHES
3 #568T-23KV & 568T-N
-}>
CHECK FOR UPLIFT &
INSTALL DOWN GUYS IF f f
I
REQUIRED
o ----) (---(---
ErII
6aUoo
odE:
J
J e----a a;-l\-a
Drsc sw @ -42' AG
MAX POLE SIZE:
s0'wooo, 5s' coNcRETE
(sw,TcHLocAnoN MAY
VARY BASED ON FIELD
COA'D'T'ON'S. FEFERENCE
D'STRIBUTION DES'GN
GU'OEL'i'ES,I
J
u
L
J
INSTALL INTERMEDIATE POLE IN
EFFORTTO REDUCE SPANS
INSTALLSTORM
GIJYS A BACK
GUY
@
Docket No. 2O2O0071-E\
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page I of 14)
FPL
Pole Sizing
FPL has made a change to adopt Extreme \Mnd loading (EWL) as the design criteria for:
(1) new pole line construction, (2) pole line extensions, (3) pole line relocations, (4) feeder
pole replacements on multi-circuit pole lines, and (4) feeder pole replacements on Top-ClF
feeders. Reference the Pole Sizing Guidelines (at the end of this section) to determine the
necessary pole class and type.
2. When installing or replacing a feeder pole on a feeder that serves a Top-ClF cuslomer,
ensure the new pole will meet the extreme wind design (versus just a minimum class 2 or
lllH pole) so that it will not have to be replaced when the feeder is hardened as a hardening
project. Please reference the Storm Secure SharePoint Site: Distribution > Central
Maintenance > Central Contractor Services > Hardening > Reports > Feeder
Prioritization_xxxxxx Snapshot forthe list of Top-ClF feeders within the Prioritization File.
3. For maintenance, existing non-top-ClF pole lines may be evaluated using NESC combined ice
and wind loading with Grade B construction. This represents the loading prior to the adoption of
extreme wind loading. lf the pole must be replaced, refer to the Pole Sizing Guidelines for the
minimum class pole to be installed.
4. When performing work on an existing pole, and the pole requires change out (e.9.,
clearance height, location, condition, or the ability to suppod the planned activity), use the
Pole Selection Guidelines. lf the planned work can be done without changing out the pole
and the pole meets minimum NESC grade B wind loading guidelines, use the existing
pole(s).
5. Foreign pole owners are required to discuss design requirements with FPL prior to
construction. FPL will assist with identifying the targeted poles.
6. Efforts should be made to ensure that span distances do not exceed 250 ft. for wood poles
and 350 ft. for concrete poles even if longer spans would meet the Extreme Wind Loading
requirements.
7. Concrete poles are prefered in the cases where replacement costs would be extremely high (i.e. duct
system riser pole, comer poles with multiple circuits, critical poles, etc.). No differential is charged
for poles in this case.
@
Docket No. 2020O071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX D (Page I of 14)
FPL
Lateral Pole Policv
1. All existing poles must meet NESC grade "8" as an absolute minimum.
2. lf a pole is modified in any way, it must meet NESC grade "B" at a minimum when
completed.
3. lf you become aware of a pole which does not meet NESC "8" or DCS standards, the pole
must be immediately upgraded or modified to meet the NESC & DCS standards.
4. All replacement lateral poles must meet NESC'EWL' and be compliant with FPL Pole
Policies.
5. Restoration of lateral poles should comply with the class 2/3 table.
For oractical purposes this means...
1. Engineer all poles to the NESC EWL standards and to meet FPL policies.
2. Run Pole Foreman on all designed WR's and poles suspected of being substandard.
3. lf you are completing substantial work on a pole, such as installing additional cables,
upgrading a TX, re-conductor or new framing: The pole must meet EWL and the revised
class standards.
4. lf you are completing minor like for like work such as replacing a fuse switch, insulator or
other small equipment: The pole must meet NESC grade "8" and DCS standards at a
minimum when the work is complete.
a. Note: Most FPL poles currently exceed NESC grade "8". This means there is
some leeway for minor changes in wind loading and clearances while maintaining
the NESC grade "B" minimum.
5. Temporary or time constrained poles may be installed to NESC grade "N" temporary
construction. This is relatively complicated, requires sound engineering judgment and should
be avoided. lf grade NESC grade "N" is applied, a replacement pole engineered to NESC
EWL must be designed and installed as soon as practical and not longer than 6 months after
NESC grade "N" was installed.
6. Class 4 poles may only be installed for SVC, SEC, SL, OL's. Once the available stock of
class 4 is used up no more will be ordered and FPL will install class 3 poles for these
applications.
7. ln no case should class 4 poles be installed in laterals.
Contact Enoineering Standards for situations that still are in question after careful
consideration
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX D (Page 10 of 14)
@FPL
Critical Pole Definitions & Sizing:
The following list comprises what will be considered critical poles. When installing and/or when
doing work that othenruise requires the replacement of an accessible critical pole, use concrete.
lf the pole is inaccessible, use a minimum Class 2 wood pole, or consider relocating the
equipment to an accessible concrete pole.
For all critical poles run Pole Foreman to calculate the wind loading for the specified pole and
attachments combination. Additional information can be found in DERM Section 4 - Addendum
for Extreme Wind Loading tables 4.2.2-8,4.2.2-9, or 4,2.2-10.
') Every attempt shoutd be made to instatl storm guys where feasible and practical.
't Frame in-line per standard to equatly distribute weight.t\ Refer to the Crossrng Multi-Lane Limited Access Highways section for details.
a) Contact CMC Hardening Group before designing new multi-circuit line.
5) To eliminate field drilting, inventory Speciat Dritl Pole & create Pole Boring Detailfor all lll-H
Poles on Hardening Jobs.
Critical Pole ldentifier
For new or when replaced use minimum Ill-H Square Concrete Poles
(minimum Class 2 if inaccessible)
Critical Poles
'1"1 switch out of substation or
duct system riser pole
DCS Reference
UH-15.0.0 Fig 2
uH-15.3.1
Critical Poles
Automated Feeder Switches
(AFS),
DGS Reference
c-9.2.0
lnterstate Grossingsr'3 E-l0.0.0 Fig 2 Aerial Auto Transformers2 l-9.0.0
Poles with multiple primary
risers uH-15.2.0 3 phase transformer banks
3 -'100 kVA and laroel l-52.0.2
Multi-circuit polesa
Three-phase reclosers2 (or
Three single-phase reclosers)
Frame as existing
c-8,0.0
Capacitor Banks2
Regulators
J-2.0.2 & J-2.0.3
t-10.1.1
PrimaryMeter K-28-0.0 lntelliruptors c-9.5.0
All references are to the Distribution Construction Standards (DCS)
Docket No. 20200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 11 ot 14)
@FPL
Pole Sizing Guidelines:
The following tables should be used as guidelines to help determine pole class and type, when
installing and/or replacing a feeder, lateral or service pole.
Feeder or Three Phase Lateral:
When designing for EWL run Pole Foreman to calculate the wind loading for the specified pole
and aftachments combination. Additional information can be found in DERM Section 4 -
Addendum for Extreme Wind Loading tables 4.2.2-8,4.2.2-9, or 4.2.2-10.
Sin or Two Phase Lateral:
Nofes;1) To be used when replacing equipment or instalting new equipment on an existing pole4 Reference Critical Pole List on pg.8.
'J Use of tlLG potes shoutd be timited to existing concrete lateral pote lines whose wire
s2e is less than or equal to 1/0A.
a) Use Pole Foreman to calculate wind toading on all poles.
Pole Line
Description
New Gonstruction,
Line Extension, &
Pole Line Relocation
Existing
lnfrastructure 1
lnstalling or
Replacing
a Critical Pole2
Wood Use minimum Class 2
Wood Pole to meet EWL
Use Class 2 Wood
Poles
Use lll-H (Accessible) or
Class 2 Wood
(lnaccessible)
Concrete
Use minimum lll-H
Concrete Pole to meet
EWL
Use lll-H Concrete
Poles
Use lll-H Concrete
Poles
Pole Line
Description
New Construction,
Line Extension,
Pole Line
Relocation, Pole
Replacement, &
lntermediate Poles
Existing
lnfrastructurel
lnstalling or
Replacing
a Critical Pole'
105/135 mph:
Use minimum Class 3
MUSI meet EWL
105/135 mph: Use
minimum Class 3
Wood 145 mph:
Use minimum Class 2
MUST meet EWL
145 mph: Use
minimum Class 2
Use lll-H (Accessible) or
Class 2 Wood
(lnaccessible)
Concrete Use minimum lll-G3 or
lll-H poles
Use lll-G" or lll-H
poles to match
existinq line
Use lll-H Concrete
Poles
@
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-'1 , APPENDIX D (Page 12 of 14)
F]'L
Basic Span Lengths for selected poles for Extreme Wind Loading:
Facility Phase(s)Wire size Pole
size
Recommended Maximum Span Lengtha
(FPL with 2 attachments - FPL ONLY)
105 MPH I30 MPH I45 MPH
Feeder 3#568 ACAR Class 2 1 80' - 230'1 25' - 200'90'- '140'
3#3/0 AAAC Class 2 '180' - 250'17}',-250'.120',-220'
Lateral 3PH 3#1/0 AMC Class 2 1 80', - 250',1 80' - 250',155'- 250'
2PH 2#1t0 A AC Class 3 1 80' - 250''180' - 250'125'-250'-
1PH 1#1/0 AAAC Class 3 1 80' - 250'1 80'- 250'1 50' - 250'
aThe lower number equates to the maximum span for FPL primary and two 1" foreign
attachments. The higher number equates to the recommended maximum span for FPL
primary only. Reference the DERM Addendum for EWL tables 4.2.2-8, 4.2.2-9, 4.2.2-10 when
adding additionalattachment(s) or equipment. As always, good engineering judgment,
safety, reliability, and cost effectiveness should be considered.
Service / Secondary / St. Light I Outdoor Light Poles:
When installing or replacing a service or street light poles, a minimum of Class 3 wood pole
should be used. Specific calculations may require a higher class pole for large quadruplex wire.
For any questions on pole sizing to meet EWL or running Pole Foreman to calculate wind
loading, please contact the CMC Hardening Group.
Christopher T. Wright
Senior Attorney - Regulatory
Florida Power & Light Company
700 Universe Blvd
Juno Beach, FL 33408-0420
Phone: (561)691-7144
E-mail: Christoper.Wrieht@fpl.com
Florida Authorized House Counsel;
Admitted in Pennsylvania
April10,2020
VA ELECTRONIC FILING
Mr. Adam Teitzman
Division of the Commission Clerk and Administrative Services
Florida Public Service Commission
2540 Shumard Oak Blvd.
Tallahassee, FL 32399 -0850
Re: Docket No. 20200071-El
Review of 2020-2029 Storm Protection Plan pursuant to Rule 25-6.030, F.A.C.,
X'lorida Power & Lisht Comnanv
Dear Mr. Teitzman:
Enclosed for electronic filing in the above-referenced docket, please find Florida Power &Light
Company's Petition for Approval of the 2020-2029 Storm Protection Plan pursuant to Rule 25-
6.030, F.A.C., together with the Direct Testimony of FPL witness Michael Jarro and Exhibit MJ-
1 . Copies of this filing will be provided as indicated on the enclosed Certificate of Service.
If you or your staff have any question regarding this filing, please contact me at (561) 691-7144.
Respectfully submitted,
s/Christopher Wr
Christopher T. Wright
Authorized House Counsel No. 1007055
Enclosure
FJ'L"
Florida Power & Light Company
700 Universe Boulevard, Juno Beach, FL 33408
Page | 1
BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
Review of 2020-2029 Storm Protection Plan pursuant
to Rule 25-6.030, F.A.C., Florida Power & Light
Company
Docket No. 20200071-EI
Filed: April 10,2020
PETITION OF FLORIDA POWER & LIGHT COMPAi\Y
FOR APPROVAL OF THE 2020-2029 STORM PROTECTION PLAN
L INTRODUCTION
Florida Power & Light Company ("FPL" or the "Company") hereby files this petition (the
"Petition") requesting that the Florida Public Service Commission ("Commission") approve the
proposed Transmission and Distribution ("T&D") Storm Protection Plan for the years 2020-2029
(hereinafter, the "SPP") pursuant to Section 366.96, Florida Statutes ("F.S.") and Rule 25-6.030,
Florida Administrative Code ("F.A.C."). FPL's SPP is, in large part, a continuation and expansion
of its previously approved and successful storm hardening and storm preparedness programs. FPL
submits that the storm hardening and storm preparedness programs included in its SPP are
appropriate and necessary to achieve the legislative objectives of Section366.96, F.S., to protect
and strengthen T&D infrastructure from extreme weather conditions, reduce outage times and
restoration costs, and improve overall service reliability to customers.l In support of this Petition,
FPL states as follows:
1. The name and address of the Petitioner is:
Florida Power & Light Company
700 Universe Blvd
Juno Beach, FL 33408
I The recovery of costs associated with the SPP, as well as the actual and projected costs to be included in
FPL's Storm Protection Plan Cost Recovery Clause, will be addressed in subsequent and separate Storm
Protection Plan Cost Recovery Clause dockets pursuant to Rule 25-6.031, F.A.C. The Commission has
opened Docket No. 20200092-EI to address Storm Protection Plan Cost Recovery Clause petitions to be
filed the third quarter of 2020.
1
2. FPL is a corporation organized and existing under the laws of the State of Florida
and is an electric utility as defined in Sections 366.02(2) and366.96,F.S. FPL provides generation,
transmission, and distribution service to nearly five million retail customer accounts.
3. Any pleading, motion, notice, order or other document required to be served upon
the petitioner or filed by any party to this proceeding should be served upon all of the following
individuals:
Kenneth A. Hoffrnan
Vice President, Regulatory Affairs
Florida Power & Light Company
215 South Monroe Street, Suite 810
Tallahassee,FL 3230I
Phone: 850-521 -3919
Fax: 850-521-3939
Email : ken.hoffman@fpl.com
John T. Burnett
Vice President and Deputy General Counsel
Christopher T. Wright
Senior Attorney
Florida Power &Light Company
700 Universe Boulevard
Juno Beach, FL 33408-0420
Phone: 561-691-7144
Fax: 561-691-7135
Email : j ohn.t.burnett@fpl.com
Email : christopher.wri ght@fpl. com
4. The Commission has jurisdiction pursuant to Section 366.96, F.S., and Rule 25-
6.030, F.A.C.
5. This Petition is being filed consistent with Rule 28-106.201, F.A.C. The agency
affected is the Commission, located at2540 Shumard Oak Boulevard, Tallahassee, Florida32399.
This case does not involve reversal or modification of an agency decision or an agency's proposed
action. Therefore, subparagraph (c) and portions ofsubparagraphs (b), (e), (0 and (g) ofsubsection
(2) of Rule 28-106.201, F.A.C., are not applicable to this Petition. In compliance with
subparagraph (d) of Rule28-106.201, F.A.C., FPL states that it is not known which, if any, of the
issues of material fact set forth in the body of this Petition may be disputed by any others who may
plan to participate in this proceeding. The discussion below demonstrates how the petitioner's
substantial interests will be affected by the agency determination.
2
il. BACKGROUND AND OVERVIEW
6. On June 27, 2019, the Governor of Florida signed CS/CS/CS/SB 796 addressing
Storm Protection Plan Cost Recovery, which was codified in Section 366.96, F.S. Therein, the
Florida Legislature found that it was in the State's interest to "strengthen electric utility
infrastructure to withstand extreme weather conditions by promoting the overhead hardening of
electrical distribution and transmission facilities, the undergrounding of certain electrical
distribution lines, and vegetation management," and for each electric utility to "mitigate restoration
costs and outage times to utility customers when developing transmission and distribution storm
protection plans." Section 366.96(1), F.S. The Florida Legislature directed the Commission to
adopt rules to specify the elements that must be included in each utility's SPP. Section366.96(l),
F,S.
7. Rule 25-6.030, F.A.C., requires each utility to file an updated SPP at least every
three years that covers the utility's immediate ten-year planning period. Rule 25-6.030, F.A.C.,
also specifies the information to be included in each utility's SPP. Consistent with these
requirements, FPL is herein submitting its SPP for the ten-year period of 2020-2029, which is
provided as Exhibit MJ-1.
8. FPL's SPP is largely a continuation and expansion of its existing storm hardening
and storm preparedness programs, which were most recently approved in FPT 's 2019-2021Storm
Hardening Plan.z These existing hardening and storm preparedness programs have already
demonstrated that they have and will continue to increase T&D infrastructure resiliency, reduce
restoration times, and reduce restoration costs when FPL's system is impacted by extreme weather
2 See In re: Petitionfor Approval of Florida Power & Light Company's 2019-202I Storm Hardening Plan
pursuantto Rule 25-6.0342, F.A.C.,DocketNo.20180144-EI, OrderNo. PSC-2019-0364-CO-EI (Fla. PSC
Aug.27,2019) (making Order No. PSC-2019-0301-PAA-EI issued on July 29,2079, effective and final).
aJ
events. FPL performed an analysis of Hurricanes Matthew and Irma that indicated the restoration
construction man-hours ("CMH"), days to restore, and storm restoration costs for these storms
would have been significantly higher without FPL's storm hardening programs.3
9. While FPL's nation-leading initiatives have made significant progress toward
strengthening FPL's infrastructure, FPL must continue its T&D storm hardening and storm
preparedness plans and initiatives. Storms remain a constant threat and Florida is the most
hurricane-prone state in the nation. With the significant coast-line exposure of FPL's system, and
the fact that the majority of FPL's customers live within twenty miles of the coast, a robust storm
protection plan is critical to maintaining and improving grid resiliency and storm restoration as
contemplated by the Legislature in Section 366.96.
10. As part of its SPP, FPL will continue the previously approved storm hardening and
storm preparedness programs to achieve the legislative objectives of promoting the overhead
hardening of T&D facilities, the undergrounding of distribution lines, and vegetation management
to reduce restoration costs and outage times to customers and improve the overall service reliability
for customers. In addition, FPL proposes to implement a new substation storm surge/flood
mitigation program. FPL submits that the SPP will continue and expand the benefits of hardening,
including improved day-to-day reliability, to all customers throughout FPL's system.
I 1. Submitted herewith and in support of FPL's SPP is the Direct Testimony of Michael
Jarro and Exhibit MJ-l, which includes FPL's SPP for the period of 2020-2029 and supporting
schedules.
3 See FPL's Third Supplemental Response to Staffs First Data Request No. 29 ("Third Supplemental
Amended") in Docket No. 20170215-EI, which is provided as Appendix A to Exhibit MJ-1.
4
III. STORM PROTECTION PLAN
A. Description of the SPP Programs
12. FPL's SPP is largely a continuation and expansion of the following previously
approved storm hardening and storm preparedness programs:
Pole Inspections - Distribution Program
Structures/Other Equipment Inspections - Transmission Program
Feeder Hardening (EWL) - Distribution Program
Lateral Hardening (Undergrounding) - Distribution Program
Wood Structures Hardening (Replacing) - Transmission Program
Vegetation Management - Distribution Program
Vegetation Management - Transmission Program
In addition, FPL proposes to implement a new Substation Storm Surge/Flood Mitigation-Program
to protect T&D substations and equipment that are susceptible to storm surge or flooding during
extreme weather events. These SPP programs are summarized below and a detailed description
of each SPP program, consistent with Rule 25-6.030(3Xd), F.A.C., is provided in Section IV of
Exhibit MJ-i.
13. The Pole Inspection - Distribution Program will continue FPL's existing
Commission-approved distribution pole inspection program, which is an eight-year pole
inspection cycle for all distribution poles that targets approximately 1/8 of the system annually
(the actual number of poles inspected canvary somewhat from year to year). With approximately
1.2 million distribution poles as of year-end 2019, FPL expects to inspect approximately 150,000
poles annually. The estimated 2020-2029 annual average cost for the Pole lnspection -
Distribution Program is approximately $61 million per year, which is consistent with historical
5
costs for the existing distribution pole inspection program.a A detailed description of the Pole
Inspection - Distribution Program is provided in Section IV(A) of Exhibit MJ-1.
14. The Structures/Other Equipment Inspections - Transmission Program will continue
FPL's current Commission-approved transmission inspection program which requires: (a)
transmission circuits and substations and all associated hardware to be inspected on a six-year
cycle; (b) wood structures to be visually inspected from the ground on an annual basis and climbing
or bucket truck inspections to be conducted on a six-year cycle; and (c) steel and concrete
structures to be visually inspected on an annual basis and climbing or bucket truck inspections to
be conducted on a ten-year cycle. FPL expects to inspect approximately 68,000 transmission
structures annually. The estimated 2020-2029 annual average cost for the Structures/Other
Equipment Inspections - Transmission Program is approximately $50 million per year, which is
consistent with historical costs for the existing transmission inspection program.s A detailed
description of the Structures/Other Equipment Inspections - Transmission Program is provided in
Section IV(B) of Exhibit MJ-1.
15. The Feeder Hardening (EWL) - Distribution Program will continue FPL's existing
Commission-approved approach to harden existing feeders and certain critical distribution poles,
as well as FPL's initiative to design and construct new pole lines and major planned work to meet
the extreme wind loading ("EWL") criteria set forth in the National Electric Safety Code. FPL
a Note, the2020-2029 program costs shown above are projected costs estimated as of the time of this filing.
Subsequent projected and actual costs could vary by as much as l}Yoto l1%io. The annual projected costs,
actual/estimated costs, actuals costs, and true-up of actual costs to be included in FPL's Storm Protection
Plan Cost Recovery Clause will all be addressed in subsequent and separate Storm Protection Plan Cost
Recovery Clause filings pursuant to Rule 25-6.031, F.A.C. The Commission has opened Docket No.
20200092-EI to address Storm Protection Plan Cost Recovery Clause petitions to be filed the third quarter
of2020.
5 See footnote 4.
6
expects to harden approximately 280-350 feeders annually, with 100% of FPL's feeders expected
to be hardened or underground by year-end 2024 and with the final costs of the program to be
incurred in 2025. The estimated average annual cost for the Feeder Hardening (EWL) -
Distribution Program to be incuned over the period of 2020-2025 is approximately $534 million
per year, which is consistent with historical costs for the existing distribution feeder hardening
program.6 A detailed description of the Feeder Hardening (EWL) - Distribution Program is
provided in Section IV(C) of Exhibit MJ-1.
16. The Lateral Hardening (Undergrounding) - Distribution Program includes
completing FPL's existing three-year Storm Secure Underground Program Pilot ("SSUP Pilot") in
2020 and expanding the application of the SSUP to the implementation of the system-wide Lateral
Hardening (Undergrounding) - Distribution Program forthe period of 2021-2029. The SSUP Pilot
is a program that targets certain overhead laterals that were impacted by recent storms and have a
history ofvegetation-related outages and other reliability issues for conversion from overhead to
underground. As part of its SPP, FPL will incorporate, continue, and expand the SSUP during the
ten-year SPP period to provide the benefits of underground lateral hardening throughout its system.
After completing the SSUP Pilot in 2020,FPL estimates that it will convert approximately 300-
700 laterals annually in202l-2023 and approximately 800-900 laterals annually in2024-2029.
The estimated 2020-2029 anntal average cost for the Lateral Hardening (Undergrounding) -
Distribution Program is approximately $510 million per year.7 A detailed description of the
Lateral Hardening (Undergrounding) - Distribution Program is provided in Section IV(D) of
Exhibit MJ-1.
6 See footnote 4
7 See footnote 4
7
17. The Wood Structures Hardening (Replacing) - Transmission Program is a
continuation of FPL's existing transmission hardening program to replace all wood transmission
structures with steel or concrete structures. As of year-end 2019, 96yo of FPL's transmission
structures, system-wide, were steel or concrete, with less than 2,900 (or 4Y") wood structures
remaining to be replaced. FPL expects to replace the 2,900 wood transmission structures
remaining on its system by year-end2022. The estimated2020-2022 annual average cost for the
Wood Structure Hardening (Replacing) - Transmission Program is approximately $39 million per
year, which is a decrease from the historical costs for the existing transmission hardening
program.8 A detailed description of the Wood Structure Hardening (Replacing) - Transmission
Program is provided in Section IV(E) of Exhibit MJ-1.
18. The Substation Storm Surge/Ilood Mitigation Program is the only new storm
hardening program that FPL proposes to implement as part of its SPP. The Substation Storm
Surge/Flood Mitigation Program will implement measures to protect certain T&D substations and
equipment that are susceptible to storm surge or flooding due to extreme weather events.
Specifically, FPL will raise the equipment at certain substations above the flood level and construct
flood protection walls around other substations that are susceptible to storm surge or flooding
during extreme weather events. The Storm Surge/Flood Mitigation - Transmission and
Distribution Program will reduce customer outages due to flooding and the need to de-energize
substations that are impacted by storm surge or flooding, as well as reduce flood damage and
restoration costs at these targeted substations. At this time, FPL has identified between 8-10
substations where it initially plans to implement storm surge/flood mitigation measures over the
8
8 See footnote 4
next three yearc (2020-2022). The estimated 2020-2022 annual average cost for the new
Substation Storm Surge/Flood Mitigation Program is approximately $8 million per year.e A
detailed description of the Substation Storm Surge/Flood Mitigation Program is provided in
Section IV(F) of Exhibit MJ-1.
lg. The Vegetation Management - Distribution Program is a continuation of FPL's
existing, Commission-approved distribution vegetation management program. FPL's currently
approved distribution vegetation program, includes the following system-wide vegetation
inspection and management activities: three-year cycle for feeders; mid-year cycle targeted
trimming for certain feeders; six-year cycle for laterals; and continued education of customers
through its Right Tree, Right Place initiative. FPL plans to inspect and maintain, on average,
approximately 15,200 miles annually, which is consistent with the historic miles inspected and
trimmed annually. The estimated2020-2029 average annual cost for the Vegetation Management
- Distribution Program is approximately $60 million per year, which is consistent with historical
costs for the existing distribution vegetation management program.l0 A detailed description of the
Vegetation Management - Distribution Program is provided in Section IV(G)of Exhibit MJ-1.
20. The Vegetation Management - Transmission Program is a continuation of FPL's
existing transmission vegetation management program, which includes visual and aerial
inspections of all transmission line conidors, LiDAR inspections of North American Electric
Reliability Corporation transmission line corridors, developing and executing annual work plans
to address identified vegetation conditions, and identifying and addressing priority and hazard tree
conditions prior to and during storm season. FPL plans to inspect and trim, on average,
e See footnote 4.
10 See footnote 4
9
approximately 7,000 miles of transmission lines annually, which is consistent with the historic
miles inspected and trimmed annually. The estimat ed 2020-2029 average annual cost for the
Vegetation Management - Transmission Program is approximately $10 million per year, which is
consistent with historical costs for the existing transmission vegetation management program.ll A
detailed description ofthe Vegetation Management- Transmission Program is provided in Section
IV(H) of Exhibit MJ-1.
B. Additional Details for First Three Years of the SPP
21. The following additional project level information required by Rule 25-
6.030(3)(e)(1), F.A.C., for the first year of the SPP (2020) is provided in Appendix E to Exhibit
MJ-l: (a) the actual or estimated construction start and completion dates; (b) a description of the
affected existing facilities, including number and type(s) of customers served, historic service
reliability performance during extreme weather conditions, and how this data was used to prioritize
the storm protection project; and (c) a cost estimate including capital and operating expenses. A
description of the criteria used to select and prioritize storm protection projects is included in the
description of each SPP program provided in Section IV of Exhibit MJ-1.
22. Pursuant to Rule 25-6.030(3)(eX2), F.A.C., FPL has also provided the estimated
number and costs of projects under each specific program for the second and third years (202I-
2022) of the SPP. This information is provided in Appendix C to Exhibit MJ-l.
23. The following additional information required by Rule 25-6.030(3)(f), F.A.C., for
the first three years (2020-2022) of the vegetation management activities under the SPP is provided
in Sections IV(c) and IV(H) of Exhibit MJ-l and Appendix C to Exhibit MJ-l: (a) the projected
frequency (trim cycle); (b) the projected miles of affected transmission and distribution overhead
ll,See footnote 4.
10
facilities; and (c) the estimated annual labor and equipment costs for both utility and contractor
personnel. Descriptions of how the vegetation management activities will reduce outage times
and restoration costs due to extreme weather conditions are provided in Sections IV(G) and IV(H)
of Exhibit MJ-1.
C. Estimated Revenue Requirements and Rate Impacts
24. Pursuant to Rule 25-6.030(3)(9), F.A.C., the estimated annual jurisdictional
revenue requirements of FPL's SPP for the ten-year period of 2020-2029 are provided in Section
VI of Exhibit MJ-l. While FPL has provided estimated costs by program as of the time of this
filing and associated total revenue requirements in its SPP, consistent with the requirements of
Rule 25-6.030, F.A.C., subsequent projected and actual program costs submitted for cost recovery
through the Storm Protection Plan Cost Recovery Clause (per Rule 25-6.031, F.A.C.,) could vary
by as much as l0-l5o/o, which variations would also impact the associated estimated revenue
requirements and rate impacts.
25. FPL anticipates the programs included in the SPP will have zero bill impacts on
customer bills during the first year of the SPP and only minimal bill increases for years two and
three of the SPP. An estimate of hypothetical overall rate impacts for the first three years of the
SPP (2020-2022) based on the total program costs reflected in this filing, without regard for the
fact that FPL remains under a general base rate freeze pursuant to a Commission-approved
settlement agreement through December 31,2021, are provided in Section VII of Exhibit MJ-1.
The annual jurisdictional revenue requirements and the estimated rate impacts are based on the
total estimated costs, as of the time of this filing, for all programs included in the SPP regardless
of whether those costs will be recovered in FPL's Storm Protection Plan Cost Recovery Clause or
through base rates. In addition, under FPL's Commission-approved rate case settlement
1l
agreement, any incremental base rate adjustment may not take place until FPL's base rates are
established by the Commission in FPL's next base rate proceeding.t'
26. FPL is not seeking Commission approval, through this petition, to recover any of
the estimated costs associated with the SPP in this filing. The projected costs, actual/estimated
costs, actual costs, and true-up of actual costs to be included in FPL's Storm Protection Plan Cost
Recovery Clause, including whether these costs are included in current base rates, will all be
addressed in subsequent and separate Storm Protection Plan Cost Recovery Clause filings pursuant
to Rule 25-6.031, F.A.C. The Commission has opened DocketNo.202000g2-EIto address Storm
Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
D. FPL's SPP is in the Public Interest and Should Be Approved
21. Sections 366.96(4)-(5), F.S., provide that the Commission shall review each
utility's SPP and, within 180 days from filing, determine whether the SPP is in the public interest.13
28. As explained above, the programs included in the SPP are largely a continuation
and expansion ofFPL's already successful and ongoing storm hardening and storm preparedness
programs previously approved by the Commission, as well as a new storm hardening progtam to
t2 See In re: Petitionfor rate inuease by Florida Power & Light Company, Docket No. 160021-EI, Order
No. PSC-16-0560-AS-EI (Fla. PSC Dec. 15, 2016).
13 In reaching this determination, the Florida Legislature has directed the Commission to consider the
following:
(a) The extent to which the plan is expected to reduce restoration costs and outage times associated with
extreme weather events and enhance reliability, including whether the plan prioritizes areas of lower
reliability performance.
(b) The extent to which storm protection of transmission and distribution infrastructure is feasible,
reasonable, or practical in certain aleas of the utility's service territory, including, but not limited to,
flood zones and rural areas.
(c) The estimated costs and benefits to the utility and its customers of making the improvements
proposed in the plan.
(d) The estimated annual rate impact resulting from implementation of the plan during the first 3 years
addressed in the plan.
,See Section 366.96(4), F.S.
t2
protect T&D substations and equipment from storm surge and flooding due to extreme weather
events. These SPP programs will continue to provide increased T&D infrastructure resiliency,
reduced restoration times, and reduced restoration costs when FPL's system is impacted by
extreme weather events.
29. In Docket No. 20170215-EU, the Commission reviewed the electric utilities' storm
hardening and storm preparedness programs and found the following:
Florida's aggressive storm hardening programs are working;
The length of outages was reduced markedly from the 2004-2005 storm
season;
Hardened overhead distribution facilities performed better than non-
hardened facilities;
Underground facilities performed much better compared to overhead
facilities; and
The primary causes of power outages came from outside the utilities' rights-
of-way including falling trees, displaced vegetation, and other debris.
See Review of Florida's Electric Utility Hurricane Preparedness and Restoration Actions 2018,
Docket No. 2017021 5-EU (July 24,201 8). 14
30. The estimate of cumulative reductions in restoration costs and outage times
associated with the SPP will be directly affected by how frequently storms hit FPL's service
territory. Of course, no one is in a position to know for sure how frequently FPL's service territory
will be impacted by strong hurricanes. However, consistent with historical results, FPL expects
that the storm hardening and storm preparedness programs included in its SPP will result in a
reduction in storm as well as non-storm (dayto-day) restoration costs. See FPL's Third
Supplemental Response to Staff s First Data Request No. 29 ("Third Supplemental Amended") in
ta Available at lfttp:llwww.psc.state.fl.usllibrarylfilingsl2}l8l04847 -2018104847-2018.pdf .
t3
Docket No. 20170215-EI, which is provided as Appendix A to Exhibit MJ-1.
31. FPL's storm hardening and storm preparedness programs have also provided and
will continue to provide increased levels of day-to-day reliability. For example, FPL has
previously submitted reports to the Commission that show hardened feeders have performed
approximately 40o/o better (i.e., fewer outages) on a day-to-day basis than non-hardened feeders.
32. A detailed summary of the benefits of FPL's SPP is provided in Section II of
Exhibit MJ-l, and the benefits and costs associated with each program is provided in Section IV
of Exhibit MJ-1.
33. FPL's SPP meets the objectives of Section 366.96, F.S., satisfies the requirements
of Rule 25-6.030, F.A.C., is in the public interest, and should be approved.
IV CONCLUSION
34. As explained above and in further detail in Exhibit MJ-1 and the supporting Direct
Testimony of FPL witness Michael Jaro, FPL's SPP provides a systematic approach to achieve
the legislative objectives of reducing restoration costs and outage times associated with extreme
weather events and enhancing reliability. FPL's SPP appropriately and effectively maintains and
builds on FPL's commitment to provide safe and reliable electric service to customers, consistent
with our customers' needs and expectations .
l4
WHEREFORE, FPL respectfully requests that the Commission find FPL's proposed SPP,
provided as Exhibit MJ-l, is in the public interest and approve the SPP for the yearc 2020-2029.
Respectfully submitted this 1Oth day of April,2020,
John T. Burnett
Vice President and Deputy General Counsel
Christopher T. Wright
Senior Attomey
Florida Power &Liglrt Company
700 Universe Boulevard
Juno Beach, FL 33 408-0420
Phone: 561-691-7144
Fax: 561-691-7135
Email : i ohn.t.bumett@fpl.com
Email : christopher.wrieht@fpl.com
By s/C hr i sto pher T. Wr i sht
Christopher T. Wright
Fla. Auth. House Counsel No. 1007055
15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of Florida Power & Light Company's
Petition for Approval of the 2020-2029 Storm Protection Plan in DocketNo. 2020007I-El, along
with the Direct Testimony of Michael Jaro and Exhibit MJ-l, has been furnished by Electronic
Mail to the following parties of record this 1Oth day of April,2020:
s/ Christopher T. Wrisht
Christopher T. Wright
Fla. Auth. House Counsel No. 1007055
Fla. Auth. House Counsel No. 1017875
Florida Power & Light Company
700 Universe Boulevard (JB/LAW)
Juno Beach, Florida 33408
Attorneyfor Florida Power & Light Company
Charles Murphy, Esquire
Rachael D zie chciarz, Esquire
Florida Public Service Commission
2540 Shumard Oak Boulevard
Tallahassee,FL 32399
rdziechc@psc. state.fl .us
cmurphy@Fsc.state.fl .us
Office of Public Counsel
J.R.Kelly
Patricia A. Christensen
c/o The Florida Legislature
111 West Madison Street, Room 812
Tallahassee, FL 32399 -I 400
kelly jr@le g.state.fl .us
christensen.patty@le g. state.fl .us
BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
FLORIDA POWER & LIGIIT COMPANY
2020-2029 STORM PROTECTION PLAN
DOCKET NO. 202000071-EI
DIRECT TESTIMONY OF'
MICHAEL JARRO
APRIL 10,2020
1
TABLE OF CONTENTS
I. INTRODUCTION
U. OVERVIEW OF FPL'S SPP............4
IIII. DESCRIPTION OF'EACH SPPPROGRAM.......... ........,....,,.7
IV. ADDITIONAL DETAILS FOR FIRST THREE YEARS OF THE SPP ....................16
v. coNcLUSroN........... ......................18
EXHIBIT MJ-l - FPL's 2020-2029 Storm Protection Plan
2
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aJ
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LJ
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25
a.
A.
a.
A.
I. INTRODUCTION
Please state your name and business address.
My name is Michael Jarro. My business address is Florida Power & Light Company, 15430
Endeavor Drive, Jupiter, FL, 3347 8.
By whom are you employed and what is your position?
I am employed by Florida Power & Light Company ("FPL" or the'oCompany") as the Vice
President of Distribution Operations.
Please describe your duties and responsibilities in that position.
My curent responsibilities include the operation and maintenance of FPL's approximately
68,000 miles of distribution infrastructure, including 42,000 miles of overhead and 26,000
miles of underground, that safely, reliably, and efficiently deliver electricity to more than five
million customers in FPL's service tenitory covering approximately 28,000 square miles. I am
responsible for the oversight of more than 1,600 employees in a control center and sixteen
management areas. The functions and operations within my area are quite diverse and include
distribution operations, major projects and construction services, power quality, meteorology,
and other operations that together help provide the highest level of service to FPL's customers.
Please describe your educational background and professional experience.
I graduated from the University of Miami with a Bachelor of Science Degree in Mechanical
Engineering and Florida International University with a Master of Business Administration. I
joined FPL in 1991 and have held several leadership positions in distribution operations and
customer service, including serving as distribution reliability manager, manager of distribution
operations for south Miami-Dade area, control center general manager, director of network
operations, senior director ofcustomer strategy and analytics, senior director ofpower delivery
central maintenance and construction, and vice-president of transmission and substations.
What is the purpose of your direct testimony?
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The purpose of my testimony is to present and provide an overview of FPL's proposed 2020-
2029 Storm Protection Plan ("SPP" or "the Plan"), which is attached to my direct testimony as
Exhibit MJ-l, and demonstrate that FPL's SPP is in compliance with Section 366.96, Florida
Statutes ("F.S.") and Rule 25-6.030, Florida Administrative Code ("F.A.C."). I will provide a
description ofeach storm protection program included in FPL's SPP and how it is expected to
reduce restoration costs and outage times. I will also describe the estimated start/completion
dates, estimated costs, and criteria used to select and prioritize the projects in each program.
Finally, I will describe the additional detail provided for the first three years of FPL's SPP
pursuant to Rule 25-6.030(3Xe)-(0, (h), and (i), F.A.C.
Are you sponsoring any exhibits in this case?
Yes. I am sponsoring Exhibit MJ-l - FPL's Storm Protection Plan 2020-2029.
il. OVERVIEW OF FPL'S SPP
What is the purpose of FPL's SPP?
On June 27,2019, the Governor of Florida signed into law the Storm Protection Plan Cost
Recovery legislation, which was codified in Section 366.96, F.S. As part of the new law, the
Florida Legislature expressly found that it is in the State's interest: (a) "to strengthen electric
utility infrastructure to withstand extreme weather conditions by promoting the overhead
hardening of electrical transmission and distribution facilities, the undergrounding of certain
electrical distribution lines, and vegetation management;" and (b) "for each electric utility to
mitigate restoration costs and outage times to utility customers when developing transmission
and distribution storm protection plans." See Sections 366.96(lXc)-(d), F.S. Based on these
findings, the Florida Legislature directed each electric utility to file a SPP with the Florida
Public Service Commission ("Commission") covering the immediate ten (10) year plaruring
period. ,See Section 366.96(3), F.S. Consistent with this legislative requirement, FPL is
submitting its SPP for the ten-year period of 2020-2029.
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FPL's SPP is a systematic approach to achieve the legislative objectives of reducing restoration
costs and outage times associated with extreme weather events and enhancing reliability. As
required by Rule 25-6.030, F.A.C., FPL's SPP includes, among other things, a description of
each proposed storm protection program, including: (a) how each program will enhance the
existing system to reduce restoration costs and outage times; (b) applicable start and completion
dates for each program; (c) a cost estimate for each program; (d) a comparison of the costs and
benefits for each program; and (e) a description of how each program is prioritized. The SPP
also provides an estimate of the annual jurisdictional revenue requirement for each year of the
SPP and additional details on each program for the first three years ofthe SPP (2020-2022),
including estimated rate impacts.
What programs are included in FPL's SPP?
FPL's SPP is, in large part, a continuation and expansion of its previously approved storm
hardening and storm preparedness programs, and includes the following SPP programs:
. Pole Inspections - Distribution Program
o Structures/Other Equipment Inspections - Transmission Program
o Feeder Hardening - Distribution Program
o Lateral Hardening (Undergrounding) - Distribution Program
. Wood Structures Hardening (Replacing) - Transmission Program
o Vegetation Management - Distribution Program
r Vegetation Management - Transmission Program
In addition, FPL proposes to implement a new Substation Storm Surge/Flood Mitigation
Program to protect T&D substations and equipment that are susceptible to storm surge or
flooding during extreme weather events.
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With the exception of the new storm surge/flood mitigation program, the majority of these
programs have been in place since 2007. As demonstrated by recent storm events, these
programs have been successful in reducing restoration costs and outage times following major
storms, as well as improving dayto-day reliability. FPL submits that continuing these
previously approved storm hardening and storm preparedness programs in the SPP, together
with the new storm surge/flood mitigation program, is appropriate and necessary to meet the
requirements of Section 366.96, F.S., and Rule 25-6.030, F.A.C. These programs will address
the expectations ofFPL's customers and other stakeholders for increased storm resiliency, and
will result in fewer outages, reduced restoration costs, and prompt service restoration. The SPP
will continue and expand the benefits of hardening, including improved dayto-day reliability,
to all customers throughout FPL's system.
Please provide an overview of the benefits of FPL's SPP.
The major benefit of FPL's SPP is to provide increased resiliency and faster restoration to the
electric infrastructure that FPL's five million customers and Florida's economy rely on for their
electricity needs. Safe and reliable electric service is essential to the life, health, and safety of
the public, and has become a critical component of modern life. Florida remains the most
hurricane-prone state inthe nation and, withthe significant coastJine exposure ofFPL's system
and the fact that the vast majority of FPL's customers live within 20 miles of the coast, a robust
storm protection plan is critical to maintaining and improving grid resiliency and storm
restoration as contemplated by the Legislature in Section 366.96.
FPL's SPP programs have already demonstrated that they have provided and will continue to
provide increased Transmission and Distribution ("T&D") infrastructure resiliency, reduced
restoration time, and reduced restoration cost when FPL is impacted by extreme weather
events. FPL performed an analysis of Hurricanes Matthew and Irma that indicated the
restoration construction man-hours ("CMH"), days to restore, and storm restoration costs for
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these storms would have been significantly greater without FPL's storm hardening programs.
In the case of Hurricane Matthew, FPL estimated that without hardening, restoration would
have taken two additional days (50% longer), and resulted in additional restoration costs of
$l05million(36%higherthanactualcosts). InthecaseofHurricanelrma,FPLestimatedthat
without hardening, restoration would have taken four additional days (40Vo longer), and
resulted in additional restoration costs of $496 million (40% higher than actual costs). A copy
of FPL's analysis is provided in Appendix A to Exhibit MJ-1.
A detailed summary of the benefits of FPL's SPP is provided in Section II of the SPP, and the
benefits ofeach program are provided in Section IV ofthe SPP.
Does FPL's SPP address recovery of the costs associated with the SPP?
No. FPL anticipates the programs included in the SPP will have zero bill impacts on customer
bills during the first year of the SPP and only minimal bill increases for years two and three of
the SPP. However, the recovery of the actual costs associated with the SPP, as well as the costs
to be included in FPL's Storm Protection Plan Cost Recovery Clause, will be addressed in
subsequent and separate Storm Protection Plan Cost Recovery Clause dockets pursuant to Rule
25-6.031, F.A.C. The Commission has opened Docket No. 20200092-EI to address Storm
Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
ilI. DESCRIPTION OF EACH SPP PROGRAM
Has FPL provided the information required by Rule 25-6.030(3Xd) for each program
included in its SPP?
Yes. FPL's SPP provides the information required by the Rule 25-6.030(3Xd) for each
program. If applicable, each program description included in FPL's SPP includes: (1) a
description of how each program is designed to enhance FPL's existing transmission and
distribution facilities including an estimate of the resulting reduction in outage times and
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restoration costs due to extreme weather conditions; (2) identification ofthe actual or estimated
start and completion dates of the program; (3) a cost estimate including capital and operating
expenses; (4) a comparison ofthe costs and the benefits; and (5) a description ofthe criteria
used to select and prioritize proposed storm protection programs. Each of the above listed
descriptions is provided in Section IV of FPL's SPP. Below, I will provide a brief overview
of each program included in FPL's SPP.
Please provide a summary of FPL's Pole Inspection - Distribution Program included in
the SPP.
The Pole Inspection - Distribution Program included in the SPP is a continuation of FPL's
existing Commission-approved distribution pole inspection program. FPL's existing,
Commission-approved distribution pole inspection program is an eight-year pole inspection
cycle for all distribution poles that targets approximately 1/8 of the system annually (the actual
number of poles inspected can vary somewhat from year to year). To ensure inspection
coverage throughout its service territory, FPL established nine inspection zones (based on
FPL's management areas and pole population) and annually performs pole inspections of
approximately 1/8 of the distribution poles in each of these zones, as well as any necessary
remediation as a result of such inspections. As explained in the SPP, recent storm events
demonstrate that FPL's existing distribution pole inspection program has contributed to the
overall improvement in distribution pole performance during storms, resulting in reductions in
storm damage to poles, days to restore, and storm restoration costs.
With approximately 1 .2 million distribution poles as of year-end 2019, FPL expects to inspect
approximately 150,000 poles annually (spread throughout its nine inspection zones) during the
2020-2029 SPP period. The total estimated costs for the Pole Inspection - Distribution
Program for the ten-year period of 2020-2029 is $605 million with an annual average cost of
approximately $61 million, which is consistent with historical costs for the existing distribution
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pole inspection program.r A detailed description of the Pole Inspection - Distribution Program
is provided in Section IV(A) of FPL's SPP.
Please provide a summary of FPL's Structures/Other Equipment Inspections -
Transmission Program included in the SPP.
The Structures/Other Equipment Inspections - Transmission Program included in the SPP is a
continuation of FPL's existing Commission-approved transmission inspection program. The
SPP will continue FPL's current, Commission-approved transmission inspection program
which requires: (a) transmission circuits and substations and all associated hardware to be
inspected on a six-year cycle; (b) wood structures to be inspected visually from the ground on
an annual basis and climbing or bucket truck inspections to be conducted on a six-year cycle;
and (c) steel and concrete structures to be inspected visually on an annual basis and climbing
or bucket truck inspections to be conducted on a ten-year cycle. As explained in the SPP, the
performance of FPL's transmission facilities during recent storm events indicates FPL's
transmission inspection program has contributed to the overall storm resiliency of the
transmission system and provided savings in storm restoration costs.
FPL expects to inspect approximately 68,000 structures annually during lhe 2020-2029 SPP
period. The total estimated costs for the Structures/Other Equipment Inspections -
Transmission Program for the ten-year period of 2020-2029 is $500 million with an annual
average cost of approximately $50 million, which is consistent with historical costs for the
1Note, the2020-2029 program costs shown above are projected costs estimated as of the time of this filing.
Subsequent projected and actual costs could vary by as much as 10o/o to 15oh. The annual projected costs,
actual/estimated costs, actuals costs, and true-up of actual costs to be included in FPL's Storm Protection Plan
Cost Recovery Clause will all be addressed in subsequent and separate Storm Protection Plan Cost Recovery
Clause filings pursuant to Rule 25-6.031, F.A.C. The Commission has opened Docket No. 20200092-EIto
address Storm Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
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existing transmission inspection program.2 A detailed description of the Structures/Other
Equipment Inspections - Transmission Program is provided in Section IV(B) of FPL's SPP.
Please provide a summary of FPL's Feeder Hardening (EWL) - Distribution Program
included in the SPP.
The Feeder Hardening (EWI-) - Distribution Program included in the SPP is a continuation of
FPL's existing Commission-approved approach to harden existing feeders and certain critical
distribution poles, as well as FPL's initiative to design and construct new pole lines and major
planned work to meet the National Electrical Safety Code's ("NESC") extreme wind loading
criteria ("EWL"). During the period 2006-2019, FPL hardened over 1,300 existing feeders, the
vast majority being Critical Infrastructure Function ("CIF") feeders (i.e., feeders that serve
hospitals, 911 centers, police and fire stations, water treatment facilities, county emergency
operation centers) and Community Project feeders (i.e., feeders that serve other key community
needs like gas stations, grocery stores and pharmacies) throughout FPL's service territory.
Additional feeders were hardened as a result of FPL's Priority Feeder Initiative, a reliability
program that targeted feeders experiencing the highest number of intenuptions and/or customers
interrupted. FPL also applied EWL to the design and construction of new pole lines and major
planned work, including pole line extensions and relocations and certain pole replacements.
As provided in previous FPL Annual Reliability Report filings and three-year Storm Hardening
Plan filings (per Rule 25-6.0342, F.A.C.), hardened feeders perform better than non-hardened
feeders, both in day-to-day reliability performance and during severe storms. Additionally, upon
review of the electric utilities' storm hardening and storm preparedness programs, the
Commission found that for Hurricane Irma, hardened feeders performed significantly better than
2 See footnote I
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non-hardened feeders with respect to outage rates, pole failures, and CMH required to restore
power.3
FPL expects to harden approximately 250-350 feeders annually, with 100% of FPL's feeders
expected to be hardened or underground by year-end 2024 and with the final costs of the
program to be incurred in2025. The total estimated costs for the Feeder Hardening (EWL) -
Distribution Program for the period of 2020-2025 is $3,206 million with an annual average cost
of approximately $534 million, which is consistent with historical costs for the existing
distribution feeder hardening program.a A detailed description of the Feeder Hardening (EWI-)
- Distribution Program is provided in Section IV(C) of FPL's SPP.
Please provide a summary of FPL's Lateral Hardening (Undergrounding) - Distribution
Program included in the SPP.
The Lateral Hardening (Undergrounding) - Distribution Program included in the SPP is a
continuation and expansion ofFPL's existing three-year Storm Secure Underground Program
Pilot ("SSUP Pilot") implemented in 2018. The SSUP Pilot is a program that targets certain
overhead laterals that were impacted by recent storms and have a history of vegetation-related
outages and other reliability issues for conversion from overhead to underground. As part of its
proposed SPP, FPL will complete its existing three-year SSIIP Pilot in 2020 and expand the
application of the SSUP during 2021-2029 to the implementation of the system-wide Lateral
Hardening (Undergrounding) - Distribution Program to provide the benefits of underground
lateral hardening throughout its system. As explained in the SPP, the proposal to continue and
expand the application of the SSUP under the SPP is based on the performance of the
3 See Review of Florida's Electric Utility Huruicane Preparedness and Restoration Actions 2018, Docket No
2017 021 5 -EU (Iuly 24, 20 1 8).
a See footnote 1
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underground facilities as compared to overhead facilities and the extensive damage to the
overhead facilities caused by vegetation during Hurricanes Matthew and Irma.
By the end of2020, the third and final year ofthe SSIIP Pilot, FPL expects to have converted
a total of 220-230 laterals from overhead to underground, which is consistent with the SSUP
Pilot plan most recently approved in July 2019 in FPL's most recent storm hardening plan
docket, Docket No. 20180144-EI. After completing the SSUP Pilot in 2020, FPL estimates
that it will convert approximately 300-700 laterals annually in202l-2023 and approximately
800-900 laterals annually in2024-2029. The total estimated costs for the Lateral Hardening
(Undergrounding) - Distribution Program for the ten-year period of 2020-2029 is $5,101
million with an annual average cost of approximately $510 million.s A detailed description of
the Lateral Hardening (Undergrounding) - Distribution Program is provided in Section IV(D)
of FPL's SPP.
Please provide a summary of FPL's Wood Structures Hardening (Replacing) -
Transmission Program included in the SPP.
The Wood Structure Hardening (Replacing) - Transmission Program included in the SPP is a
continuation of FPL's existing transmission hardening program to replace all wood transmission
structures with steel or concrete structures. As explained in the SPP, the performance of FPL's
transmission facilities during recent storm events indicates FPL's transmission hardening
program has contributed to the overall storm resiliency ofthe transmission system and provided
savings in storm restoration costs.
As of year-end 2019, 96yo of FPL's transmission structures, system-wide, were steel or
concrete, with less than2,900 (or 4%) wood structures remaining to be replaced. FPL expects
s See footnote I
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to replace the 2,900 wood transmission structures remaining on its system by year-end 2022.
The total estimated costs for the Wood Structure Hardening (Replacing) - Transmission
Program for the period of 2020-2022 is $118 million with an annual average cost of
approximately $39 million, which is a decrease from the historical costs for the existing
transmission hardening program.6 A detailed description of the Wood Structure Hardening
(Replacing) - Transmission Program is provided in Section IV(E) of FPL's SPP.
Please provide a summary of FPL's Substation Storm Surge/Flood Mitigation Program.
The Substation Storm Surge/Flood Mitigation Program is the only new storm hardening
program that FPL proposes to implement as part of its SPP. The Storm SurgelFlood Mitigation
- Transmission and Distribution Program will implement measures to protect T&D substations
and equipment that are susceptible to storm surge or flooding due to extreme weather events.
Historically, several FPL distribution and transmission substations have been impacted by
storm surge andlor flooding as a result of extreme weather conditions. While proactively de-
energizing those substations impacted by storm surge and/or flooding helps reduce damage to
substation equipment, FPL is still required to implement both temporary flood mitigation
efforts and repairs to substation facilities and equipment that become flooded as a result of
extreme weather conditions. Further, flooding and the need to proactively de-energize
substations located in areas susceptible to storm surge and flooding can result in significant
customer outages. To prevent/mitigate future substation equipment damage and customer
outages due to storm surge and flooding, FPL's new Storm Surge/Flood Mitigation Program
will raise the equipment at certain substations above the flood level and construct flood
protection walls around other substations to prevent/mitigate future damage due to storm surge
and flooding.
6 See footnote I
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At this time, FPL has identified between 8-10 substations where it initially plans to implement
storm surge/flood mitigation measures over the next three years (2020-2022). The total
estimated costs for the new Substation Storm Surge/Flood Mitigation over this three-year
period is approximately $23 million with an annual average cost of approximately $8 million
per year.1 A detailed description of the Storm Surge/Flood Mitigation - Transmission and
Distribution Program is provided in Section IV(F) of FPL's SPP.
Please provide a summary of FPL's Vegetation Management - Distribution Program
included in the SPP.
The Vegetation Management - Distribution Program included in the SPP is a continuation of
FPL's existing, Commission-approved distribution vegetation management program. FPL's
currently-approved distribution vegetation program, includes the following system-wide
vegetation management activities: three-year cycle for feeders; mid-year cycle targeted
trimming for certain feeders; six-year cycle for laterals; and continued education of customers
through its Right Tree, Right Place initiative. In approving FPL's current distribution vegetation
management cycles, the Commission indicated that FPL's distribution vegetation management
cycles were cost-effective and would provide savings to customers. Additionally, as explained
in the SPP, recent storm events demonstrate that FPL's existing distribution vegetation
management program has contributed to the overall improvement in the resiliency of
distribution system during storms, resulting in reductions in storm damage to poles, days to
restore, and storm restoration costs.
Under the SPP, FPL plans to trim, on average, approximately 15,200 miles annually, including
approximately 11,400 miles for feeders (cycle and mid-cycle) and 3,800 miles for laterals,
which is consistent with the historic miles trimmed annually. The total estimated costs for the
7 See footnote I
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Vegetation Management - Distribution Program for the ten-year period of 2020-2029 is $596
million with an annual average cost of approximately $60 million, which is consistent with
historical costs for the existing distribution vegetation management program.8 A detailed
description of the Vegetation Management- Distribution Program is provided in Section IV(G)
of FPL's SPP.
Please provide a summary of FPL's Vegetation Management - Transmission Program
included in the SPP.
The Vegetation Management - Transmission Program included in the SPP is a continuation of
FPL's existing transmission vegetation management program. The key elements of FPL's
transmission vegetation management program are to inspect the transmission right-of-ways,
document vegetation inspection results and findings, prescribe a work plan, and execute the
work plan. In its SPP, FPL will continue its cunent transmission vegetation management plan,
which includes visual and aerial inspections of all transmission line conidors, Light Detection
and Ranging ("LiDAR") inspections of North American Electric Reliability Corporation's
("NERC") transmission line corridors, developing and executing annual work plans to address
identified vegetation conditions, and identifying and addressing priority and hazard tree
conditions prior to and during storm season. As explained in the SPP, the execution of FPL's
transmission vegetation management plan has been and is a significant factor in mitigating
damage to transmission facilities and avoiding transmission-related outages.
Under the SPP, FPL plans to inspect and maintain, on average, approximately 7,000 miles of
transmission lines annually, including approximately 4,300 miles for NERC transmission line
corridors and2,700 miles for non-NERC transmission line corridors. This is comparable to
the approximately 7,000 miles inspected and maintained annually, on average for 2017 -2019.
8 See footnote 1
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The total estimated costs for the Vegetation Management - Transmission Program for the ten-
year period of 2020-2029 is $96 million with an annual average cost of approximately $10
million, which is consistent with historical costs for the existing transmission vegetation
management program.e A detailed description of the Vegetation Management - Transmission
Program is provided in Section IV(H) of FPL's SPP.
IV. ADDITIONAL DETAILS FORFIRST THREE YEARS OF THE SPP
Has FPL provided additional project-level details and information for the first year
(2020) of the SPP?
Yes. The following additional information required by Rule 25-6.030(3)(e)(1), F.A.C., for the
first year (2020) of the SPP is provided in Appendix E to FPL's SPP: (1) the actual or estimated
construction start and completion dates; (2) a description of the affected existing facilities,
including number and type(s) of customers served, historic service reliability performance
during extreme weather conditions, and how this data was used to prioritize the proposed storm
protection project; and (3) a cost estimate including capital and operating expenses.
Additionally, a description ofthe criteria used to select and prioritize proposed storm protection
projects is included in the description ofeach proposed SPP program provided in Section IV
ofthe SPP.
Does FPLos SPP provide sufficient detail to develop preliminary estimates of the rate
impacts for the second and third years (2021-2022) of the SPP?
Yes. As required by Rule 25-6.030(3Xe)(2), F.A.C., FPL has provided the estimated number
and costs of projects under each specific SPP program, which information was used to develop
the estimated rate impacts for 2021-2022. This information is provided in Appendix C to FPL's
SPP.
e See footnote I
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Did FPL provide a description of its vegetation management activities under the SPP for
the first three years (2020-2022) of the SPP?
Yes. The following additional information required by Rule 25-6.030(3X0, F.A.C., for the
first three years (2020-2022) of the vegetation management activities under the SPP is provided
in Sections IV(G) and IV(H) of FPL's SPP and Appendix C to FPL's SPP: the projected
frequency (trim cycle); the projected miles of affected transmission and distribution overhead
facilities; and the estimated annual labor and equipment costs for both utility and contractor
personnel. Additionally, descriptions of how the vegetation management activities will reduce
outage times and restoration costs due to extreme weather conditions are provided in Sections
IV(G) and IV(H) of FPL's SPP.
Has FPL provided the annual jurisdictional revenue requirements for the 2020-2029
SPP?
Yes. Pursuant to Rule 25-6.030(3Xg), F.A.C., FPL has provided the estimated annual
jurisdictional revenue requirements in Section VI of the SPP. While FPL has provided
estimated costs by program as of the time of this filing and associated total revenue
requirements in its SPP, consistent with the requirements of Rule 25-6.030, F.A.C., subsequent
projected and actual program costs submitted for cost recovery through the Storm Protection
Plan Cost Recovery Clause (per Rule 25-6.031, F.A.C.) could vary by as much as 10-150%,
which variations would also impact the associated estimated revenue requirements and rate
impacts. The projected costs, actuall estimated costs, actuals costs, and true-up ofactual costs
to be included in FPL's Storm Protection Plan Cost Recovery Clause will all be addressed in
subsequent filings in separate Storm Protection Plan Cost Recovery Clause dockets pursuant
to Rule 25-6.031, F.A.C.ro
llas FPL estimated the rate impacts for each of the first three years of the SPP?
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r0 The Commission has opened Docket No, 20200092-El to address Storm Protection Plan Cost Recovery Clause
petitions to be filed the third quarter of 2020.
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FPL anticipates the programs included in the SPP will have zero bill impacts on customer bills
during the first year of the SPP and only minimal bill increases for years two and three of the
SPP. An estimate of the hypothetical overall rate impacts for the first three years of the SPP
(2020-2022) based on the total program costs reflected in this filing, without regard for the fact
that FPL remains under a general base rate freeze pursuant to a Commission-approved
settlement agreement through December 31,2021, are provided in Section VII ofthe SPP. The
projected costs, actual/estimated costs, actuals costs, and true-up ofactual costs to be included
in FPL's Storm Protection Plan Cost Recovery Clause will all be addressed in subsequent
filings in separate storm protection plan cost recovery clause dockets pursuant to Rule 25-
6.031, F.A.C. rr
V. CONCLUSION
Does FPL believe that its SPP will achieve the legislative objectives of Section 366.96, F.S.,
to reduce costs and outage times associated with extreme weather events by promoting
the overhead hardening of electrical transmission and distribution facilities, the
undergrounding of certain electrical distribution lines, and vegetation management?
Yes. While no electrical system can be made completely resistant to the impacts of hurricanes
and other extreme weather conditions, FPL's SPP provides a systematic approach to achieve
the legislative objectives of reducing restoration costs and outage times associated with extreme
weather events and enhancing reliability. As explained above and in further detail in the SPP,
FPL's SPP programs are largely a continuation and expansion of FPL's already successful and
ongoing storm hardening and storm preparedness programs previously approved by the
Commission, as well as a new storm hardening program to protect T&D substations and
equipment from storm surge and flooding due to extreme weather events. These SPP programs
llSee footnote 10
i8
2
J
4
5
6
7
a.
A.
will continue to provide increased T&D infrastructure resiliency, reduced restoration time, and
reduced restoration costs when FPL's system is impacted by extreme weather events. FPL's
SPP appropriately and effectively maintains and builds on FPL's commitment to provide safe
and reliable electric service to customers, and to meet the needs and expectations of our
customers, today and for many years to come.
Does this conclude your direct testimony?
Yes.
19
Docket No. 2020O071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 1 of 48
Florida Power & Light Gompany
Storm Protection Plan
2020-2029
(Rule 25-6.030, F.A.C.)
Docket No. 20200071-El
April 10, 2020
il
IV
TABLE OF CONTENTS
Executive Summary.
The 2020-2029 SPP will Strengthen FPL's lnfrastructure to
Withstand Extreme Weather Conditions and will Reduce
Restoration Costs and Outage Times....
Description of Service Area and T&D Facilities.
2020-2029 SPP Programs..........
A. Pole lnspections - Distribution Program.
Docket No. 2O2O0071-E\
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 2 of 48
1
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B.
c.
1. Description of the Program and Benefits........
2, Actual/Estimated Start and Completion Dates
3 Cost Estimates
4. Comparison of Costs and Benefits.............
5. Criteria used to Select and Prioritize the Program
Structures/Other Equipment lnspections - Transmission
Program
1. Description of the Program and 8enefits..............
2. Actual/Estimated Start and Completion Dates .....
3. CostEstimates.........
4. Comparison of Costs and 8enefits.............
5. Criteria used to Select and Prioritize the Program
Feeder Hardening (EWL) - Distribution Program ...........
1. Description of the Program and 8enefits.............
2. Actual/Estimated Start and Completion Dates
3. CostEstimates.........
4. Comparison of Costs and 8enefits.............
5. Criteria used to Select and Prioritize the Program .....
Lateral Hardening (Undergrounding) - Distribution Program
1. Description of the Program and 8enefits....................
D
2. ActualiEstimated Start and Completion Dates
3. CostEstimates.........
Comparison of Costs and Benefits.............
Criteria used to Select and Prioritize the Program ....
4
5 .26
E
F
Wood Structures Hardening (Replacing) - Transmission
Program
1. Description of the Program and 8enefits..............
2. Actual/Estimated Start and Completion Dates.....
3. CostEstimates.........
4. Comparison of Costs and 8enefits.............
5. Criteria used to Select and Prioritize the Program
Substation Storm Surge/Flood Mitigation Program
1. Description of the Program and Benefits
2. Actual/Estimated Start and Completion Dates ........
3. Cost Estimates...
4. Comparison of Costs and 8enefits.................
5. Criteria used to Select and Prioritize Projects
G. Vegetation Management - Distribution Program ......
1. Description of the Program and Benefits........
2. ActualiEstimated Stad and Completion Dates
3. CostEstimates.........
4. Comparison of Costs and Benefits..
5. Criteria Used to Select and Prioritize the Program..
H. Vegetation Management - Transmission Program
1. Description of the Program and Benefits.................
2. Actual/Estimated Start and Completion Dates........
3. CostEstimates.........
4. Comparison of Costs and 8enefits.............
5. Criteria used to Select and Prioritize the Programs.
Detailed lnformation on the First Three Years of the SPP (2020-
2022)
A. Detailed Description for the First Year of the SPP (2020)..
B. Detailed Description of the Second and Third Years of the
c
sPP (2021-2022)
Detailed Description of the Vegetation Management
Activities for the First Three Years of the SPP (2020-2022)
Estimate of Annual Jurisdictional Revenue Requirements for the
Docket No. 2O2OO071-E\
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1 , Page 3 of 48
26
26
28
28
29
29
30
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31
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32
35
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36
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...41
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V
il
VI
2020-2029 SPP ..42
Docket No. 20200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 4 of 48
43
44
Vlt. Estimated Rate lmpacts for First Three Years of the SPP (2020-
2022)
Vlll. Conclusion
Appendices:
Appendix A -
Appendix B -
Appendix C -
Appendix D -
Appendix E -
FPL's Third Supplemental Response to Staffs First Data
Request No. 29 ("Third Supplemental Amended") in Docket No.
2017021s-El
FPL Management Areas and Customers Served
FPL 2020-2029 SPP Estimated Annual Costs and Estimated
Numbdr and Costs of Projects
FPL Distribution Design Guidelines
Project Level Detail for First Year of the SPP (2020)
Docket No. 20200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 5 of 48
Florida Power & Light Gompany
2020-2029 Storm Protection Plan
l. Executive Summary
Pursuant to Section 366.96, Florida Statutes ("F.S."), and Rule 25-6.030, Florida
Administrative Code ('F.A.C."), Florida Power & Light Company ("FPL') submits its Storm
Protection Plan for the ten (10) year period 2020-2029 (hereinafter, the "SPP"). As
explained herein, the SPP is largely a continuation of FPL's successful storm hardening
and storm preparedness programs previously approved by the Florida Public Service
Commission ("Commission") over the last fourteen years. FPL anticipates the programs
included in the SPP will have zero bill impacts on customer bills during the first year of
the SPP and only minimal bill increases foryears two and three of the SPP.1
Since 2006, FPL has been implementing Commission-approved programs to strengthen
its transmission and distribution ("T&D") infrastructure. These programs include multiple
storm hardening and storm preparedness programs, such as feeder hardening, replacing
wood transmission structures, vegetation management, and pole inspections. As
demonstrated by recent storm events, these ongoing storm hardening and storm
preparedness programs have resulted in FPL's T&D electricalgrid becoming more storm
resilient, experiencing less infrastructure damage and reduced restoration times, as
compared to non-hardened facilities. These programs have also provided significant
improvements in dayto-day reliability.
The success of FPL's storm hardening and storm preparedness programs has been
achieved through the development and implementation of FPL's forward-looking storm
hardening, grid modernization, and reliability initiatives and investments, combined with
the use of cutting-edge technology and strong employee commitment. Under the SPP,
FPL remains committed to continue these successful and industry-leading programs to
1 The recovery of the costs associated with the SPP, as well as the actual and projected costs to
be included in FPL's Storm Protection Plan Cost Recovery Clause, will be addressed in a
subsequent and separate Storm Protection Plan Cost Recovery Clause docket pursuant to Rule
25-6.031, F.A.C.
1
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection PIan
Exhibit MJ-1, Page 6 of 4B
further strengthen its T&D infrastructure, mitigate restoration costs and outage times,
continue to provide safe and reliable electric service to customers, and meet future
increasing needs and expectations.
As stated previously, FPL's SPP is, in large part, a continuation and expansion of its
previously approved storm hardening and storm preparedness programs, and includes
the following SPP programs:
. Pole lnspections - Distribution Program
. Structures/Other Equipment lnspections - Transmission Program
. Feeder Hardening (EWL) - Distribution Program
. Lateral Hardening (Undergrounding) - Distribution Program
. Wood Structures Hardening (Replacing) - Transmission Program
. Vegetation Management - Distribution Program
. Vegetation Management - Transmission Program
ln addition, FPL will implement a new Substation Storm Surge/Flood Mitigation Program
to harden certain targeted substations that, based on prior experience, are susceptible to
storm surge or flooding during extreme weather events.
With the exception of the new storm surgeiflood mitigation program, the majority of the
programs included in the SPP have been in place since 2007. As demonstrated by recent
storm events, these programs have been successful in reducing restoration costs and
outage times following major storms, as well as improving day-to-day reliability. FPL
submits that continuing these previously approved storm hardening and storm
preparedness programs in the SPP, together with the new storm surge/flood mitigation
substation program, is appropriate and necessary to address the mandates set forth in
Section 366.96, F.S., and Rule 25-6.030, F.A.C., as well as the expectations of FPL's
customers and other stakeholders for increased storm resiliency and will result in fewer
2
Docket No. 20200071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 7 of 48
outages, reduced restoration costs, and prompt service restoration.2 The SPP will
continue and expand the benefits of hardening, including improved dayto-day reliability,
to all customers throughout FPL's system.
The following sections provide information and details on FPL's SPP as required by and
in compliance with Rule 25-6.030, F.A.C. For the reasons explained below, FPL submits
that implementing the SPP is necessary and appropriate to achieve the goals and
requirements expressed by the Florida Legislature in Section 366.96, F.S., to reduce
restoration costs and outage times associated with extreme weather events and improve
overall service reliability to customers and the State of Florida by promoting the overhead
hardening of electrical transmission and distribution facilities, the undergrounding of
ceftain electrical distribution lines, and vegetation management.
ll. The 2020-2029 SPP will Strenqthen FPL's lnfrastructure
to Withstand Extreme Weather Gonditions and will
Reduce Restoration Gosts and Outaqe Times
Pursuant to Rule 25-6.030(3)(a), F.A.C., this section provides an overview of how the
SPP will strengthen FPL's electric utility infrastructure to withstand extreme weather
conditions by promoting the overhead hardening of electricaltransmission and distribution
facilities, the undergrounding of certain electrical distribution lines, and vegetation
management. Consistent with Rule 25-6.030(3Xb), F.A.C., this section also provides a
summary of how the SPP is expected to further reduce restoration costs and outage times
associated with extreme weather conditions and, therefore, improve overall service
reliability.
To date, significant progress has been made toward strengthening FPL's infrastructure.
For example, at year-end 2019, approximately 54o/o of FPL's distribution feeders have
been either hardened or placed underground, and approximately 96% of FPL's
transmission structures are either steel or concrete. Also, since 2006, FPL has completed
multiple system-wide cycles of distribution and transmission pole inspections and
2 As explained below, a couple of the programs included in the SPP are expected to be completed
within the next severalyears.
3
Docket No. 20200071-El
FPL's 2O20-2O29 Storm Protection Plan
Exhibit MJ-1 , Page 8 of 48
vegetation management. Within the next few years several significant milestones are
also expected to be reached, including replacement of all wood transmission structures
with steel or concrete structures by year-end 2022 and for allfeeders to be hardened or
placed underground by year-end 2024.
FPL also implemented a three-yearStorm Secure Underground Program Pilot in 2018
("SSUP Pilot") that converls certain targeted overhead laterals - laterals that have been
impacted by recent storms and have a history of vegetation-related outages and other
reliability issues - to underground laterals. At year-end 2020, the final year of the SSUP
Pilot, FPL expects 220-230 of these targeted laterals to be converted from overhead to
underground. ln addition, FPL's Design Guidelines incorporate and apply extreme wind
loading ('EWL') criteria to the design and construction of all new overhead pole lines and
major planned work, including pole line extensions, relocations, and certain pole
replacements.
FPL's SPP programs have already demonstrated that they have and will continue to
provide increased T&D infrastructure resiliency, reduced restoration time, and reduced
restoration costs when FPL's system is impacted by severe weather events. ln FPL's
Third Supplemental Response to Staff's First Data Request No. 29 ("Third Supplemental
Amended") in Docket No. 20170215-E1,3 FPL prepared and submitted an analysis of
Hurricanes Matthew and lrma that indicated the restoration construction man-hours
("CMH"), days to restore, and storm restoration costs for these storms would have been
significantly higher without FPL's storm hardening programs. Below is a summary of the
results of FPL's analysis:
Without Harden Hurricane Matthew Hurricane lrma
3 The Commission opened Docket No. 20170215-El to review electric utility preparedness and
restoration actions and to identify potential areas where infrastructure damage, outages, and
recovery time for customers could be minimized in the future.
Additional CMH (%)93,000 (36%)483,000 (40%)
2 (50o/o)4 (40%)Additional days to restore (%)
$105 (36%)$4e6 (40%)Additional restoration costs
($millions) (%)
4
Docket No. 2O200071-El
F PL's 2O2O-202g Storm Protection Plan
Exhibit MJ-1, Page I of 48
A copy of FPL's Third Supplemental Amended Response in Docket No. 20170215-El,
including the analysis referenced above, is provided in Appendix A. Based on a 40-year
net present value analysis, the savings achieved from storm hardening would equate to
$653 million (for a storm occurring once every three years) and $406 million (for a storm
occurring once every five years) for a storm similar to Hurricane Matthew and $3.1 billion
(for a storm occurring once every three years) and $1.9 billion (for a storm occurring once
every five years) for a storm similar to Hurricane lrma.
These programs have also provided increased levels of day{o-day reliability. For
example, FPL has previously submitted reports to the Commission that show hardened
feeders have performed approximately 40% better (i.e., fewer outages) on a dayto-day
basis than non-hardened feeders.a Further details on the benefits of the SPP programs
are provided throughout the remaining sections of this SPP.
Although FPL's storm preparedness and hardening programs to date have produced a
more storm resilient and reliable T&D electrical grid, FPL must continue its efforts to
storm-harden its T&D electrical grid consistent with the findings, conclusions, and
objectives of the Florida Legislature in Section 366.96, F.S. Indeed, Florida remains the
most hurricane-prone state in the nation and, with the significant coast-line exposure of
FPL's system and the fact that the vast majority of FPL's customers live within 20 miles
of the coast, a robust storm protection plan is critical to maintaining and improving grid
resiliency and storm restoration.
Safe and reliable electric service is essential to the life, health, and safety of the public,
and has become a critical component of modern life. lmportantly, as evidenced by the
significant numbers of Florida's workforce that are working remotely during the COVID-
19 pandemic, today's digital society, economy, national security, and daily life are more
dependent on reliable electric service than ever before. While no electrical system can
be made completely resistant to the impacts of hurricanes and other extreme weather
conditions, the programs included in FPL's SPP have already demonstrated that they
5
a See Appendix A.
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 10 of 48
mitigate and will continue to mitigate the impacts of future storms.s While FPL's nation-
leading initiatives have made significant progress toward strengthening FPL's
infrastructure, continuing these previously approved storm hardening and storm
preparedness programs in the SPP, together with the new storm surge/flood mitigation
substation program, is appropriate and crucial to further mitigate restoration costs and
outage times, continue to provide safe and reliable electric service to customers, and
meet current and future needs and expectations of customers, today and for many years
to come.
lll. Description of Service Area and T&D Facilities
Pursuant to Rule 25-6.030(3)(c), F.A.C., this section provides a description of FPL's
service area, including areas prioritized for enhancement, if any, and any areas where
FPL has determined that enhancement of its existing T&D facilities would not be feasible,
reasonable, or practical at this time.
Today, FPL's service territory consists of approximately 28,000 square miles. To serve
its more than 5 million customers, FPL has constructed a T&D electric grid that contains
approximately 75,000 miles of electrical lines, including:
. Approximately 42,000 miles of overhead distribution lines;
. Approximately 26,000 miles of underground distribution lines;
. Approximately 7,000 miles of high-voltage transmission lines;
. Approximately 1.2 million distribution poles; and
. Approximately 68,000 transmission structures.
FPL's service territory is divided into sixteen (16) distribution management areas. A map
depicting FPL's service territory and distribution management areas (with the number of
customers served within each management area) is provided in Appendix B.
At this time, FPL has not identified any areas of its service territory where its SPP
programs would not be feasible, reasonable, or practical. While all of FPL's SPP
5 lt is important to note that despite the implementation of these storm hardening and storm
preparedness programs, outages will still occur when severe weather events impact Florida.
6
Docket No. 202O0071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 1 1 of 48
programs are currently system-wide initiatives, annual activities are prioritized based on
certain factors such as last inspection date, last trim date, reliability performance, and
efficient resource utilization.o At this time, there is no area specifically targeted or
prioritized for enhanced performance based on its geographical location.
lV. 2020-2029 SPP Proqrams
Pursuant to Rule 25-6.030(3XcXd), F.A.C., this section provides a description of each
program included in FPL's SPP. lf applicable, each program description below includes:
(1) a description of how each program is designed to enhance FPL's existing transmission
and distribution facilities including an estimate of the resulting reduction in outage times
and restoration costs due to extreme weather conditions; (2) identification of the actual or
estimated start and completion dates of the program; (3) a cost estimate including capital
and operating expenses; (4) a comparison of the costs and the benefits; and (5) a
description of the criteria used to select and prioritize storm protection programs.
A. Pole Inspections - Distribution Program
1 n the P ram and
The Pole lnspection - Distribution Program included in the SPP is a continuation of FPL's
existing Commission-approved distribution pole inspection program. Below is an
overview of FPL's existing distribution inspection program and its associated benefits.
a. Overview of the Distribution Pole I nsoection Prooram
ln response to the 2004-2005 storm seasons and, in particular, the "large number of poles
throughout Florida that required replacement," the Commission required investor-owned
utilities ("lOUs") to implement an eight-year pole inspection cycle for all wood distribution
poles.T FPL's plan was approved in September 20068 and modified in January 2007.e
6 The criteria and factors used to select and prioritize projects within each SPP program are
described below.
7 See Order No. PSC-06-0144-PAA-E|.
I See, Order No. PSC-06-0778-PAA-EU.
e See Order No. PSC-07-0078-EU.
7
Docket No. 2020007t-El
FPL'i 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 12 of 48
Subsequently, FPL expanded its distribution pole inspection plan to also include concrete
poles.
FPL's eight-year pole inspection cycle for all distribution poles targets approximately 1/8
of the system annually (the actual number of poles inspected can vary somewhat from
year to year). To ensure inspection coverage throughout its service territory, FPL
established nine (9) inspection zones (based on FPL's management areas and pole
population) and annually performs pole inspections of approximately 1/8 of the distribution
poles in each of these zones, as well as any necessary remediation as a result of such
inspections. FPL utilizes Osmose Utilities Services, lnc. ("Osmose"), an industry-leading
pole inspection contractor, to perform the system-wide inspection of its distribution poles.
FPL's strength and loading calculations for its distribution poles and pole inspections are
based on the National Electrical Safety Code's ("NESC') Grade B construction standard,
as outlined by Table 261-1A section 26 of the NESC. Osmose utilizes mobile computing
technology to record inspection data and to calculate strength and loading. The loading
calculation, span lengths, attachment heights, and wire sizes are recorded in the mobile
computer to determine whether the remaining pole strength capacity meets or exceeds
NESC requirements. This data is then transferred to FPL's Geographic lnformation
System ("GlS"). Pole locations inspected by Osmose are also randomly audited by FPL
to verify that inspections are completed and meet inspection standards.
lnspections include a visual inspection of all distribution poles from the ground-line to the
top of the pole to identify visualdefects (e.9., woodpecker holes, split tops, decayed tops,
cracks, etc.). lf, due to the severity of the defects, the poles are not suitable for continued
service, the poles are designated for replacement.
Wood poles that pass the above-ground visual inspection are excavated to a depth of 18"
(where applicable), and sounded and bored to determine the internal condition of the
pole. Poles encased in concrete or asphalt are not excavated, but are sounded and bored
to determine their internal condition using a standard industry-accepted inspection
process called "Shell Boring." All suitable wood poles receive external and/or internal
preservative treatment or, if not suitable, are replaced. Strength calculations are also
8
Docket No. 20200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 13 of 4B
performed on wood poles to determine compliance with NESC requirements. The poles
that are not suitable for continued service are designated for replacement or remediation.
ln 2014, FPL obtained Commission approval to: (1) exempt the loading assessment
during the second eight-year cycle for any pole that had less than 80% of full load during
FPL's initial eight-year cycle; and (2) excavate Chromium CopperArsenate ('CCA') poles
every 28 years (extended from 16 years originally approved by the Commission).10 To
ensure that these exceptions to the standard eight-year inspection cycle do not
compromise existing safety and storm hardening programs, FPL conducts annual testing
on 1o/o of the exempted poles.
b. Benefits of the Distribution Pole lnspection Proqram
The Commission has previously found that "efforts to maintain system components can
reduce the impact of hurricanes and tropical storms upon utilities' transmission and
distribution systems," and noted that an "obvious key component in electric infrastructure
is the transmission and distribution poles.'11 The Commission has also previously
identified multiple benefits of and reasons for justifying pole inspections cycles for electric
utilities, including, but no limited to: the likelihood of increased hurricane activity in the
future; the high probability for equipment damage if a pole fails during a storm; the
likelihood that failure of one pole often causes other poles to fail; the fact that deteriorated
poles are more prone to fail when exposed to high winds; the fact that Florida electric
utilities replaced nearly 32,000 poles during the 2004 storm restoration efforts; and the
fact that restoration times increase significantly when a large number of poles fail, which
limits the electric utilities' ability to respond quickly to widespread outages.l2
ln addition to the benefits discussed above that underlie the creation of the Commission's
mandated pole inspection requirements, recent storm events indicate that FPL's
distribution pole inspection program has contributed to the overall improvement in
distribution pole performance during storms, resulting in reductions in storm damage to
poles, days to restore, and storm restoration costs. The table below compares distribution
10 See Order No. PSC-14-0594-PAA-El
11 See Order No. PSC-06-0144-PAA-E.
12 See id.
I
Docket No. 20200071-El
FPL's 2O2O-2029 Storm Protection Plan
Exhibit MJ-1, Page '14 of 48
pole performance for Hurricane Wilma, which occurred in 2005 before FPL implemented
its current distribution pole inspection program, and Hurricane lrma, which occurred in
2017 after FPL implemented its current distribution pole inspection program:
Hurricane Wilma Hurricane lrma
H u rricane Strength (Category)3 4
Customer Outages (Millions)3.2 4.4
Distribution Poles Replaced >12,400 <2,90013
Total Days to Restore 18 10
Average Days to Restore 5.4 2.1
FPL's Commission-approved distribution pole inspection program has facilitated the
replacement and/or strengthening of over 140,000 distribution poles since it was first
implemented in 2006 and has directly improved and will continue to improve the overall
health and storm resiliency of its distribution pole population.
2. Actual/Estimated Start and Completion Dates
The SPP will continue FPL's ongoing Commission-approved distribution pole inspection
program described above. With approximately 1.2 million distribution poles as of year-
end 2019, FPL expects to inspect approximately 150,000 poles annually (spread
throughout its nine inspection zones) during the 2020-2029 SPP period.
3. Cost Estimates
Estimated/actual annual distribution pole inspection costs are a function of the number of
inspections estimated to be/actually completed and the number of poles estimated to
be/actually remediated/replaced as a result of the annual inspections. Although costs to
inspect the poles are operating expenses, the vast majority of pole inspection program
costs are capital costs resulting from remediation/replacement of poles that fail
inspection.
13 Approximately 99% of distribution poles replaced after Hurricane lrma were non-hardened
poles.
10
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 15 of 48
The table below provides a comparison of the 2017-2019 total actual distribution pole
inspection costs with the 2020-2022 (first three years of the SPP) total estimated
distribution pole inspection costs and the 2020-2029 lotal estimated distribution pole
inspection costs:
Total Program Costs Annual Average Program
millions Costs millions
Further details regarding SPP estimated distribution pole inspection costs, including
estimated annual capitalexpenditures and operating expenses, are provided in Appendix
c.14
4. Comparison of Costs and Benefits
As provided in Section (lV)(A)(3) above, during 2020-2029, total costs for FPL's Pole
lnspection - Distribution Program are expected to average approximately $61 million per
year. Benefits associated with FPL's Pole lnspection - Distribution Program, discussed
in Sections ll and IV(AX1)(b) above, include a more storm resilient pole population that
will result in reductions in pole failures and poles needing to be replaced during storms,
fewer storm-related outages and reductions in storm restoration costs.
5. Criteria used to Select and Prioritize the Proqram
Poles to be inspected annually are selected/prioritized within each of the nine (9)
inspection zones established throughout FPL's service territory based on the last cycle's
inspection dates, to ensure that poles are in compliance with FPL's established eight-year
14 Note, the 2020-2029 program costs shown above are projected costs estimated as of the time
of this filing. Subsequent projected and actual costs could vary by as much as 10% to 15%. The
annual projected costs, actual/estimated costs, actuals costs, and true-up of actual costs to be
included in FPL's Storm Protection Plan Cost Recovery Clause will all be addressed in
subsequent and separate Storm Protection Plan Cost Recovery Clause filings pursuant to Rule
25-6.031, F.A.C. The Commission has opened Docket No.20200092-El to address Storm
Protection Plan Cost Recovery Clause petitions to be filed the third quarter of 2020.
2017-2019 $1 52 $51
2020-2022 $1 70 $sz
2020-2029 $605 $61
11
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1, Page 16 of 48
cycle. As such, approximately 1/8 of the distribution poles in each inspection zone are
inspected annually.
At this time, FPL has not identified any areas where the Pole lnspection - Distribution
Program would not be feasible, reasonable or practical.
B.Structures/Other Equipment lnspections Transmission
Program
1. Description of the Prooram and Benefits
The Structures/Other lnspections - Transmission Program included in the SPP is a
continuation of FPL's existing Commission-approved transmission inspection program.
Below is an overview of FPL's existing transmission inspection program and the
associated benefits.
a Overview of the Transmission nsnecfion Prooram
ln 2006, as part of its Storm Preparedness lnitiative No. 3, the Commission required
electric utilities to develop and implement plans to fully inspect alltransmission structures,
substations, and all hardware associated with these facilities on a six-year cycle.
Consistent therewith, FPL implemented a Commission-approved transmission inspection
plan in 2006 and has continued that plan to date.
Under its Commission-approved transmission inspection plan, FPL inspects its
transmission circuits, substations, and other equipment on a six-year cycle. Additionally,
all of FPL's transmission structures are visually inspected from the ground each year.
Finally, FPL performs climbing or bucket truck inspections on all wood transmission
structures on a six-year cycle and all steel and concrete structures on a ten-year cycle.
lnspections for wood structures include an overall assessment of the condition of the
structures, as well as other pole/structure components including the foundation, all
attachments, insulators, guys, cross-braces, cross-arms, and bolts. lf a wood
transmission structure does not pass visual inspection, it is designated for replacement
with a concrete or steel transmission structure.
12
Docket No. 20200071-El
FPL'i 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 17 of 48
For steel and concrete structures, the visual inspection includes an overall assessment
of the structure condition (e.9., cracks, chips, exposed rebar, and rust) as well as other
pole/structure components including the foundation, all attachments, insulators, guys,
cross-braces, cross-arms, and bolts. lf a concrete or steel pole/structure fails the
inspection, it is designated for repair or replacement.
The SPP will continue FPL's current transmission inspection program which requires: (a)
transmission circuits and substations and all associated hardware to be inspected on a
six-year cycle; (b) wood structures to be inspected visually from the ground each year
and climbing or bucket truck inspections to be conducted on a six-year cycle; and (c) steel
and concrete structures to be inspected visually each year and climbing or bucket truck
inspections to be conducted on a ten-year cycle.
b. Benefits of the Transmission lnspection Proqram
As noted in Section |V(AX1)(b) above, the Commission has found numerous benefits and
reasons justifying inspections of electrical utility facilities, including transmission facilities.
lmportantly, the transmission system is the backbone of the electric grid. While outages
associated with distribution facilities (e.9., a transformer, lateral orfeeder) can result in
an outage affecting anywhere from a few customers up to several thousands of
customers, a transmission related outage can affect tens of thousands of customers.
Additionally, an outage on a transmission facility could cause cascading (a loss of power
at one transmission facility can trigger the loss of power on another interconnected
transmission facility, which in turn can trigger the loss of power on another interconnected
transmission facility, and so on) and result in the loss of service for hundreds of thousands
of customers. As such, it is imperative that transmission facilities be properly inspected
using appropriate cycles and standards to help ensure they are prepared for storms.
Further, the performance of FPL's transmission facilities during recent storm events
indicates FPL's transmission inspection program has contributed to the overall storm
resiliency of the transmission system and provided savings in storm restoration costs.
The table below compares the performance of FPL's transmission system for Hurricane
Wilma, which occurred in 2005 before FPL implemented its current transmission
13
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-'l , Page 18 of 4B
inspection program, and Hurricane lrma, which occurred in 2017 after FPL implemented
its current transmission inspection program:
Transmission Facilities Hurricane Wilma Hurricane lrma lm ent
As shown above, the impacts on FPL's transmission facilities associated with Hurricane
lrma were significantly reduced from those experienced with Hurricane Wilma, even
though Hurricane lrma's winds were stronger and its path impacted substantially more of
FPL's facilities. As reflected in the Commission's reasoning for mandating transmission
facility inspections, FPL submits that its systematic transmission inspection program is a
key factor for this improved performance.
2. Actual/Estimated Start and Completion Dates
The SPP will continue FPL's ongoing Commission-approved transmission inspection
program described above. This requires FPL to inspect: (a) transmission circuits and
substations and all associated hardware on a six-year cycle, (b) wood structures to be
visually inspected from the ground each year and conduct climbing or bucket truck
inspections on a six-year cycle; and (c) steel and concrete structures visually each year
and conduct climbing or bucket truck inspections on a ten-year cycle.
3. Cost Estimates
Estimated/actual annual transmission inspection costs are a function of the number of
inspections estimated to be/actually completed and the transmission facilities estimated
to be/actually remediated/replaced as a result of those annual inspections. Although the
inspection costs are operating expenses, the vast majority of the transmission inspection
program costs are capital costs resulting from remediation/replacement of facilities that
fail inspection.
The table below provides a comparison of the 2017-2019 total actual transmission
inspection costs with the 2020-2022 (first three years of the SPP) total estimated
345 215 38%Line Section Outages
62YoSubstation Outages 241 92
95o/o1005Structures Failed
14
Docket No. 2O2O007|-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , Page 19 of 48
transmission inspection costs and the 2020-2029 totalestimated transmission inspection
COSTS:
Total Program Costs Annual Average Program
millions Costs millions
Further details regarding the SPP estimated transmission inspection costs, including
estimated annual capitalexpenditures and operating expenses, are provided in Appendix
c.15
4. Comparison of Costs and Bengfilg
As provided in Section |V(BX3) above, during 2020-2029, total costs for FPL's
Structures/Other lnspections - Transmission Program are expected to average
approximately $50 million per year. Benefits associated with the Structures/Other
lnspections - Transmission Program discussed in Sections ll and |V(BX1)(b) above,
include avoiding outages that can affect tens of thousands of customers and, in particular,
cascading outages where the loss of service can affect hundreds of thousands of
customers.
5. Criteria used to Select and Prioritize the Proqram
As explained above, FPL visually inspects from the ground alltransmission structures on
an annual basis. For the inspection of transmission circuits and substations and all
associated hardware, the facilities are selected/prioritized throughout FPL's service
territory based on the last cycle's inspection dates, to ensure that facilities are inspected
in compliance with the established six-year inspection cycle. Similarly, for bucket truck
or climbing inspections, structures are selected/prioritized throughout FPL's service
territory based on the last cycle's inspection dates, to ensure that structures are inspected
2017-2019 $1 28 $43
2020-2022 $e7 $32
$500 $502020-2029
15 See footnote 14
15
Docket No. 20200O71-El
F PL's 2O20-2029 Storm Protection Plan
Exhibit MJ-'1 , Page 20 of 4B
in compliance with the established six-year (wood) and ten-year (steel and concrete)
cycles.
At this time, FPL has not identified any areas where the Structures/Other lnspections -
Transmission Program would not be feasible, reasonable or practical.
Feeder Hardening (EWL) - Distribution Program
1. Description of the Proqram and Benefits
The Feeder Hardening (EWL) - Distribution Program included in the SPP is a
continuation of FPL's existing Commission-approved approach (most recently approved
in Docket No.20180144-El) to harden existing feeders and ceftain critical distribution
poles, as well as FPL's initiative to design and construct new pole lines and major planned
work to meet the NESC's extreme wind loading criteria ("EWL'). FPL will continue the
distribution feeder hardening program untll2024, when FPL expects 100% of its feeders
to be hardened or underground. Below is an overview of FPL's existing distribution feeder
hardening program and the associated benefits.
a. Overview of the Distribution Feeder Hardeninq Proqram
The foundation for FPL's distribution feeder hardening program was the extensive
forensic and other analyses that FPL conducted after Hurricane Wilma.16 These analyses
concluded that "wind only" (as opposed to, for example, trees or other flying debris) was
the predominant root cause of distribution pole breakage. This data, together with the
overall performance of FPL's transmission poles that were already built to the NESC EWL
standards and the performance of hardened feeders during Hurricanes Matthew and
lrma, formed the basis for FPL's feeder hardening strategy.
The SPP will continue FPL's previously approved approach to apply EWL criteria to
harden existing distribution feeders and ceftain critical poles. The NESC extreme wind
map for Florida will continue to be applied to FPL's system by dividing the application of
16 These analyses were conducted either directly by FPL or with the aid of external resources
(e.9., KEMA, lnc.).
c
16
Docket No. 202O0071-El
F PL's 2O20-2029 Storm Protection Plan
Exhibit MJ-'1 , Page 2'1 of 48
EWL into three wind regions, corresponding to expected extreme winds of 105, 130 and
145 mph, as shown below.
FPL Extreme Wind Reqions - mph (meter/sec)
r4o(G3)
105 mph
130 mph
145 mph
so(Gn
By evaluating each of the counties served by FPL, including each county's applicable
wind zones, FPL determined that utilizing three extreme wind regions of 105, 130 and
145 mph for its service territory was appropriate for the following reasons:
A smaller number of wind regions generate advantages through efficiency of
work methods, training, engineering and administrative aspects (e.9.,
standards development and deployment); and
I
E
a
Using 105, 130 and 145 mph wind zones is a well balanced approach that
recognizes differences in the EWL requirements in the counties within each
region.
The SPP will also continue to utilize FPL's Design Guidelines and processes that apply
EWL criteria to the design and construction of new pole lines and major planned work,
including pole line extensions and relocations and certain pole replacements. Depending
on the scope of the work that is performed in a particular project, this could result in the
EWL hardening of an entire circuit (in the case of large-scale projects) or in EWL
hardening of one or more poles (in the case of small projects) so that the affected circuit
will be in a position to be fully EWL hardened in the future. The Design Guidelines are
17
Docket No. 20200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 22 ot 48
primarily associated with changes in pole class, pole type, and desired span lengths to
be utilized. The Design Guidelines standardize the design and construction of new pole
lines and major planned work to ensure that these projects align with FPL's hardening
strategy.
FPL's current pole sizing guidelines provide for a minimum installation of: Class 2 wood
poles for all new feeder and three-phase lateral work; Class 3 wood pole for two-phase
and single-phase lateral work; and Class 3 wood pole for service and secondary work.
For critical poles, FPL's current pole sizing guidelines provide for the installation of
concrete poles at accessible locations. These guidelines significantly increase the wind
ratings (up to nearly 50 percent) from the Design Guidelines in place prior to 2007. FPL's
current Distribution Design Guidelines are provided in Appendix D.
To determine how an existing overhead circuit or critical pole will be hardened, a field
survey of the circuit facilities is performed. By capturing detailed information at each pole
location, such as pole type, class, span distance, attachments, wire size, and framing, a
comprehensive wind-loading analysis can be performed to determine the current wind
rating of each pole, and ultimately the circuit itself. This data is then used to identify
specific pole locations on the circuit that do not meet the desired wind rating. For all poles
that do not meet the applicable EWL, FPL develops recommendations to increase the
allowable wind rating of the pole.
FPL plans to continue to utilize its "design toolkit" that focuses on evaluating and using
cost-effective hardening options for each location, including:
Storm Guying - lnstalling a guy wire in each direction perpendicular to the line,
which is a very cost-effective option but is dependent on proper field conditions;
Equipment Relocation - Moving equipment on a pole to a stronger pole near-
by;
lntermediate Pole - lnstalling an additional single pole within long span lengths,
which reduce the span length and increases the wind rating of both adjacent
poles;
a
a
a
18
Docket No. 20200071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-'l , Page 23 of 48
Upgrading Pole Class - Replacing the existing pole with a higher class pole to
increase the pole's wind rating; and;
Undergrounding Facilities - Evaluated on a case-by-case basis using site-
specific factors and conditions.
These options are not mutually exclusive and, when used in combination with sound
engineering practices, provide cost-effective methods to harden a circuit. FPL's design
recommendations also take into consideration issues such as hardening, mitigation
(minimizing damage), and restoration (improving the efficiency of restoration in the event
of failure). Since multiple factors can contribute to losing power after a storm, utilizing
this multi-faceted approach to pole design helps to reduce the amount of work required
to restore power to a damaged circuit.
b. Benefits of the Distribution Feeder Hardeninq Program
Distribution feeders are the backbone of the distribution system and are critical
component to providing safe and reliable electric service to FPL's customers. Thus,
improving the storm resiliency of distribution feeders logically provides substantial
benefits for customers. Therefore, hardening distribution feeders has been and continues
to be one of FPL's highest storm hardening priorities.
During the period 2006-2019, FPL hardened over 1,300 existing feeders, the vast majority
being Critical lnfrastructure Function ("ClF") feeders (i.e., feeders that serve hospitals,
911 centers, police and fire stations, water treatment facilities, county emergency
operation centers) and Community Project feeders (i.e., feeders that serve other key
community needs like gas stations, grocery stores, and pharmacies) throughout FPL's
service territory. Additional feeders were hardened as a result of FPL's Priority Feeder
lnitiative, a reliability program that targeted feeders experiencing the highest number of
interruptions and/or customers interrupted. As of year-end 2019, approximalely 54o/o of
FPL's feeders were either hardened or placed underground. Additionally, FPL has
hardened 125 highway crossings and over 300 "01" switches (first pole out of a substation
with a feeder switch). FPL also applied EWL to the design and construction of new pole
a
a
19
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 24 ol 48
lines and major planned work, including pole line extensions and relocations and certain
pole replacements.
As provided in previous FPL Annual Reliability Report filings and three-year Storm
Hardening Plan filings (per Rule 25-6.0342, F.A.C.) hardened feeders perform better than
non-hardened feeders. This has been demonstrated in-day-to-day reliability performance
and during severe storms. For example, when comparing day-to-day reliability
performance, hardened feeders have performed 40o/o better than non-hardened feeders.
AIso, during Hurricanes Matthew and lrma, hardened feeders performed better than non-
hardened feeders.
Additionally, in Docket No. 20170215-EU, the Commission reviewed the electric utilities'
storm hardening and storm preparedness programs and found for Hurricane lrma that:
(1) outage rates were nearly 20% less for hardened feeders than non-hardened feeders;
(2) CMH to restore hardened feeders were 50% less than non-hardened feeders
(primarily due to hardened feeders experiencing less damage than non-hardened
hardened feeders); and (3) hardened feeders had significantly less pole failures as
compared to non-hardened feeders.lT
2. Actual/Estimated Start and Completion Dates
FPL initiated its feeder hardening initiative in 2006. As of year-end 2019, there are
approximately 1,600 feeders remaining to be hardened or placed underground. FPL
expects to harden approximately 250-350 feeders annually, with 100% of FPL's feeders
expected to be hardened or underground by year-end 2024 and with the final costs of the
program to be incurred in 2025.
17 See Review of Florida's Electric Utility Hurricane Prepared ness and Restoration Actions 2018,
Docket No. 20170215-EU (July 24,2018), available at
http://www.psc.state.fl.us/librarvffilinqs/2018/04847-2018/04847-2018.pdf.
20
Docket No. 20200071-El
FPL's 2O2O-2029 Storm Protection Plan
Exhibit MJ-1, Page 25 of 48
3. Cost Estimates
Estimated distribution feeder hardening costs are determined utilizing the length of each
feeder, the average historical feeder hardening cost per mile, and updated cost
assumptions (e.9., labor and materials).
The table below provides a comparison of the 2017-2019 total actual distribution feeder
hardening costs with the 2020-2022 (first three years of the SPP) total estimated
distribution feeder hardening costs and the total estimated distribution feeder hardening
costs to be incurred over the period of 2020-202518:
Total Program Gosts Annual Average Program
millions Costs illions
Further details regarding the SPP distribution feeder hardening costs, including estimated
annual capital expenditures are provided in Appendix C.1s
4. Comparison of Costs and Benefits
As provided in Section lV(C)(3) above, during 2020-2025, total costs for FPL's Feeder
Hardening (EWL) - Distribution Program average approximately $534 million per year
through 2025. Benefits associated with the Feeder Hardening (EWL) - Distribution
Program discussed in Sections ll and |V(CX1Xb) above, include improved storm
resiliency as well as improved day{o-day reliability.
5. Criteria used to Select and Prioritize the Proqram
As explained above, there are approximately 1,600 feeders remaining to be hardened or
placed underground. FPL attempts to spread its annual projects throughout its service
territory. ln prioritizing the remaining existing feeders to be hardened each year,
18 lt is currently estimated that 100% of FPL's feeders will be hardened or underground by year-
end 2024, with the final costs to be incurred in 2025.
1e See footnote 14.
2017-2019 $1,492 $497
2020-2022 $1,959 $653
2020-2025 $3,206 $534
21
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 26 of 48
considerations include the feeder's historical reliability performance, restoration
difficulties (e.9., environmentally sensitive areas, islands with no vehicle access, river
crossings, etc.), on-going or upcoming internal/external projects (e.9., FPL maintenance
or system expansion projects, municipal overhead/underground conversion project or
municipal road project) and geographic location.
At this time, FPL has not identified any areas where the Feeder Hardening (EWL) -
Distribution Program would not be feasible, reasonable or practical.
D. Lateral Hardening (Undergrounding) - Distribution Program
1. Description of the Proqram and Benefits
ln 2018, FPL implemented a three-year Commission-approved SSUP Pilot. The SSUP
Pilot is a program that targets certain overhead laterals for conversion from overhead to
underground. As part of its SPP, FPL will expand undergrounding laterals in 2021-2029.
Below is an overview of FPL's Lateral Hardening (Undergrounding) - Distribution
Program and the associated benefits.
a. Overview of the Distribution Lateral Hardening Proqram
As part of the SPP, FPL will complete its existing approved three-year SSUP Pilot (in
2020) and expand the application of the SSUP during 2021-2029 to the implementation
of the system-wide Lateral Hardening (Undergrounding) - Distribution Program. The
SSUP Pilot targeted certain overhead laterals that were impacted by recent storms and
that have a history of vegetation-related outages and other reliability issues for conversion
from overhead to underground. Key objectives of the SSUP Pilot included validating
conversion costs and identifying cost savings opportunities, testing different design
philosophies, better understanding customer impacts and sentiments, and identifying
barriers (e.9., obtaining easements, placement of transformers, and attaching entities'
issues).
Two design options are being utilized when FPL converts overhead laterals to
underground, referred to as the North American and the European designs. The North
American design currently is the predominant design, but both undergrounding designs
eliminate all overhead lateral and service wire. The North American design generally
22
Docket No. 20200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 27 of 48
utilizes more primary conductor and a greater number of smaller-sized transformers, with
less customers per transformer, and is better suited for front lot construction and service.
The European design utilizes more secondary conductor, and a smaller number of larger-
sized transformers, with more customers per transformer, and is better suited for rear lot
construction and service. Where practical, FPL attempts to relocate existing facilities from
the rear of to the front of customers' premises; however, there are instances where that
option is not available (e.9., FPL is unable to obtain easements in front of customers'
premises). FPL's standard design is the North American design (front lot construction),
but FPL is gaining important experience and knowledge from its utilization of the
European design (rear lot construction), which it can then better utilize for future projects
as appropriate.
As part of the conversion process, FPL is also installing meter base adaptors that allow
underground service to be provided to the customer by utilizing the existing meter and
meter enclosure. The meter base adaptors minimize the impact on customer-owned
equipment and facilities. For example, in ceftain situations, overhead to underground
conversions of electric service can trigger a local electrical code requirement that
necessitates a customer upgrade of the home's electric service panel. This can cost the
customer thousands of dollars. However, by utilizing a meter base adaptor, overall costs
are reduced and customers are able to avoid the need and expense to convert their
electrical service panels.
b. Benefits of the Distribution Lateral Hardenino Prooram
Laterals make up the majority of FPL's distribution system. For example, system-wide,
there are over 180,000 laterals (including lateralswith multi-stage fusing), in contrastto
approximately 3,300 feeders, and there are 1.8 times as many miles of overhead laterals
as there are overhead feeders (approximately 23,000 miles vs. 13,000 miles,
respectively). Additionally, while feeders are predominately located in the front of
customers' premises, many laterals are "rear of' or behind customers' premises. This is
especially the case in older neighborhoods located throughout FPL's service territory.
Generally, facilities in the rear of customers' premises take longer to restore than facilities
in front of customers' premises because rear-located facilities are more difficult to access
23
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 2B of 48
and are more likely to be near vegetation. This results in a greater amount of CMH being
devoted to laterals during storm restoration.
The basis for FPL's SSUP Pilot and the proposal to expand upon the Pilot under the SPP
is the performance of the underground facilities as compared to overhead facilities and
the extensive damage to the overhead facilities caused by vegetation during Hurricanes
Matthew and lrma. This performance was demonstrated by the results of FPL's analysis
referenced above in Section |V(AX1)(b) and contained in the Commission's Review of
Florida's Electric Utility Hurricane Preparedness and Restoration Actions in 2018,2o which
is summarized in the table below:
Storm and Faci Laterals Out Total Laterals % Out
Finally, it is important to note that underground facilities also perform better than overhead
facilities on a day-to-day basis. For example, based on the reliability performance metrics
for overhead and underground facilities provided to the Commission in FPL's February
28,2020 Annual Reliability Report filing, the System Average lnterruption Duration lndex
("SAlDl') for underground facilities is significantly better than hybrid facilities (combination
of overhead and underground) or overhead facilities as shown in the table below:
SAIDI2l
Year UG OHH brid
20 See footnote 17.
21 See pages 93-97 of FPL's February 28, 2020 Annual Reliability Report filing for more details
on day-to-day reliability performance - overhead vs. underground.
3,473 82,729 4o/oMatthew OH
Matthew UG 238 101,892 0.2o/o
lrma OH 20,341 84,574 24o/o
103,384 4o/olrma UG 3,767
2015 21.4 102.4 60.0
17.2 80.4 57.62016
2017 17.7 89.6 55.5
2018 21.2 89,0 54.2
87.4 49.4201930.3
24
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 29 of 48
2. Actual/Estimated Start and Completion Dates
FPL's SSUP Pilotwas initiated in 2018. Bythe end of 2020, the third and final yearof
the SSUP Pilot, FPL expects to have converted a total of 220-230laterals from overhead
to underground, which is consistent with the SSUP Pilot's plan most recently approved in
Docket No. 20180144-El. As part of its SPP, FPL will incorporate, continue, and expand
the SSUP to provide the benefits of underground lateral hardening throughout its system.
After completing the SSUP Pilot in 2020, FPL estimates it will convert 300-700 laterals
annually. ln 2024-2029 FPL estimates it will convert 800-900 laterals annually.
3. Cost Estimates
Estimated lateral undergrounding costs are determined utilizing the length of each lateral,
the average historical lateral undergrounding cost per mile, and updated cost
assumptions (e.9., labor and materials). The table below provides a comparison of the
2018-2019 total actual costs for the SSUP Pilot with the 2020-2022 (first three years of
the SPP) total estimated distribution lateral hardening program costs and the 2020-2029
total estimated distribution lateral hardening program costs:
Total Annual Average
P ram Costs millions ram Gosts illions
Further details regarding the SPP estimated distribution lateral hardening program costs,
including estimated annual capital expenditures are provided in Appendix C.23
4. Comparison of Costs and Benefits
As provided in Section |V(DX3) above, during 2020-2029, total costs for FPL's Lateral
Hardening (Undergrounding) - Distribution Program average approximately $510 million
per year. Benefits associated with the Lateral Hardening (Undergrounding) - Distribution
22 The Storm Secure Underground Program Pilot was initiated in 2018
23 See footnote 14.
2019-201922 $76 $38
2020-2022 $676 $225
2020-2029 $5,101 $s1 0
25
Docket No. 20200071-El
FPL'S 2O2O-2O29 Storm Protection Plan
Exhibit MJ-1 , Page 30 of 4B
Program discussed in Sections ll AND |V(DX1)(b) above, include improved storm
resiliency as well as improved day-to-day reliability.
5. Criteria used to Select and Prioritize the Proqram
FPL will select/prioritize future laterals for conversion to undergrounding based on an
overall feeder performance methodology. Rather than selecting individual "stand-alone"
laterals, FPL will underground all the laterals on a feeder such that when a hardened
feeder that has experienced an outage is restored, all associated underground laterals
would also be restored (unless the underground lateralwas damaged).
On average, there are currently 20-30 overhead laterals on a feeder. The selection and
prioritization of the laterals to be converted will be based on a methodology that considers:
(a) all of the overhead laterals on each feeder; (b) outage experience during the recent
Hurricanes Matthew and lrma; (c) the number of vegetation-related outages experienced
over the most recent 10 years; and (d) the total number of lateral and transformer outages
experienced over the most recent 10 years. These overhead lateral factors are totaled
for each feeder, and the feeders are ranked based on these totals. All laterals on the
feeders will then be hardened according to the ranking of each feeder.
In order to optimize resources and provide lateral hardening throughout FPL's system,
lateral hardening projects will be performed annually in all sixteen (16) of FPL's
management areas. At this time, FPL has not identified any areas where the Lateral
Hardening (Undergrounding) - Distribution Program would not be feasible, reasonable,
or practical. However, in areas that are more prone to flooding or storm surge, FPL will
consider alternative construction methods (e.9., elevating transformer pads).
E Wood Structures Hardening (Replacing) - Transmission
Program
1. Descriptio n of the Prooram and Benefits
The Wood Structure Hardening (Replacing) - Transmission Program included in the SPP
is a continuation of FPL's existing transmission hardening program through the end of
2022, when FPL expects that 100% of its transmission structures will be steel or concrete.
26
Docket No. 20200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 31 of 48
Below is an overview of FPL's existing transmission wood structure hardening program
and the associated benefits.
a. Overview of the Transmission Hardening Program
While FPL's transmission facilities were affected by the 2004 and 2005 storms, the
damage experienced was significantly less than the damage sustained by distribution
facilities. A primary reason for this resulted from the fact that transmission structures were,
at that time, already constructed to meet EWL consistent with Florida Statute 366.04 and
the National Electrical Safety Code, Rule 250 C.
Based on the forensic data collected from the 2004 and 2005 storms, FPL implemented a
Commission-approved transmission storm hardening initiative to replace all wood
transmission structures, which accounted for nearly 70 percent of all transmission
structures replaced during the2004-2005 storm seasons, with steelor concrete structures.
As explained below, this initiative is ongoing and expected to be completed by the end of
2022. As part of its SPP, FPL will continue its initiative to replace all wood transmission
structures with steel or concrete structures.
b. Benefits of the Transmission Hardening Program
While an outage associated with distribution facilities (e.9., a transformer, lateral, or
feeder) can impact up to several thousands of customers, a transmission-related outage
can result in an outage affecting tens of thousands of customers. Additionally, an outage
on a transmission facility could cause cascading (a loss of power at one transmission
facility can trigger the loss of power on another interconnected transmission facility, which
in turn can trigger the loss of power on another interconnected transmission facility, and
so on) and result in the loss of service for hundreds of thousands of customers. As a
result, the prevention of transmission-related outages is essential. As discussed earlier,
while transmission facilities performed significantly better than distribution facilities during
the 2004 and 2005 storms, there were several opportunities for improvement identified,
including the replacement of wood transmission structures. As a result of its transmission
inspection programs and its replacement of wood transmission structures, FPL's
transmission facilities have demonstrated to be more storm resilient.
27
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 32 of 48
The table below compares the performance of FPL's transmission system for Hurricane
Wilma, which occurred in 2005 before FPL implemented its current transmission
hardening program, and Hurricane lrma, which occurred in 2017 after FPL implemented
its current transmission hardening program:
Hurricane Wilma Hurricane
lrma
% Line Section Outages 37o/o 17o/o
Transmission Structure Failures 100 5
(all non-hardened)
Transmission Substations De-energized 241 92
Days to Restore Substation Outages 5 1
As shown above, the impacts on FPL's transmission facilities associated with Hurricane
lrma were significantly reduced from those experienced with Hurricane Wilma, even
though Hurricane lrma's winds were stronger and its path impacted substantially more of
FPL's facilities.
2. Actual/Estimated Start and Completion Dates
FPL implemented its transmission hardening program in 2007. As of year-end 2019, 96%
of FPL's transmission structures, system-wide, were steel or concrete, with less than
2,900 (or 4o/o) wood structures remaining to be replaced. FPL expects to replace the
2,900 wood transmission structures remaining on its system by year-end 2022.
3, Cost Estimates
Estimated/actual annual transmission hardening costs are a function of the number of
poles to be replaced, actual historical replacement costs, and updated cost assumptions
(e.9., labor and materials). The vast majority of the transmission hardening program costs
are capital costs resulting from replacement of the wood transmission structures.
28
Docket No. 20200O71-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 33 of 48
The table below provides a comparison of the 2017-2019 total actual transmission
hardening costs with the 2020-2022 (first three years of the SPP) total estimated
transmission hardening costs:24
Annual Average
illions P ram Costs millions
Further details regarding the SPP estimated transmission hardening costs, including
estimated annual capitalexpenditures and operating expenses, are provided in Appendix
c.25
4. Comparison of Costs and Benefits
As provided in Section lV(E)(3) above, during 2020-2022, total costs for FPL's Wood
Structure Hardening (Replacing) - Transmission Program average approximately $39
million per year. Benefits associated with the Wood Structure Hardening (Replacing) -
Transmission Program discussed in Sections Il and |V(EX1)(b) above, include improved
storm resiliency.
5. Criteria used to Select and Prioritize the Proqram
The annual prioritization/selection criteria for the remaining wood structures to be
replaced includes proximity to high wind areas, system importance, customer counts, and
coordination with other storm initiatives (e.9., distribution feeder hardening). Other
economic efficiencies, such as opportunities to perform work on multiple transmission line
sections within the same transmission corridor, are also considered.
At this time, FPL has not identified any areas where the replacement of the remaining
wood transmission structures under the Wood Structure Hardening (Replacing) -
Transmission Program would not be feasible, reasonable or practical.
24 FPL expects that 100% of the remaining wood transmission structures in its system will be
replaced by year-end 2022.
25 See footnote 14.
Total
ram Gosts
2017-2019 $1 62 $s+
2020-2022 $1 18 $3e
29
Docket No. 2020O071-El
FPL'i 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 34 of 48
F. Substation Storm Surge/Flood Mitigation Program
1. Description of the Prooram and Benefits
The Substation Storm Surge/Flood Mitigation Program is the only new program included
in FPL's SPP. As explained below, Substation Storm Surge/Flood Mitigation Program is
a new program to mitigate damage at several targeted distribution and transmission
substations that are susceptible to storm surge and flooding during extreme weather
events.
Historically, several FPL distribution and transmission substations have been impacted
by storm surge and/or flooding as a result of extreme weather conditions. For example,
as a result of flooding caused by Hurricanes Matthew and lrma, FPL's St. Augustine
substation was required to be proactively de-energized (r.e., shut down before water
reached levels that would cause significant damage to powered substation equipment).
Another example is FPL's South Daytona substation that was proactively de-energized
during Hurricane lrma as a result of flooding. While proactively de-energizing those
substations impacted by storm surge and/or flooding helps reduce damage to substation
equipment, FPL is still required to implement both temporary flood mitigation efforts and
repairs to substation facilities and equipment that become flooded as a result of extreme
weather conditions.
An outage associated with distribution substations can impact up to severalthousands of
customers, and an outage associated with a transmission substation can result in an
outage affecting tens of thousands of customers. Flooding and the need to proactively
de-energize substations located in areas susceptible to storm surge and flooding can
result in significant customer outages. For example, the flooding and de-energization of
St. Augustine and South Daytona during Hurricane lrma resulted in more than 8,000
customer outages. Therefore, the prevention of outages at transmission and distribution
substations due to storm surge or flooding is essential.
To prevent/mitigate future substation equipment damage and customer outages due to
storm surge and flooding, FPL's new Substation Storm Surge/Flood Mitigation Program
will target and harden certain substations located in areas throughout FPL's service
30
Docket No. 202OO071-E\
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 35 of 48
territory that are susceptible to storm surge or flooding during extreme weather events.
Specifically, FPL plans to raise the equipment at certain substations above the flood level
and construct flood protection walls around other substations to prevent/mitigate future
damage due to storm surge and flooding.
2. Actual/Estimated Stad and Completion Dates
At this time, FPL has identified between 8-10 substations where it initially plans to
implement storm surge/flood mitigation measures over the next three years (2020-2022).
FPL plans to initiate construction in late summer/early fall 2020 to raise the equipment at
the St. Augustine substation, which is expected to be completed in2021. |n2021 and
early 2022, FPL also plans to begin construction on flood protection walls for the other 7-
9 substations identified for mitigation, which is expected to be completed by 2022.
3. Cost Estimates
The storm surge/flood mitigation costs associated with St. Augustine substation (raising
substation equipment) are estimated to be approximately $10 million in total (2020 and
2021). Estimated storm surge/flood mitigation costs for the remaining 7-9 substations
identified at this time (constructing surrounding flood walls) are estimated to be
approximately$l3million intotal (2021 and2022). Seethetablebelowtheestimated
annual program costs:
Annual Average
illions ram Costs millions
Further details regarding the SPP estimated storm surge/flood mitigation costs, including
estimated annual capitalexpenditures and operating expenses, are provided in Appendix
c.26
4.
As provided in Section |V(FX3) above, during 2020-2022, totalcosts for FPL's Substation
Storm Surge/Flood Mitigation Program average approximately $8 million per year.
Total
ram Costs
2020-2022 $23 $8
26 See footnote 14.
31
Docket No. 20200071-El
FPL's 2O2O-2029 Storm Protection Plan
Exhibit MJ-1 , Page 36 of 48
Benefits associated with this program discussed in Section |V(FX1) above, include
improved storm resiliency (avoiding storm surge/flood damage), reduced customer
outages and storm restoration costs.
5. Criteria used to Select and Prioritize Projects
The annual prioritization/selection criteria for the targeted substations is based on FPL's
historical storm surge/flood experience, in particular, Hurricanes Matthew and lrma. At
this time, for the targeted substations, FPL has not identified any areas where the
upgrades would not be feasible, reasonable or practical.
c. Vegetation Management - Distribution Program
L Description of the Proqram and Benefits
The Vegetation Management - Distribution Program included in the SPP is a continuation
of FPL's existing Commission-approved Vegetation Management - Distribution Program.
Below is an overview of FPL's existing Vegetation Management - Distribution Program
and the associated benefits.
a. Overview of the Veqetation Manaoement - Distribution
Proqram
Prior to 2006, FPL's Vegetation Management - Distribution Program consisted of
inspecting and maintaining its feeders on a three-year average trim cycle and performing
targeted trimming on certain feeders more frequently (e.9., targeting vegetation with faster
growth rates and palm trees) through its "mid-cycle" program. Lateral trimming was
prioritized based on reliability performance. Another important component of thisprogram
was FPL's "Right Tree Right Place" initiative, which provided information to educate
customers on FPL's vegetation management program and practices, safety issues, and
the importance of placing trees in the proper location.
After the 2004-2005 storm seasons, the Commission determined that the "vegetation
management practices of the investor-owned electric utilities do not provide adequate
assurance that tree clearances for overhead distribution facilities are being maintained in
a manner that is likely to reduce vegetation related storm damage. We believe that
32
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 37 of 48
utilities should develop more stringent distribution vegetation management programs."27
As result, FPL proposed and the Commission approved the continuation of FPL's system-
wide three-year average trim cycle for feeders, mid-cycle targeted trimming for certain
feeders, and its Right Tree Right Place initiative, as well as the implementation of a new
six-year average trim cycle for laterals.28 These same initiatives, which have provided
storm and day-to-day reliability benefits, remain in place today.
Tree limbs and branches, especially palm fronds, are among the most common causes
of power outages and momentary interruptions during both day{o-day operations and
storm events. The primary objective of FPL's Vegetation Management - Distribution
Program is to clear vegetation in areas where FPL is permitted to trim from the vicinity of
distribution facilities and equipment in order to provide safe, reliable, and cost-effective
electric service to its customers. The program is comprised of multiple initiatives
designed to reduce the average time customers are without electricity as a result of
vegetation-related interruptions. These include preventive maintenance initiatives
(planned cycle and mid-cycle maintenance), corrective maintenance (trouble work and
service restoration efforts), customer trim requests, and support of system improvement
and expansion projects, which focus on long{erm reliability by addressing vegetation that
will impact new or upgraded overhead distribution facilities.
FPL's Vegetation Management Distribution Program's practices follow the NESC, the
American National Standards lnstitute ('ANSI')4-300, and all other applicable standards,
while considering tree species, growth rates, and the location of trees in proximity to FPL's
facilities. Danger orhazard trees (leaning, structurally damaged, or diseased/dead that
have a high likelihood to fail and impact FPL's facilities) located outside of right-of-way
("ROW'), which cannot be trimmed without approval from the property owner, are
identified as candidates for customer-approved removal.
Finally, a very important component of FPL's vegetation program is providing information
to customers to educate them on the company's trimming program and practices, safety
issues, and the importance of placing trees in the proper location - FPL's "Right Tree,
27 See Order No. PSC-06-0351-PAA-El
28 See Order No. PSC-07-0468-FOF-El
33
Docket No. 20200071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , Page 38 of 48
Right Place" initiative. Right Tree, Right Place is a public education program based on
FPL's core belief that providing reliable electric service and sustaining the natural
environment can go hand-in-hand and is a win-win partnership between the utility and its
customers.
The SPP will continue FPL's currently-approved distribution vegetation program, which
includes the following system-wide vegetation management activities: three-year cycle
for feeders; mid-cycle targeted trimming for certain feeders; six-year cycle for laterals;
and continued education of customers through its Right Tree, Right Place initiative.
b. Benefits of the Veqetation Manaqement Distribution
Proeram
ln Order No. PSC-07-0468-FOF-El, the Commission confirmed that FPL should continue
to implement three-year and six-year average cycles for its feeders and laterals because
the cycles complied with the Commission's storm preparedness objectives to increase
the level of trimming over historical levels, promote system reliability and reduce storm
restoration costs.2e Additionally, Commission's orders indicated that FPL's proposed
cycles: were cost-effective; would improve dayto-day "tree SAlFl" from 0.22to 0.16 in
ten years;3o and would provide savings when comparing savings on a customers
interrupted ("Cl') per storm basis. Further, day-to-day distribution tree SAIFI has
significantly improved as a result of FPL implementing its approved distribution vegetation
management program (from 0.20 prior to the 2004-2005 storm seasons to 0.08 at year-
end 2019).
Finally, another indication that the current program is providing benefits is that, while
forensic analysis indicated vegetation was the ovenruhelming primary cause for pole and
wire failures and a significant cause of outages during Hurricanes Matthew and lrma, the
vast majority of damage resulted from uprooted trees, broken trunks, and broken limbs
2e FPL's proposed three-year and six-year cycles were initially approved in Order No. PSC-06-
O7B1-PAA-EI.
30 The tree-related SAIFI has averaged less than 0.09 over the last few years.
34
Docket No. 20200071-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 39 of 4B
thatfell into distribution facilities from outside of right-of-way, i.e., beyond where FPL is
currently allowed trim without approvalfrom the property owner.
2. ActualiEstimated Start and Completion Dates
FPL's ongoing vegetation management plan was originally approved in 2007, and
remains in place today. Under the SPP, FPL plans to inspect and maintain, on average,
approximately 15,200 miles annually, including approximately 11,400 miles for feeders
(cycle and mid-cycle) and 3,800 miles for laterals. This is comparable to the
approximately 15,200 miles inspected and maintained annually, on average, for 2017-
2019.
3. Cost Estimates
The vast majority of vegetation management costs are associated with cycle and mid-
cycle trimming, which is performed by several FPl-approved contractors throughout
FPL's system. Other vegetation management costs include costs associated with day-
to-day restoration activities (e.9., summer afternoon thunderstorms), removals, debris
cleanup, and support (e.9., arborists, supervision, back office support). Costs associated
with vegetation management are generally operating expenses.
The table below provides a comparison of the 2017-2019 total actual distribution
vegetation management costs with the 2020-2022 (first three years of the SPP) total
estimated distribution vegetation management costs and the 2020-2029 total estimated
distribution vegetation management costs:31
Annual Average
illions P ram Costs millions
Further details regarding the SPP estimated distribution vegetation management costs,
31 The vegetation management costs shown in the table below exclude storm-related vegetation
management costs.
P
Total
ram Gosts
2017-2019 $1 89 $63
2020-2022 $1 83 $ol
$5e6 $602020-2029
35
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 40 of 4B
including estimated annual capitalexpenditures and operating expenses, are provided in
Appendix C.32
4. Comparison of Costs and Benefils
As provided in Section IV(GX3) above, during 2020-2029, totalcosts for FPL's Vegetation
Management - Distribution Program average approximately $60 million per year.
Benefits associated with the Vegetation Management - Distribution Program discussed
in Sections ll and |V(GX1)(b) above, include increased storm resiliency.
5. Criteria Used to Select a d Prioritize the Prooram
The primary reason for maintaining feeders on a three-year average cycle, as opposed
to a six-year average cycle for laterals, is that a feeder outage can affect, on average,
approximately 1,500 customers as compared to an outage on a lateral line that can affect,
on average, approximately 35 customers. FPL enhances its approved feeder inspection
and trimming plan through its mid-cycle trimming program, which encompasses patrolling
and trimming feeders between planned maintenance cycles to address tree conditions
that may cause an interruption prior to the next planned cycle trim. Mid-cycle work units
typically have a trim age of 12to 18 months and usually involve certain fast-growing trees
(e.9., palm trees) that need to be addressed before the next scheduled cycle trim date.
Additionally, customers often contact FPL with requests to trim trees around distribution
lines in their neighborhoods and near their homes. As a result of these discussions with
customers and/or a follow-up investigation, FPL either performs the necessary trimming
or determines that the requested trimming can be addressed more efficiently by
completing it through the normal scheduled cycle trimming.
Cycle trimming is prioritized annually to ensure compliance with cycle schedules. At this
time, FPL has not identified any areas where the Vegetation Management - Distribution
Program would not be feasible, reasonable or practical.
32 See footnote 14
36
Docket No. 20200071-El
FPL's 2O2O-2O29 Storm Protection Plan
Exhibit MJ-1 , Page 41 of 48
H. Vegetation Management - Transmission Program
1. Description of the Prosram and Benefits
The Vegetation Management - Transmission Program included in the SPP is a
continuation of FPL's existing transmission vegetation management program. Below is
an overview of FPL's existing transmission vegetation management program and the
associated benefits.
a. Overview of the Veqetation Manaqement - Transmission
Proqram
The North American Electric Reliability Corporation's (NERC) vegetation management
standards/requirements serve as the basis for FPL's transmission vegetation
management program. The reliability objective of these standards/requirements is to
prevent vegetation-related outages that could lead to cascading by utilizing effective
vegetation maintenance while recognizing that certain outages such as those due to
vandalism, human errors, and acts of nature are not preventable. Transmission lines that
must conform with these standards/requirements include lines operated at or above 200
kV or any line that is either an element of the Interconnection Reliability Operating Limit
(IROL) or the Western Electricity Coordinating Council (WECC).
For FPL, just over 4,300 miles of its transmission system (or nearly two{hirds of all of
FPL's total transmission system) are subject to NERC's vegetation management
standards/requirements. NERC's vegetation management standards/requirements
include annual inspection requirements, executing 100% of a utility's annual vegetation
work plan, and to prevent any encroachment into established minimum vegetation
clearance d istances (.MVCD").
The key elements of FPL's transmission vegetation management program are to inspect
the transmission right-of-ways, document vegetation inspection results and findings,
prescribe a work plan, and execute the work plan.
FPL conducts ground inspections of all transmission corridors annually for work planning
purposes. During these inspections, FPL identifies vegetation capable of approaching
the defined Vegetation Action Threshold ("VAT'). VAT is a calculated distance from the
37
Docket No. 202OO071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1 , Page 42 of 4B
transmission line that factors in MVCD, conductor sag/sway potential, and a buffer. The
identified vegetation is given a work prescription and then prioritized and organized into
batches of work, which collectively become the annual work plan.
For transmission lines that are subject to NERC's vegetation management
standards/requirements, FPL also uses a technology called "L|DAR," short for light
detection and ranging. L|DAR is a remote sensing technology that uses light in the form
of a pulsed laser to measure ranges (distances) to a target. For vegetation management
purposes, L|DAR is used to measure distance between vegetation and transmission lines.
L|DAR patrols are conducted annually for all NERC transmission corridors. Data
collected by the L|DAR patrols is then used to develop annual preventative and reactive
work plans.
ln its SPP, FPL will continue its current transmission vegetation management plan, which
includes visual and aerial inspections of all transmission line corridors, LiDAR inspections
of NERC transmission line corridors, developing and executing annual work plans to
address identified vegetation conditions, and identifying and addressing priority and
hazard tree conditions priorto and during storm season.
b.Benefits of the Veoetation Man aoemcnf ransmtsston
Proeram
The benefits of a Vegetation Management - Transmission Program are self-evident and
the consequences of not having a reasonable transmission vegetation management plan
can be extreme. As discussed previously, the transmission system is the backbone of
the electric grid. While outages associated with distribution facilities (e.9., a transformer,
lateral, or feeder) can result in an outage affecting anywhere from a few customers up to
several thousands of customers, a transmission related outage can affect tens of
thousands of customers. Additionally, an outage on a transmission facility could cause
cascading and result in the loss of service for hundreds of thousands of customers. As
such, it is imperative that vegetation impacting transmission facilities be properly
maintained using reasonable and appropriate cycles and standards to help ensure they
are prepared for storms. For these reasons, it is no surprise that NERC has developed
38
Docket No. 20200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , Page 43 of 48
prescriptive vegetation management requirements for transmission facilities to help
prevent such damage from occurring.
FPL also notes that while vegetation-related damage and transmission line outages
occurred during Hurricanes Matthew and lrma, the vast majority of such
damages/outages were caused by vegetation located outside of the right-of-way, i.a.,
beyond where FPL is currently allowed to trim without approval from the property owner,
which further demonstrates that FPL's historical efforts in this area have been beneficial.
2. Actual/Estimated Start and Completion Dates
FPL's Vegetation Management - Transmission Program is an ongoing program, initiated
decades ago. Under the SPP, FPL plans to inspect and maintain, on average,
approximately 7,000 miles annually, including approximately 4,300 miles for NERC
transmission line corridors and 2,7O0 miles for non-NERC transmission line corridors.
This is comparable to the approximately 7,000 miles inspected and maintained annually,
on average , for 2017-2019.
3. Cost Estimates
The vast majority of vegetation management costs are associated with annual inspections
and the execution of planned work to address identified conditions, which is performed
by several FPL approved contractors throughout FPL's system. Other vegetation
management costs include costs associated with day{o-day restoration activities (e.9.,
summer afternoon thunderstorms), removals, debris cleanup, and support (e.9., arborists,
supervision, back office support). Costs associated with vegetation management are
generally operating expenses.
The table below provides a comparison of the 2017-2019 total actual transmission
vegetation management costs with the 2020-2022 (first three years of the SPP) total
estimated transmission vegetation management costs and the 2020-2029 totalestimated
transmission vegetation management costs.33
33 The vegetation management costs shown in the table below exclude storm-related vegetation
management costs.
39
2017-2019 $zz $g
2020-2022 $zz $g
2020-2029 $go $10
Docket No. 20200071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1, Page 44 of 48
Total Annual Average
ram Costs millions ram Costs millions
Further details regarding the SPP estimated transmission vegetation management costs,
including estimated annualcapitalexpenditures and operating expenses, are provided in
Appendix C.3a
4. Comparison of Costs and Benefits
As provided in Section lV(H)(3) above, during 2020-2029, totalcosts for FPL's Vegetation
Management - Transmission Program average approximately $10 million per year.
Benefits associated with the Vegetation Management - Transmission Program discussed
in Sections ll and |V(HX1)(b) above, include increased storm resiliency. The execution
of FPL's Vegetation Management - Transmission Program is a significant factor in
mitigating damage to transmission facilities and avoiding transmission-related outages.
5. Criteria used to Select and Prioritize the Proqrams
Priority vegetation conditions and hazard tree conditions are completed annually prior to
storm season. Additionally, prior to and during the storm season, FPL conducts aerial
inspections of transmission corridors to identify hazard trees and any priority vegetation
locations. Priority vegetation conditions and hazard tree conditions identified through
aerial inspections are addresbed as soon as possible.
At this time, FPL has not identified any areas where the Vegetation Management -
Transmission Program would not be feasible, reasonable or practical.
3a Seefootnote 14.
40
Docket No. 20200071-El
FPL'9 202O-2029 Storm Protection Plan
Exhibit MJ-1 , Page 45 of 4B
V. Detailed lnformation on the First Three Years of the SPP
2020-2022
A. Detailed Description for the First Year of the SPP (20201
The following additional information required by Rule 25-6.030(3XeX1), F.A.C., for the
first year of the SPP (2020) is provided in Appendix E. (1) the actual or estimated
construction start and completion dates (2) a description of the affected existing facilities,
including number and type(s) of customers served, historic service reliability performance
during extreme weather conditions, and how this data was used to prioritize the storm
protection projects; (3) a cost estimate including capital and operating expenses. A
description of the criteria used to select and prioritize the storm protection programs is
included in the description of each SPP program provided in Section lV.
Detailed Description of the Second and Third Years of the
sPP (2021-20221
Additional details required by Rule 25-6.030(3XeX2), F.A.C., for the second and third
years of the SPP (2021-2022), including the estimated number and costs of projects
under every program, is provided in in Appendix C.
Detailed Description of the Vegetation Management
Activities for the First Three Years of the SPP (2020-20221
The following additional information required by Rule 25-6.030(3X0, F.A.C., for the first
three years of the vegetation management activities under the SPP (2020-2022) is
provided in n Sections lV(G) and lV(H) above and Appendix C: the projected frequency
(trim cycle); the projected miles of affected transmission and distribution overhead
facilities; the estimated annual labor and equipment costs for both utility and contractor
personnel. A description of how the vegetation management activities will reduce outage
times'and restoration costs due to extreme weather conditions is provided in Sections
lV(G) and lV(H) above.
B
c
41
Docket No. 202OO071-El
F PL's 2O20-2029 Storm Protection Plan
Exhibit MJ-'l , Page 46 of 48
Vl. Estimate of Annual Jurisdictional Revenue Reouirements
for the 2020-2029 SPP
Pursuant to Rule 25-6.030(3X0, F.A.C., the table below provides the estimated annual
jurisdictional revenue requirements for each year of the SPP.
Estimated Annual
Revenue
Requirements
illions
While FPL has provided estimated costs by program as of the time of this filing and
associated total revenue requirements in its SPP, consistent with the requirements of
Rule 25-6.030, F.A.C., subsequent projected and actual program costs submitted for cost
recovery through the Storm Protection Plan Cost Recovery Clause (per Rule 25-6.031,
F.A.C.,) could vary by as much as 10-15%, which would then also impact associated
estimated revenue requirements and rate impacts. The projected costs, actual/ estimated
costs, actuals costs, and true-up of actual costs to be included in FPL's Storm Protection
2020 $257.6
2021 $369.1
$494.32022
2023 $625.5
2024 $760.9
$878.12025
2026 $963.7
2027 $1,037.1
$1,110.92028
2029 $1 ,195.2
42
Docket No. 2O2OOO71-E\
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1 , Page 47 of 48
Plan Cost Recovery Clause will all be addressed in subsequent filings in separate storm
protection plan cost recovery clause dockets pursuant to Rule 25-6.031, F.A.C.35
Vll. Estimated Rate lmpacts for First Three Years of the SPP
(2020-20221
FPL anticipates the programs included in the SPP will have zero bill impacts on customer
bills during the first year of the SPP and only minimal bill increases for years two and
three of the SPP. An estimate of hypothetical overall rate impacts for the first three years
of the SPP (2020-2022), without regard for the fact that FPL remains under a general
base rate freeze pursuant to a Commission-approved settlement agreement through
December 31 ,2021, as stated in footnote 36 below are based on the total program costs
reflected in this filing.36 The projected costs, actual/estimated costs, actuals costs, and
true-up of actual costs to be included in FPL's Storm Protection Plan Cost Recovery
Clause will all be addressed in subsequent filings in Storm Protection Plan Cost Recovery
Clause dockets pursuant to Rule 25-6.031, F.A.C.37
Pursuant to Rule 25-6.031, F.A.C., FPL has not identified any reasonable implementation
alternatives that could mitigate the resulting rate impact for each of the first three years
of the SPP. As explained above, FPL's SPP is largely a continuation of existing
Commission-approved storm hardening programs and initiatives, which have already
demonstrated that they have and will continue to provide increased T&D infrastructure
resiliency, reduced restoration time, and reduced restoration costs when FPL's system is
impacted by severe weather events. Further, as explained above, the estimated costs
35 The Commission has opened Docket No. 20200092-El to address Storm Protection Plan Cost
Recovery Clause petitions to be filed the third quarter of 2020.
36 Pursuant to Rule 25-6.030(3)(h), F.A.C., the hypothetical rate impacts for FPL's typical
residential, commercial, and industrial customers for the first three years of the SPP (2020-2022)
without regard for the fact that FPL remains under a general base rate 'freeze pursuant to a
Commission-approved settlement agreement through December 31, 2021, are as follows for
2020, 2021, and 2022, respectively: Residential (RS-1) $0.00251/kwh, $0.00357/kWh, and
$0.00478/kWh; Commercial (GSD-1) $0.81/kW, $1.15/kW, and $1.54/kW; and lndustrial
(GSLDT-3) $0.05/kW, $0.08/kW and $0.10/kW. These rate impacts are for all programs included
in the SPP and are based on the total estimated costs as of the time of this filing, which could
vary by as much as 10% lo 15oh, regardless of whetherthose costs will be recovered in FPL's
Storm Protection Plan Cost Recovery Clause or through base rates.
37 See footnote 34.
43
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, Page 48 of 4B
for the programs included in FPL's SPP are consistent with the historical costs incurred
for the existing storm hardening and storm preparedness programs, which were most
recently approved in FPL's 2019-2021Storm Hardening Plan.
Vlll. Gonclusion
The Florida Legislature has determined that it is in the State's interest to "strengthen
electric utility infrastructure to withstand extreme weather conditions by promoting the
overhead hardening of distribution and transmission facilities, undergrounding of certain
distribution lines, and vegetation management," and for each electric utility to "mitigate
restoration costs and outage times to utility customers when developing transmission and
distribution storm protection plans." Section 366.96(1), F.S. Based on these findings, the
Florida Legislature concluddd that it is in the State's interest for each electric utility to
develop and file a SPP for the overhead hardening and increased resilience of electric
T&D facilities, undergrounding of electric distribution facilities, and vegetation
management. See Sections 366.96(1)-(3).
FPL's SPP is a systematic approach to achieve the legislative objectives of reducing
restoration costs and outage times associated with extreme weather events and
enhancing reliability. As explained above, FPL's SPP is largely a continuation and
expansion of its existing and already successful storm hardening and storm preparedness
programs previously approved by the Commission, as well as a new storm hardening
program to harden certain targeted substations that are susceptible to storm surge or
flooding during extreme weather events. Based on the recent experiences of Hurricanes
Matthew and lrma, the existing storm hardening programs have a demonstrated and
proven track record of mitigating and reducing restoration CMH, outage times, and storm
restoration costs, as well as improving day-to-day reliability. FPL's SPP will continue and
expand these imporlant benefits to customers and the State.
44
Docket No. 2020007'l -El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX A (Page I of 1B)
APPENDIXA
(FPL's 3rd Supplemental Amended Response to
Staffs lst Data Request)
Docket No. 2020o071-El
FPL's 202o-2o29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 2 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 1 of9
QUESTION:
Please complete the table below summarizing hardened facilities that required repair or
replacement as a result of Hurricanes Matthew, Hermine, Irma, Maria, and Nate.
RESPONSE
FPL does not maintain its accounting records at the level of detail required to provide the
requested information as they do not differentiate hardened facilities from non-hardened
facilities, nor do they track which assets were repaired. However, FPL does track certain assets,
at the total system level, that were requested and replaced during each hurricane as reflected in
the tables below. Note, FPL did not track storm repairs/replacements for Hurricanes Maria and
Nate as Huricane Maria did not impact FPL's service territory and Nate had limited impact.
Also, Hurricanes Matthew and Irma capital details associated with follow-up work are not yet
available by plant account as these costs have not yet been unitized from account 106 to account
l0l by plant account.
Hurricane Matthew Number of Facilities Requiring
Repair Replacement
Transmission
Structures N/A 0
Substations N/A 0
Total N/A 0
Distribution
Poles N/A 656
Substation N/A 0
Feeder OH N/A 0
Feeder UG N/A 0
Feeder Combined N/A 0
Lateral OH N/A N/A
Lateral UG N/A N/A
Lateral Combined N/A N/A
Total N/A N/A
Service
Service OH N/A N/A
Service UG N/A N/A
Service Combined N/A N/A
Total N/A N/A
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 3 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page2 of9
Hurricane Hermine Number of Facilities Requiring
Repair Replacement
Transmission
Structures N/A 0
Substations N/A 0
Total N/A 0
Distribution
Poles N/A I9
Substation N/A 0
Feeder OH N/A 0
Feeder UG N/A 0
Feeder Combined N/A 0
Lateral OH N/A N/A
LateralUG N/A N/A
Lateral Combined N/A N/A
Total N/A N/A
Service
Service OH N/A N/A
Service UG N/A N/A
Service Combined N/A N/A
Total N/A N/A
Docket No. 20200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX A (Page 4 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 3 of9
Hurricane Irma Number of Facilities Requiring
Repair Replacement
Transmission
Structures N/A 0
Substations N/A 0
Total N/A 0
Distribution
Poles N/A 3,562
Substation N/A 0
Feeder OH N/A 0
Feeder UG N/A 0
Feeder Combined N/A 0
Lateral OH N/A N/A
Lateral UG N/A N/A
l,ateral Combined N/A N/A
Total N/A N/A
Service
Service OH N/A N/A
Service UG N/A N/A
Service Combined N/A N/A
Total N/A N/A
Notes:
For Hurricane Matthew, there is a difference of 248 poles between what is provided in this
discovery response for total poles replaced (656 poles) and what is provided in FPL's post-storm
forensic review report for Huricane Matthew (provided in FPL's response to Staff s Second
Data Request No. 2 in this same docket) for poles that failed and needed to be replaced to restore
selice (408 poles). The difference is associated with poles replaced during "follow-up" - i.e.,
poles that were damaged (e.g., a cracked pole) as a result of the storm and needed to be replaced
to restore the pole to its pre-storm condition - but did not fail during the storm and, thus, did not
need to be replaced to restore service. As mentioned above in FPL's response to this data
request, FPL's accounting records do not differentiate hardened facilities from non-hardened
facilities and FPL did not track or maintain forensic information on the 248 distribution poles
replaced as a result of follow-up work. As a result, FPL does not have a hardened vs. non-
hardened breakdown for the 248 distribution poles replaced during follow-up work.
Docket No. 2O200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX A (Page 5 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs X'irst Data Request
Request No. 29 - Third Supplemental Amended
Page 4 of 9
The distribution pole and transmission structure counts provided above represent the amount of
pole/structure replacements FPL has recorded on its books and records associated with Hurricane
Irma as of December 31,2017. These amounts should be consideredpreliminary atthis time as
they are subject to change (e.g., the counts do not reflect poles that will be replaced during
follow-up work, which has yet to be completed).
N/A - Information is not available at this level of detail in FPL's accounting records.
For substations and feeders, FPL has stated 0 since no entire substation or feeder was replaced.
However, these facilities consist of many pieces of equipment (e.g., wire, cable, breakers,
transformers, cross arms and arrestors) some of which may have been replaced.
2016 12017 Hurricanes - FPL Restoration/Infrastructu re Performance
FPL's infrastructure/restoration performance for Huruicanes Matthew (2016) and Irma (2017)
demonstrates that the implementation and execution of its FPSC-approved (l) ten storm
preparedness initiatives (which includes vegetation management): (2) pole inspection programs;
(3) storm hardening plans; and (4) tariffs to incent municipal overhead to underground
conversions have provided great benefits to FPL's customers and to the State of Florida.
During 2016 and 2017, FPL' s service territory was threatened with massive Category 4 and 5
storms. The size and scale of these storms impacted FPL's infrastructure throughout its entire
service temitory (which encompasses 35 counties in the State of Florida). For both Matthew and
Irma, FPL's infrastructure storm resiliency and smart grid investments resulted in improved
infrastructure resiliency performance and reduced restoration times.
2016 12017 Hurricanes - Restoration Performance
FPL saw significant improvements in overall restoration results. As can be seen in the table
below, restoration results for Hurricanes Matthew and Irma show significant improvement vs.
Humicane Wilma. FPL attributes these significant improvements in restoration to the investments
made to make its system smarter and more storm-resilient as well as its well-tested restoration
processes. This includes FPL's distribution and transmission storm hardening and storm
preparedness initiatives, pole inspection programs, smart grid initiatives, vegetation management
programs and continuous efforts to improve its restoration processes.
4.4MCustomer Outages 3.2M 1.2M
% Restored / davs s0%/s s9%/2 so% l!
All restored / davs 18 4 10
5.4 <1 2.1,Avg, to restore / days
Docket No. 2020O071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 6 of 1B)
Florida Power & Light Company
Docket No.20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 5 of9
2016 12017 Hu rricanes - Infrastructu re Performance
To assess the effectiveness of FPL's infrastructure storm hardening investments, the Company
utilizes information collected through post-storm forensic data collection and various systems
(e.g., FPL's outage management system) to conduct post-storm infrastructure performance
analysis. These efforts and analysis allow FPL to quantit/ and assess its distribution and
transmission infrastructure performance including the performance of: hardened and non-
hardened facilities; overhead and underground facilities; and smart grid performance. For
distribution, this includes reviewing the storm performance of poles, feeders and laterals. For
transmission, this includes reviewing the storm performance of poles/structures, line sections
and substations. The data demonstrates that hardened infrastructure performed better than non-
hardened infrastructure, underground facilities performed better than overhead facilities and
smart grid devices prevented a significant number of outages from occurring.
DistributionlTransmission Poles/ Structures Performance
The performance of FPL's approximately 1.2 million distribution and transmission
poles/structures during Hurricanes Matthew and Irma was excellent, as hardened poles and
structures performed as expected by minimizing outages and reducing restoration times. The
total number of distribution/transmission poles that failed (i.e., had to be repaired/replaced in
order to restore service) during Hurricanes Matthew and Irma was a mere fraction of lYo of the
1.2 million pole/structure pole population.
Additionally, hardened distribution and transmission pole performance was significantly better
than non-hardened pole performance, as hardened pole failures were either non-existent (e.g.,
Hurricane Matthew) or significantly less than non-hardened pole failures (e.g., during Hurricane
Irma, hardened feeder poles had a 0.02o/o failure rate, while non-hardened feeder poles had a
0.20% failure rate). Also, total poles replaced (i.e., poles that failed * poles that were replaced
during follow-up work) were also a mere fraction of lYo of the total pole population and
significantly less than the number of poles replaced during Hunicane Wilma.
FPL notes that for Hunicanes Matthew and Irma, while it did track hardened vs. non-hardened
pole performance during restoration, it did not track poles replaced (hardened vs. non-hardened)
during follow-up work, since these poles had accomplished their intended purpose of not failing
during the storms. Therefore, FPL cannot provide the number of hardened poles replaced during
follow up work in Hurricanes Matthew and Irma. Based on the performance of hardened poles
that failed during these storms (see table below), it is highly unlikely that there would be a
significant number of hardened poles, if any, that needed to be replaced during follow-up work.
However, going forward, should the Commission want FPL to track replacement of hardened
vs. non-hardened poles during follow-up work, FPL will begin to track this information.
FPL attributes this excellent pole performance to its FPSC-approved distribution and
transmission storm hardening plan initiatives (e.g., extreme wind load construction standards for
distribution poles and replacing wood transmission poles/structures) and its pole inspection
programs.
Docket No. 202OO071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 7 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 6 of 9
Distribution Poles l2l3 1/1 7
TotalNumber 1,188,202
TotalHardened 124j18*
* This number is understated as it includes only poles hardened as a result of FPL's approved
hardening plan projects, as FPL does not track or maintain the number of hardened poles
installed as a result of new construction (e.g., new feeders or laterals) andlor daily work activities
(e.g., maintenance, pole line extensions, relocation projects). There are also other existing poles
throughout FPL's service teritory that would currently meet the NESC's extreme wind loading
criteria and therefore qualify as a hardened pole, however, FPL does not currently track or
maintain that information.
Distribution Pole Failures*Hardened
Non-
Hardened Total
Matthew - 2016 0 408 408
ltma - 2017 26 2834 2860
*Broken/Fallen poles that must be repaired/replaced to restore service
Transmission Pole/Structures 12l3 1/l 7
Total 66,685
Concrete 60,694 (91%)
Wood 5,991 (9Yo)
Transmlssion Pole Failures*Hardened
Non-
Hardened Total
Matthew - 2016 0 0 0
lrma - 2Ot7 0 5 5
*Broken/Fallen poles that must be repaired/replaced to restore service
Distribution Feeders/Laterals Performance
As demonstrated below, FPL's hardened feeders performed significantly better than non-
hardened feeders and underground feeders/laterals performed significantly better than overhead
feeders/laterals. Performance was compared considering feeder and lateral outages that occurred
during Hurricanes Matthew and Irma. It is also important to note that during Hurricane Irma, the
Construction Man Hours ("CMH") to restore hardened feeders was 50% less than non-hardened
feeders, primarily due to hardened feeders experiencing less damage than non-hardened feeders.
It is important to note that the majority of outages for overhead facilities resulted from trees that
broke andlor fell into FPL's facilities. Many of these trees were outside of easements or public
rights of way where FPL is generally allowed to trim. As a result, no additional amount of
Docket No. 2O2O0071-E\
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page B of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 7 of 9
traditional tree trimming would help mitigate this issue. Tree damage was particularly impactful
on FPL laterals.
The two tables below provide feeder and lateral outage performance statistics for Hurricanes
Matthew and Irma.
Pop: Population; Latelal population includes laterals with rlulti-stage fusing
Pop - Population; Latelal population includes laterals with multistage fusing
FPL notes that, overall, for Hurricane Irma, many more laterals experienced outages compared to
feeders, thus laterals required significantly more time to restore (871,000 CMH) compared to
feeders (170,000 CMH). FPL continues to promote its Right Tree Right Place initiative and
recommends there be changes to state laws andlor local ordinances to restrict the type and
location of trees and provide utilities additional trimming rights to address existing tree
conditions.l
Additionally, FPL notes that day-to-day, hardened feeders perform approximately 40Yo better
than non-hardened feeders.
Transmission Line Sections/Substations Performance
The transmission system's performance was excellent during Hurricanes Matthew and lrma.
Equipment and conductor damage was minimal as a result of our investments in transmission
hardening and the installation of flood monitoring equipment in those substations located in
flood prone areas. Substations that experienced outages were restored in one day. During
Hurricanes Matthew and Irma, flood monitoring equipment operated as expected, providing
notification which allowed FPL to proactively de-energize three substations (one in Matthew and
two in Irma) and prevent potential serious damage from occurring at these substations.
I Where mLrnicipalities are not actively engaged in ensuling appropriate limitations on planting trees in public rights
of way, restoration efforts are impeded and made more costly. In fact,_one particular municipality is actively
planting "wrong trees in the wrong place," in spite of FPL's direct communications and efforts to encourage its
Right Tree Right Place initiative.
Matthew
Overhead non-Hardened
Overhead
Hardened Undersround Total
Out Pop
o/o
Out Out Pop
o/o
Out Out Pop
%
Out Out Pop YoOut
Distribution Feeders 280 2,031 t4%68 t2t 9%II 493 359 3,245 73o/o
Distribution Laterals 3,473 82,729 4%N.A.N.A.N.A.238 101,892 0.2%3,71.1.t84,621 2%
rRMA- 2017
Overhead Non-Hardened
Overhead
Hardened Undereround Total
Out Pop
%
Out Out Pop
%
Out Out Pop
%
Out Out Pop
%
Out
Distribution Feeders 1,609 1,958 82%592 859 69%85 470 TB%2,286 3,287 70%
Distribution Laterals 20,34!84,574 24%N.A.N.A N-A.3,161 103,384 4%24,r08 187,9s8 t3%
Docket No. 2O20OO71-E\
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page I of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 8 of 9
The tables below provide substation line section outage perfonnance for Hurricanes Matthew
and Irma.
* 2 sections were out because substation was proactively de-energized due to flooding
** 4 sections were out because substations were proactively de-energized due to flooding
*** No underground section was damaged or failed causing an outage; however, the sections were out due to line
termination equipment in substations.
The table below compares substation outage and restoration performance - Irma vs, Wilma.
Smart Grid Performance
During Hurricane Matthew and Irma, smart grid devices prevented a significant amount of
customer outages, assisted with restoration efforts and reduced restoration time and costs.
Specifically, automated feeder switches avoided approximately 664,000 outages during
Hurricanes Matthew and Irma. Additionally, FPL's restoration crews are able to "ping" Smart
meters before leaving an area to ensure that power is, in fact, restored. This prevents restoration
crews from leaving an area, thinking all power was restored, only to be called back when the
customer informs FPL that they are still without service. FPL is also enhancing an application,
first utilized during Hunicanes Maffhew and Irma, whereby it will be able to "bulk meter ping"
smart meters to confirm whether customers have service.
Trans. Line Sections 1,6 350 5%23*846 3o/o 0 49 o%39 L,245 3%
i
:1v1,:1;i;.,,1.11 i\'i)il,l rr'al J;t::r
t ,r,
.1
I11 1ri I,Ii.|:,r,.i ,.Ir I I:i('l
,tlI
I ll1 l llrt .r,irl:lii .\ I ,l.i:l:, i'rr',r ili;l i :;iiJr i I :,t(j:{i;l l:
.ri]t:ii1l1: l.ii
I :ir:r i:Jri,il,'
!1,
t:-iri
'.:1.
al!rrf,'il,jL i
25%2!5 7247 t7%Trans. Line Sections 60 306 20%742**884 16%13***51
:
"
-lt
,t'ir l:
:'4,
(,iLj
', ttt ll;.': lri, I'l\1, ;ri .l i.ttJ,.lrt jir: j( I i.rr),:. I i
al!f irl l l,,rJ Jii:'i,;I l,
I I iir:[: !i .,li:Lrllt !i]
ii'1.q1,.,1,,i :iii i.
illlll
( l!/ lt'r!i1;i: 111.1;:.q1r1'qt, ti
a.l il
:i
De-energized 24t 92
Restored (Davs)5 7
Matthew - 2016 118,000
lrma - 2Ot7 546,000
.irr i-lilc;irL"rr
'tfl!iiair'ri. Ii:,]il :;::!:r,,lflr .rJ,r/i ir(lrl.r'l r(r)L tii;l:r,r.
,,,.! rti J fi i.l,.l
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 10 of 18)
Florida Power & Light Company
Docket No. 2017021S-EU
Staffs First Data Request
Request No. 29 - Third Supplemental Amended
Page 9 of 9
Estimate of Storm Restoration Cost Savings Due to Hardening based on Storm Damaqe
Model Simulation
The attached analysis provides an estimate of transmission and distribution storm restoration
savings for Hurricanes Matthew and Irma that resulted from storm hardening completed by FPL
prior to the storms' impacts. To calculate these savings, FPL utilized its Storm Damage Model
(the same model FPL utilizes to estimate damage when a storm approaches FPL's service
territory) to simulate damage that likely would have occurred without hardening and determine
the associated required construction man hours (CMH) that would have been required to restore
service in the absence of hardening, days to restore in the absence of hardening and associated
incremental restoration costs. Additionally, FPL calculated the 4O-year net present value of these
savings for two scenarios - (1) a similar storm occurs every 3 years; and (2) a similar storm
occurs every 5 years.
As indicated on the attached analysis, the 4O-year net present values of the savings related to
storm hardening are significant. In the absence of hardening the estimated percentage increase in
CMHs for Hurricane Matthew and Hurricane Irma restoration would have been significantly
higher (36% and 4002, respectively), days to restore would have been increased (50Yo and 40%o,
respectively) and restoration costs would have been greater (360/o and 40o/o, respectively).
Florida Power & Light CompanV
Docket No. 2O1702L5-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1
TablofS
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection PIan
Exhibit MJ-1 , APPENDIX A (Page 1 1 of 18)
Estimate of Storm Restoration Cost Savings Due to Hardenine based on Storm Damaee Model Simulation
I1l I2l I3l
Construction Man-Hours
l4l lsl t61 l7l
to Restore
t8l lel [10] [111
Storm Restoration Costs
It2 |[ 131
40 Yr NPV
[14]
Storm
lrma
7o lncrease
without
Hardening
s0%
40%
Additional
Days to
Restore
without
Hardening
2
4
Modeled
System
Without
Hardening
6
'J,4
Actual
4
10
Notes:
All costs and CMH are Transmission and Distribution only, and exclusive of follow-up work
[ 1 I Calculated based on actual storm restoration requirements
[ 2 I FPL storm damage model simulation results of CMH incurred without hardening
[ 3 I Additional CMH without hardening (Col. 2 - Col. 1)
[ 4 I Percent increase in CMH without hardening (Col.3/Col.1)
[ 5 ] Actual days to restore service
[ 6 ] Storm damage model simu lation resu lt of the days to restore service without h ardeni ng (assu mes same restoration resources as actual)
[ 7 ] Additional days to restore without hardening (Col. 6 - Col. 5)
[ 8 J Percent increase in days to restore without hardening (Col.7/Col. 5)
[ 9 I Actual cost of restoration.-]llllgS$_elCjlglilqllily
[ 10 I Storm damage model simulation result of restoration costs without hardening
[ 11 I Additional restoration costs without hardening (Col. 10 - Col.9)
[ 12 I Percent increase in restoration costs without hardening ((Col. ].1/Col.9)
[ 13 I 40 year net present value savings assuming a similar storm everylblgg years (calculation details attached)
[ 14 I 40 year net present value savings assuming a similar storm everyfive years (calculation details attached)
% lncrease
without
Hardening
36%
40%
Additional
CMH
without
Hardening
93.000
483,000
Modeled
System
Without
Hardening
350.000
1.678.000
Actual
257.000
1.195.000
% lncrease
without
Hardening
36%
40%s496
510s
Additional
Storm
Restoration
Costs
without
Hardenins
s7.722
Modeled
System
Without
Hardening
S39s
s7.226
Actual
s290
s1.915
s4o6
40 Yr NPV
Savings Every
5 Years
(2017s)
s653
Savings Every
40 Yr NPV
3 Years
(2077sl
s3,082
Docket No. 20200071-El
F PL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 12 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No, 1
Tab2of5
Estimated Storm Restoration Costs Savings due to Hardening (SMM)
40-Year NPV (2017$)
Matthew Savings
Everv 3 vears Everv 5 vears
S6s3 S40G
Discount Rate = 7.760/o
$o
So
$r
$1
1
2
3
4
5
6
7
8
9
L0
IT
t2
13
1.4
15
L6
17
18
19
20
2L
22
23
24
25
26
27
s10s
So
So
Slos
$o
So
So
$o
S1r-8
So
So
So
So
S133
$o
5o
So
So
$i.so
5o
So
So
So
S169
so
$o
So
So
$1so
So
cPr
2.r%
2.4%
2.4%
2.6%
2.7%
1.7%
2.5%
2.4%
23%
2.2o/o
2.2%
2.2%
2.2%
2.2%
2.2%
2.t%
2.L%
2.t%
2.1%
2.1%
2.1%
2.1%
2.1%
2.t%
2.I%
2.1%
2.L%
13
$o
$o
cPt
Multiplier
1.000
1.024
1.049
1.076
1.105
1.124
1.152
1.179
1.206
1.233
1.260
1.288
1.317
1.346
1.375
1.404
1.434
1.464
1.495
1.526
1.558
1.590
1.623
1.656
1.691
1,727
1.763
Matthew
slos
S1o7
S1r-o
Si-13
S11s
Sr.18
S121
5124
5rzi
Si.3o
Si_33
S136
$13s
s143
$i-46
Slso
$1s3
S1s7
S16i-
S16s
$16s
Si.73
$r77
Srsr
$18s
$lso
$rga
S12r.
so
$o
$130
$o
$o
sL3s
slso
$o
So
$rer
$o
so
73
so
So
Slss
So
So
Matthew Savings
Everv 3 vears Everv 5 vearsYear
Docket No. 20200071-El
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 13 of 1B)
28
29
30
31
32
33
34
35
36
37
38
39
40
sLes
so
So
$zt+
So
$o
S23o
$o
5o
s246
$o
So
So
5zt4
So
So
So
So
$24r
$o
So
$o
So
2.to/o
2.2%
2.2%
2.1%
2.2%
2.to/o
2.1%
2.1%
2.I%
2.I%
2.7o/o
2.1%
2.1%
1.801
1.840
1.880
1.920
1.962
2.004
2.047
2.090
2.135
2.180
2.226
2.274
2.322
Sles
$204
$2oe
5214
S21e
5224
s230
$23s
5241
5246
52s2
s2s8
s26s
So
So
s26s
NPV (2017$) I s6s3 s406
Docket No. 2O2OO071-E\
FPL'' 2020-2029 Storm Protection PIan
Exhibit MJ-1, APPENDIX A (Page 14 of 18)
Florida Power & Light Company
Docket No. 20170215-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1
Tab3of5
Estimated Storm Restoration Costs Savings due to Hardening (SMM)
40-Year NPV (2017S)
lrma Savings
Everv 3 vears Everv 5 vears
s3,082 S1,915
Discount Rate =7.76%
cPl
cPt
Multiplier
1.000
1.024
1.049
1.076
1.105
1.124
1.1s2
1.179
1.206
1.233
1.260
1.288
1.317
1.346
1.375
1.404
1.434
1.464
1.495
1.526
1.558
1.590
1.623
1.656
1.69'l
1.727
1.763
lrma
$4e6
SsoT
Ss20
Ss32
Ss+s
sss8
Sszr
Ssss
$see
$6i.3
s628
s543
$6ss
$674
s6s1
Stol
5724
5742
STss
5778
S7s6
$s1s
$s3s
Ssss
s876
s8s7
Ssi-8
$o
So
So
Ss76
$o
So
L
2
3
4
5
6
7
8
9
10
11
t2
13
t4
15
16
ll
18
L9
20
21.
22
23
24
25
26
21
S4e6
So
$o
ss32
So
So
$szr
$o
$o
$613
$o
So
S6ss
So
$o
5t07
So
$o
STss
so
$o
$s1s
$496
$o
so
so
So
Sss8
So
21%
2.4%
2A%
2.6%
2.7%
Lt%
2.5%
2.4%
23%
2.2%
2.2%
2.2%
2.2%
2.2%
2.2%
2.L%
2.r%
2.I%
2.t%
2.1%
2.1%
2.1%
2.L%
2.r%
21%
2.1%
2.1%
so
$o
s628
So
So
$o
so
5t07
$o
so
so
So
S7e6
$o
So
So
so
S8e7
$o
Year
Matthew Savings
Everv 3 vears Everv 5 vears
Docket No. 202OOO71-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-'l , APPENDTX A (Page 15 of 18)
28
29
30
31
32
33
34
35
36
37
38
39
40
Ss4o
So
So
S1,oo9
So
So
S1,084
$o
So
5L,164
So
So
s1,250
$o
So
so
S1,oo9
so
$o
So
$o
S1,136
So
$o
So
So
2.L%
2.2%
2.2%
2.L%
2.2%
2.La/o
2.I%
2.7%
2.1%
2.1%
2.t%
2.1%
2.1%
1.801
1.840
1.880
1.920
1.962
2.004
2.047
2.090
2.135
2.180
2.226
2.274
2.322
Se40
$s63
Ss86
Sr,oog
Si_,034
S1,058
$1,084
S1,110
s1,135
St,16+
5L,rgz
SL,zzo
s1,250
NPV (2017s)S1,915s3,082
Docket No. 20200071-El
FPL'' 2020-2029 Storm Protection Plan
Exhibit MJ- 1 , APPENDIX A (Page 16 of I B)
Florida Power & Light Company
Docket No. 201-702L5-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1
Tab4of5
FPL
WEIGHTED AVER.AGE COST OF CAPITAL
STATE INCOME TAX
FEDERAL INCOME T
5.50%
21.OOoA
COMPOSITE INCOME TAX RAT 25.35O/O
MODEL DATE:1-Jan-1 8
Debt Gost Based on Blue Chip Corporate Aaa and Bbb Bonds
AFTERTAX PRETAX
SOURCE /UEIGHT(1) coST(2)/TD COST /TD COST /TD COST
DEBT
COMMON
40.40%
59.60%
4.88o/o
10.55%
1.97%
6.29%
1.47o/o
6.29%
1.97%
8.42%
TOTAL 100.00%8.260 7.760 10.39%
AFTER-TAX WACC 7,76%
Docket No. 20200O71-El
FPL'9 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX A (Page 17 of 1B)
Florida Power & Light Company
Docket No. 20170215-EU
Staff's First Data Request
Request No. 29 - Third Supplemental Amended
Attachment No. 1
Tab5of5
Consumer Prices (1982-84=1.000) All-Urban
(Forecast adjusted to match budget assumptions)
lndex % Change
2009 2.1454
2010 2.1.806 L.64%
2A1J 2.2494 3.16%
2012 2.2959 2.O7%
20L3 2.3296 I.46%
2014 2.3614 1..62%
2015 2.3702 0.I2%
201.6 2.4001. r.26%
2017 2.4512 2.13%
2018
20L9
2020
202L
2022
2023
2024
2025
2026
2027
2028
2029
2030
203L
2032
2033
2034
2035
2036
2037
2038
2039
2040
204L
2042
2043
2044
2045
2046
2.5100
2.5703
2.6371
2.7083
2.7553
2.8231
2.8909
2.9569
3.0228
3.0895
3.1573
3.2270
3.298L
3.3693
3.441t
3.5142
3.5887
3.6642
3.7408
3.8187
3.8972
3.9779
4.0603
4.L449
4.2324
4.3226
4.4153
4.5104
4.6077
2.40%
2.40%
2.60%
2.to%
1.73%
2.46%
2.40%
2.28%
2.23%
2.21%
2.19%
2.21%
2.20%
2.16%
2.I3%
2.12%
2.I2%
2.10%
2.09%
2.O8%
2.06%
2.07%
2.O7%
2.08%
2.tt%
2.13%
2.1.5%
2.15%
2.16%
Budget Assumptions
2.40%
2.40%
2.60%
2.70%
Docket No. 20200071-El
FPL's 202A-2o29 Storm Protection Plan
Exhibit MJ-1, APPENDIX A (Page 18 of 18)
2047
2048
4.7A67
4.8099
2
2
$%
t9Yo
2049
20s0
2051
2452
2053
2054
2055
2056
2457
4.9L22
5.0L67
5.1233
5.2323
5.343s
5,4572
5.5732
5.6917
5.8128
2.t3%
2.L3%
2.L3%
2.L3%
2.t3%
2.t3%
2.13%
2.t3%
2.13%
Actuals thru 2017 from BLS
APPENDIX
(FPL's Management l
i:
:2t
:
i4
taI
I
I
-t1t-
1
A.xrl
'j'
iL
AI
d
IEr'.
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX C (Page 1 of 2)
APPENDIXC
(FPL'I 2020-2029 Estimated SPP Costs)
2O2O-2O29 FPL
'PP
Program Costs/Activities
Docket No. 2O20O071-E\
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX C (Page 2 of 2)
Distribution - Pole lnsoections
Operating Expenses
Capital Expenditures
Total
# of Pole lnspections
Transmission - lnsoections
operating Expenses
Capital Expenditures
Total
# of Structure lnsPections
Distribution - Feeder Hardenins (1) (21
Operating Expenses
Capital Expenditures
Total
# of Feeder (3)
Distribution Lateral Hardeninp (1) (2)
Operating Expenses
Capital Expenditures
Total
# of Laterals (3)
Transmission - ReplacinF Wood Structures
OpeEting Expenses
Capital Expenditures
Total
# of structures to be Replaced
Distribution - Veqetation Manaqement
Labor - Contractor
Labor - FPL
Equipment - Contractor
Equipment - FPL
Total
# of Miles Maintained
Transmission - Vegetation Management
Labor - Contractor
Labor - FPL
Equipment - Contractor
Equipment - FPL
Total
# of Miles Maintained
Substation Storm surse/Flood Mitiqation
Operating Expenses
Capital Expenditures
Total
# of Substations
3.8
54.1
3.8
55.3 55.3
3.9
56.4
3.9
57 -8 62.3
39.1
556.1
3.9
56.5
s
5
5.6
50.7
ss3.8 s
s4.1 s
s
s9.0
154,000
68.s
68,000
in millio
59.1
L54,000
55.6
68,000
s 66.s
154,000
505,2
s
s
s
60.3 s 61.8 s 63.3 s
154,000 154,000 154,000
4.0 s 4.1 s
s9.3 s 60.8 s
64.9
s
s4.5 s s7.9 s s7.9
150,000 150,000 154,000
5 32.2 S 28.9
68,000 68,000
60.5
154,000
1.3
34.5
1.0 s
31.2 s
1..0
27.9
1.0
67.5
1.0
54.6
1.0
s3.3
1.0 s
s4.6 s
5 t-.0
52.0
s 1.0 s 1.0 s
s6.o s s7.4 s
s4.3 s ss.7 s s7.0 s s8.4 s
68,000 68,000 58,000 68,000
u7.2 653.4 s 67e.9 s 696.e s
800-900 800-900800-900 800-900
499.5 50.0
s 3,20s.8 s s34.3
5,101.4 s 510.r"
10.5
489.0
1.0
48.9
s
35.8
68,000
53.0
68,000
s 623.1 5 664.9 S 654.9 S s73.3 S 474.s S 200.0 5 s s s s 3,20s.8s 534.3
s
S s10.1
5 628.1 S 564.9 S 554.9 S s73.3 5 474.s 5 200.0 S
300-350 300-350 300-350 300-350 250-350
!20.4 212.5 342.8 s 47s.6 637.4 63L.4 647.2 663-4 679.9 696.9 s
L20.4
220-230
212.5 5 342.8
300-3s0 400-500
$ 47s.5
500-700
631.4
800-900
631,.4
800-900
0.2 s
s2.1 5
0.2
42.7
0.2
21,-9
s
s 60.6 s s9.s
s 0.6
117.3
0.2
39.1
s s
5
s
s
s
s
s
s
ss
43.8
1.5
11.0
0.1
s
s
)
s
s
s
s
s
s
s
s
s
s
s 52.9 s 42.9
1,400-r-600 900-1,100
72.7 II7.9 39.3
46.4
tf-b
300-600
5
s
s
s
s
5
s
s
3.0
3.0
1
s
s
47.7
1.3
L1.9
0.1
46.9
1.4
L]'.7
0.1
44.6
1.5
1]..2
0.L
57.4
15,200
463.7
L4.7
115.9
L.4
47.8
7.4
L2-O
0.1
s
)
s
s
s
s
s
s
s
5
5
46-9
1.5
tL.7
0.1
50.2s 60.2s 60.6
L5,200 15,200 15,200
8.9 s s.0 s
7,000 7,ooo
47.1 46.3 45.5
11.8 17.4
47.r
1.5
1"L.8
0.1
7.2
0.5
0.1
l-.6
5
s
5
s
1.5
LL.6
0.1
s
s
s
1.5
0.1
1.5
0.1
0.5
1.8
0.1
9.6
b1.a
15,200 75,200
61.3
15,200 15,200
0.r.
7,2
9.9
7,OOO
58.5
15,200
lo.2
7,O00
56.4
15,200
59s.7 s 59.6
5
s
s
s
5
s
7.6s
5
s
5
s
s
s
s
s
5
5
s
s
)
6.7 I
0.5 5
L.7 s
6.5
0.5
L.7
0.r.
6.7 s
0.s $
r.7 5
0.1 5
0.6
1.8
0.1
7.4
0.6
1.8
0.1
0.6
1.9
0.1
7.9
u.b
2.0
o.2
77.7 5
5.3 s
17.9 s
1.4 s
5.7
0.5
L]
0.r-
7,000
8.e s
7,000
9.0 9.7 s 9.7
7,000 7,000
7.8
0.6
L.9
0.10.1
10.4 s 10.7 s
7,OOO 7,000
96.4 s
s s 5s
s
5
s
5
s
s
s
10.0 23.0
23.O
7.7
7.710.0
2
5 s64.7 S 1,090.7 S 1,x9s.8 S 1,24s.6 S1,290.9 S1,014.9 S 832.7 S 8s1.0 $ 859.7 S 889.0 S10,24s.0 S L,27L.L
10.0
10.0
to7
s
5
Total SPP Costs
{1) Project level detail for 2020 in Appendix
(2) Costs include previous year(s) projects carried over to current year's project costs and future year's preliminary project costs (e.9., engineering)
(3) f offeeders or lateral to be initiated in the current year
Total SPP
Costs
An nu al
Average CostFPL SPP Programs 20292024202320222021,2020 2024 2025 2026 2027
Docket No. 20200071-El
FPL's 2O20-2029 Storm Protection PIan
Exhibit MJ-1, APPENDIX D (Page 1 of 14)
APPENDIXI)
(FPL's Hardening Design Guidelines)
Dockei No. 20200071-El
FPL's 2O2O-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 2 ol 14)
@FPL
Distribution Design Guidelines
The following guidelines will be used to standardize the design of FPL's overhead distribution
facilities when practical, feasible, and cost effective.
General
FPL has made a change to adopt Extreme Wnd loading (EWL) as the design criteria for:
(1) new pole line construction, (2) pole line extensions, (3) pole line relocations, (4)
feeder pole replacements on multi-circuit pole lines, and (5) feeder pole replacements on
Top-ClF feeders. Reference the Pole Sizing section (pg. 7) for the guidelines to
determine the necessary pole class and type for all work. Refer to the Distribution
Engineering Reference Manual Addendum for calculating pole sizes for specific framing
under extreme wind loading conditions.
2. For maintenance, existing non-top-ClF pole lines may be evaluated using NESC combined
ice and wind loading with Grade B construction. This represents the loading prior to the
adoption of extreme wind loading. lf the pole must be replaced, refer to the Pole Sizing
section for the minimum class pole to be installed. Refer to the Distribution Engineering
Reference Manual (DERM) Section 4 for calculating pole sizes for specific framing under
the NESC combined ice and wind loading conditions.
3. Every attempt should be made to place new or replacement poles in private easements
or as close to the front edge of property (right of way line) as practical.
4. Overhead pole lines should be placed in front lot lines or accessible locations where
feasible.
5. When replacing poles, the new pole should be set as close as possible to the existing
pole to avoid the creation of a new pole location.
6. Poles are not to be placed in medians.
7. Concrete poles are not to be placed in inaccessible locations or locations that could
potentially become inaccessible.
8. Please reference the minimum setting depth charts located in DCS D-3.0.0 which shows
the increased setting depths for concrete poles.
9. Every efforl should be made not to install poles in sidewalks. lf a pole must be placed in
a sidewalk, a minimum unobstructed sidewalk width of 32" must be maintained to comply
with the American Disabilities Act (ADA) requirements.
10. lf concrete poles are required by the governing agency as a requirement of the permit,
and if the work is being done solely for FPL purposes (feeder tie, etc.), then the concrete
Docket No. 2O200O71-EI
El,i';,,'ffi 3;i KJ,'. fi 'Jf f lFtT fl?i,,
poles are installed with no differential charges. lf the concrete poles are required as a
condition of the permit, and the work is being done at the request of a customer (and fall
outside the Pole Sizing Guidelines) to provide service to the customer or relocation by
request of the customer, then the customer is charged a differential cost for the concrete
poles.
1 1. \Nhen installing new OH secondary spans, multiplexed cable should be used instead of
open wire secondary. When reconductoring or relocating existing pole lines containing
open wire secondary, replace the open wire with multiplexed cable whenever possible.
The system neutral should not be removed when replacing open wire secondary with
multiplexed cable if primary wire is present. lt is necessary to maintain a separate
system neutral for operational continuity of the system.
'12. When designing overhead facilities where secondary and service crossings exist across
major roadways, the engineer should take into consideration placing these secondary
street crossings underground. Operations Director Approval is required.
13. Whenever extending a feeder, reconductoring a feeder section, or attaching a device to a
feeder, always reference the nearest existing disconnect switch number on the
construction drawing and show the dimension to the switch. This will aid the Control
Centers in updating their switching system and will aid AMG in updating AMS, as well as
provide the Productioh Lead and Distribution Tech information needed for switching and
RC Off requests.
14. When an overhead feeder crosses any obstacle to access (i.e. - water bodies such as
rivers, canals, swamps; limited access RA// such as interstate highways, turnpikes, and
expressways; etc.) disconnect switches should be placed on both sides of the obstacle in
order to isolate the crossing in the event of a wiredown situation. See the example in the
Crossing Multi-Lane Limited Access Highways section (pg. 5).
15. Projects that affect or extend feeder conductors should always be coordinated with
Distribution Planning to ensure optimization of the distribution grid. Taking into account
future feeder plans such as, feeder boundary changes, sectionalizing devices, integration
of automation and remotely controlled protection.
As always, good engineering judgment, safety, reliability, and cost effectiveness should be
considered. ln addition to these guidelines, all distribution facilities shall be engineered to meet
the minimum requirements set forth in all applicable standards and codes including but not
limited to the National Electrical Safety Code (NESC), Utility Accommodation Guide, and FPL
Distribution Construction Standards. Please contact a Distribution Construction Services (DCS)
analyst with any questions.
@
Docket No. 2020O071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 4 of 14)
FPL
New Construction
When installing a new feeder, lateral, or service pole, reference the Pole Sizing section for
the guidelines to determine the necessary pole class and type to meet Extreme Wind
Loading (EWL) for the wind zone region (105, 130, or 145 MPH).
2. Modified Vertical is the preferred framing for accessible locations. Post-top (single phase) or
Cross Arm (multi-phase) is the prefened framing for inaccessible locations.
3. During the design of new pole lines in developed areas, field visits should be conducted to
ensure the design would cause minimum impact to the existing property owners.
4. Overhead pole lines should not be built on both sides of a roadway unless agreed to by the
customer nor should multi-circuit pole lines be created. When designing main feeder routes
all viable options must be reviewed (including alternative routes) and consideration should
be given to constructing the line underground. lf undergrounding is chosen and it is nglthe
leait cost option, approval is required from the Engineering & Technical Services Director
and the Operations Director. ln addition, prior to proceeding with any pole lines on both
sides of a street or any multi-circuit feeder design recommendations, Operations Director
approval is required.
5. When there is an existing pole line in the rear easement, every effotl should be made not to
build a second pole line along the right of way.
6. When installing a pole line within a transmission line, accessible distribution poles should be
concrete. Distribution concrete poles should not be installed in inaccessible locations.
lf concrete distribution poles are installed in a concrete transmission line, there is no
additional charge to the customer (the concrete poles are FPL's choice and not requested by
the customer). Coordination between the transmission and distribution design is critical and
consideration should be given to a design with alltransmission poles versus distribution
intermediate poles. This approach will reduce the overall number of poles.
When transmission is overbuilding (concrete structures), along an existing distribution
corridor, if the distribution wood poles are in good condition, do not replace, lf wood poles
need to be changed out or relocated, replace with concrete poles to match the transmission
pole type. Coordination between the transmission and distribution design is critical and
consideration should be given to a design with alltransmission poles versus distribution
intermediate poles. This approach will reduce the overall number of poles.
1
7
8
@
Docket No. 20200071-El
F PL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 5 of 14)
FPL
Existing / Maintenance
1. When installing andior replacing a feeder, lateral, or service pole on an existing pole line,
reference the Pole Sizing section for the guidelines to determine the necessary pole class
and type.
2. When installing or replacing a feeder pole on a feeder that serves a Top-ClF customer,
ensure the new pole will meet extreme wind loading (versus just a minimum class 2 or lllH
pole) so that it will not have to be replaced when the feeder is hardened as a hardening
project. Please reference the Storm Secure Hardening SharePoint Site: Distribution >
Central Maintenance > Central Contractor Services > Hardening > Reports > Feeder
Prioritization_xxxxxx Snapshot for the list of Top-ClF feeders within the Prioritization File.
3. When extending pole lines, the existing pole type should be used as a guide for the new
pole type. lf concrete poles are requested by the customer or are required as a condition of
the permit and fall outside the Pole Sizing Guidelines, the customer will pay a differential
charge for the concrete poles.
4. When replacing pole(s) and anchor(s) with larger self-supporting concrete poles, caution
should be used, as the property owners in the vicinity of the pole will not necessarily
perceive this concrete pole as a better choice.
5. When replacing poles on a multi-circuit feeder the replacement pole should be designed for
Extreme Wnd Loading using Pole Foreman to calculate the wind loading.
Relocations
1. When relocating a pole line, reference the Pole Sizing section for the guidelines to determine
the necessary pole class and type to meet Extreme Wind Loading (EWL) for the wind zone
region (105, 130, or 145 MPH).
2. When relocating either a concrete or wood pole line for a highway improvement project, the
existing pole line 'type' should be used as a guide for the pole type replacements. There is
no additional charge for concrete poles if the existing poles being relocated are concrete
(like for like relocation). lf the customer requests an "upgrade" to concrete poles, a
differential is charged.
3. Reimbursable relocations will equal the cost to relocate the line built to Extreme Wind
Loading (plus removal of old), including indirect cost.
4. Agency relocation projects should be coordinated with Distribution Planning to ensure
optimization of the distribution grid and to take into account future feeder plans and potential
feeder boundary changes.
@
Docket No. 20200071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-'|, APPENDIX D (Page 6 of '14)
FPL
Crossing Multi-Lane Limited Access Highways
The following guidelines are to be used when an overhead feeder crosses any obstacle to
access (i.e. -limited access RAIV such as interstate highways, turnpikes, and expressways,
etc.). Similar consideration can be given to water bodies such as rivers, canals, swamps.
1. Underground installation is the preferred design for all new crossings (1,2,3 phase) of multi-
lane limited access highways & hardening of existing crossings; reference Fig 1. Limited
Access Highway Crossing Schematic (Preferred). lf underground construction is not
feasible, reference Fig 2. Limited Access Highway Crossing Schematic (Altemate).
2. Underground crossing for 1 & 2 phases should be designed for potentialthree phase feeder
size cable. Ensure riser poles meet or exceed extreme wind design for the designated
region. For further information, please contact the CMC Hardening Group.
3. For accessible overhead crossings, use concrete poles (lll-H or greater square concrete
pole) for the crossing poles and minimum Class 2 wood poles for the intermediate poles. For
inaccessible overhead crossings, minimum Class 2 wood poles should be used for the
crossing and intermediate poles. All poles installed should meet or exceed EWL for the
designated region.
4. Every attempt should be made to install storm guys & back guys for the highway crossing
poles. Storm guys are not required on the adjacent poles.
5. Frame the highway crossing pole double dead-end (See LOC 2 & 3 Fig 2 below).
6. lnstall disconnect switches on adjacent poles on both sides of the crossing (or as required
by field conditions) to isolate the feeder section for restoration. Switches are to be installed
in accessible locations that can be reached with readily available aerial equipment.
Switches should be installed at -42 Above Grade (AG), with a maximum pole size of 50'
wood or 55' concrete. lf there is no load between the nearest existing switch and the
crossing, an additionalswitch is not required.
7. Check for uplift on all poles. Refer to DERM Section 4.2.3Page 4 of 16 & DCS E-4.0.2 and
E-4.0.3. Back guys should be installed at the adjacent pole if required for uplift.
8. Ensure to maintain proper clearance above or under all highways as dictated by the owner
of the RAru& DCS 8-3.0.1.
Any conductors crossing the highway that have splices should be replaced with a continuous
conductor (NESC 261H2a). See Fig 2 below for additional notes on the use of splices on
adjacent spans. One additional set of dead-end insulators at the highway crossing pole may
be used if this eliminates the need for splices when installing a new pole.
o
@
Docket No. 2O2O0071-El
FPL'9 2O2O-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 7 ot 14)
F]'L
10. Engineers must conduct a pre-design meeting with the Production Lead to ensure the
feasibility of the proposed design.
11. As always, use good engineering judgment to produce a quality, cost-effective design
Fig 1. Limited Access Highway Crossing Schematic (Preferred)
Fig 2. Limited Access Ilighway Crossing Schematic (Alternate)
INSTALL ACCESSIBLE
DISCONNECT SwlTCHES
REMOVE OH &INSTALL ACGESSIBLE
DISCONNECTSwlTCHES
3 #568T-23KV &3/0T-N
llF _ FNc
-llF
E o
a a o--5IotaaU
oUF
=j
e--a
DOWNGUYFOR DEADEND
OUTSIOE OF LIMITED
ACCESSHIGHWAY. ADJUST
LOCATION OF POLE FOR
FIELOCONOITIONS
ALTERNATE LOCATION FOR
RISERPOLE TO PREVENT
DOWN GUYIN L|MNED
ACCESS R/W
Dtsc sw @ -,t2'AG
MAX POLE SIZEI
50' wooD, 55'coNcRETE
INSTALL ACCESSIBLE
DISCONNECTSWITCHES NO SPLICES INSTALL ACCESSIBLE
DISCONNECT SWTCHES
3 #568T-23KV & 568T-N
CHECK FOR UPLIFT E
INSTALL DOWN GUYS IF f
f
f
TREQUIRED
a ---J e--F
BI(9ro0Uo
oUt
J
H----,*-, e----tlt\j-\
INSTALLSTORM
GUYS A BACX
a
MAX Drsc sw @ -,f2' A6
MAX POLE SIZE:
50'wooD, 55'coNcRETE
(swTcE LocAnoN MAY
VARY EASED ON FIELD
CONDIT'ONS. REFERENCE
D'SIFIEUT'ONDES'GA'
GUIDEL'NES)
L
I
!
INSTALL IiITERMEDIATE POLE IN
EFFORTTO REDUCE SPANS
@
Docket No. 2020O071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 8 of 14)
FPL
Pole Sizing
1. FPL has made a change to adopt Extreme \Mnd loading (EWL) as the design criteria for:
(1) new pole line construction, (2) pole line extensions, (3) pole line relocations, (4) feeder
pole replacements on multi-circuit pole lines, and (4) feeder pole replacements on Top-ClF
feeders. Reference the Pole Sizing Guidelines (at the end of this section) to determine the
necessary pole class and tYPe.
2. When installing or replacing a feeder pole on a feeder that serves a Top-ClF customer,
ensure the new pole will meet the extreme wind design (versus just a minimum class 2 or
tllH pole) so that it will not have to be replaced when the feeder is hardened as a hardening
project. Please reference the Storm Secure SharePoint Site: Distribution > Central
Maintenance > Gentral Contractor Services > Hardening > Reports > Feeder
Prioritization_xxxxxx Snapshot forthe list of Top-ClF feeders within the Prioritization File.
3. For maintenance, existing non-top-ClF pole lines may be evaluated using NESC combined ice
and wind loading with Grade B construction. This represents the loading prior to the adoption of
extreme wind loading. lf the pole must be replaced, refer to the Pole Sizing Guidelines for the
minimum class pole to be installed.
4. When performing work on an existing pole, and the pole requires change out (e.9.,
clearance height, location, condition, or the ability to support the planned activity), use the
Pole Selection Guidelines. lf the planned work can be done without changing out the pole
and the pole meets minimum NESC grade B wind loading guidelines, use the existing
pole(s).
S. Foreign pole owners are required to discuss design requirements with FPL prior to
construction. FPL will assist with identifying the targeted poles.
6. Efforts should be made to ensure that span distances do not exceed 250 ft. for wood poles
and 350 ft. for concrete poles even if longer spans would meet the Extreme Wind Loading
requirements.
7. Concrete poles are prefened in the cases where replacement costs would be extremely high (i.e' duct
system risir pole, corner poles with multiple circuits, critical poles, etc.). No differential is charged
for poles in this case.
@
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPFNDIX D (Page 9 of 14)
FPL
Lateral Pole Policv
1. Allexisting poles must meet NESC grade "B" as an absolute minimum.
2. lf a pole is modified in any way, it must meet NESC grade "B" at a minimum when
completed.
3. lf you become aware of a pole which does not meet NESC "8" or DCS standards, the pole
must be immediately upgraded or modified to meet the NESC & DCS standards.
4. All replacement lateral poles must meet NESC'EWL" and be compliant with FPL Pole
Policies.
5. Restoration of lateral poles should comply with the class 2/3 table.
For oractical purposes this means...
1. Engineer all poles to the NESC EWL standards and to meet FPL policies.
2. Run Pole Foreman on alldesigned WR's and poles suspected of being substandard.
3. lf you are completing substantial work on a pole, such as installing additional cables,
upgrading a TX, re-conductor or new framing: The pole must meet EWL and the revised
class standards.
4. lf you are completing minor like for like work such as replacing a fuse switch, insulator or
other small equipment: The pole must meet NESC grade "8" and DCS standards at a
minimum when the work is complete.
a. Note: Most FPL poles currently exceed NESC grade "8". This means there is
some leeway for minor changes in wind loading and clearances while maintaining
the NESC grade "B" minimum.
5. Temporary or time constrained poles may be installed to NESC grade "N" temporary
construction. This is relatively complicated, requires sound engineering judgment and should
be avoided. lf grade NESC grade 'N" is applied, a replacement pole engineered to NESC
EWL must be designed and installed as soon as practical and not longer than 6 months after
NESC grade "N" was installed.
6. Class 4 poles may only be installed for SVC, SEC, SL, OL's. Once the available stock of
class 4 is used up no more will be ordered and FPL will install class 3 poles for these
applications.
7. ln no case should class 4 poles be installed in laterals.
Gontact Enoineerino Standards for situations that still are in ouestion after careful
consideration
Docket No. 202O0071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 10 of 14)
@FPL
Gritical Pole Definitions & Sizing:
The following list comprises what will be considered critical poles. When installing and/or when
doing work that othenruise requires the replacement of an accessible critical pole, use concrete.
lf the pole is inaccessible, use a minimum Class 2 wood pole, or consider relocating the
equipment to an accessible concrete pole.
For all critical poles run Pole Foreman to calculate the wind loading for the specified pole and
attachments combination. Additional information can be found in DERM Section 4 - Addendum
for Extreme Wind Loading tables 4.2.2-8,4.2.2-9, or 4,2'2'10.
Every attempt shoutd be made to install storm guys where feasible and practical,
Frame inline per standard to equally distribute weight.
Refer to the Crossing Multi-Lane Limited Access Highways section for details.
Contact CMC Hardening Group before designing new multi-circuit line.
5) To eliminate field dritting, inventory Special Drill Pole & create Pole Boring Detailfor all Ill-H
Poles on Hardening Jobs.
1)
2)
3)
4\
Gritical Pole ldentifier
For new or when replaced use minimum lll-H Square Concrete Poles
(minimum Class 2 if inaccessible)
Gritical Poles
l"tswitch outof substation or
duct system riser pole
DCS Reference
UH-15.0.0 Fig 2
uH-15.3.1
CriticalPoles
Automated Feeder Switches
(AFS)2 c-9.2.0
ce
lnterstate Grossin gsl'3 E-10.0.0 Fig 2 Aerial Auto Transformers2 t-9.0.0
Poles with multiple primary
risers uH-15.2.0 3 phase transformer banks
3 - 100 kVA and largef l-52.0.2
Multi-circuit polesa
Three-phase rectosers2 (or
Th ree single-phase reclosers)
Frame as existing
c-8.0.0
Capacitor Banks2
Regulators
J-2.0.2 & J-2.0.3
t-10.1.1
PrimaryMeter K-28.0.0 lntelliruptors c-9.5.0
All references are to the Distribution Construction Standards
Docket No. 2O200071-El
FPL'g 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX D (Page 11 o'f 14)
@FPL
Pole Sizing Guidelines:
The following tables should be used as guidelines to help determine pole class and type, when
installing and/or replacing a feeder, lateral or service pole.
Feeder or Three Phase Lateral:
When designing for EWL run Pole Foreman to calculate the wind loading for the specified pole
and attachments combination. Additional information can be found in D$RM Section 4 -
Addendum for Extreme Wind Loading tables 4.2.2-8,4.2.2-9, or 4.2.2-10.
Si le or Two Phase Lateral:
Nofes. 1) To be used when replacing equipment or instatting new equipment on an existing pole.t) Reference Criticat Pole L'tst on pg.8.
tJ Use of ttl-G poles should be timited to existing concrete lateral pole lines whose wire
s2e is less than or equal to 1/0A.a) tJse Pole Foreman to calculate wind toading on all poles.
Pole Line
Description
New Gonstruction,
Line Extension, &
Pole Line Relocation
Existing
lnfrastructurel
lnstalling or
Replacing
a Critical Polez
Wood Use minimum Class 2
Wood Pole to meet EWL
Use Class 2 Wood
Poles
Use lll-H (Accessible) or
Class 2 Wood
(lnaccessible)
Concrete
Use minimum lll-H
Concrete Pole to meet
EWL
Use lll-H Concrete
Poles
Use lll-H Concrete
Poles
Pole Line
Description
New Construction,
Line Extension,
Pole Line
Relocation, Pole
Replacement, &
lntermediate Poles
Existing
lnfrastructurel
lnstalling or
Replacing
a Criticat Polez
105/135 mph:
Use minimum Class 3
MUSImeet EWL
105/135 mph: Use
minimum Class 3
Wood 145 mph:
Use minimum Class 2
MUSImeet EWL
145 mph: Use
minimum Class 2
Use lll-H (Accessible) or
Class 2 Wood
(lnaccessible)
Concrete Use minimum lll-G3 or
lll-H poles
Use lll-G" or lll-H
poles to match
existinq line
Use lll-H Concrete
Poles
Docket No. 202OO071-EI
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX D (Page 12 o'f 14)
Basic Span Lengths for selected poles for Extreme Wind Loading:
Facility Phase(s)Wire size Pole
size
Recommended Maximum Span Lengtha
(FPL with 2 aftachments - FPL ONLY)
,I05 MPH 130 MPH 145 MPH
Feeder 3#568ACAR Class 2 1 80', - 230'125'- 200'90'- 140'
3#3/0AAAC Class 2 180'- 250'170'-250'120'-220',
Lateral 3PH 3#1/0AAAC Class 2 1 80' - 250'1 80' - 250'155'- 250'
2PH 2#1t0 AAAC Class 3 1 80' - 250'1 80' - 250',125' - 250',
1PH 1#1/0AAAC Class 3 1 80' - 250'1 80' - 250'1 50', - 250'
nThe lower number equates to the maximum span for FPL primary and two 1" foreign
attachments. The higher number equates to the recommended maximum span for FPL
primary only. Reference the DERM Addendum for EWL tables 4.2.2-8, 4.2.2-9,4.2.2-10 when
adding additionalattachment{s} or equipment. As always, good engineering judgment,
safety, reliability, and cost effectiveness should be considered.
Service / Secondary / St. Light / Outdoor Light Poles:
When installing or replacing a service or street light poles, a minimum of Class 3 wood pole
should be used. Specific calculations may require a higher class pole for large quadruplex wire.
For any questions on pole sizing to meet EWL or running Pole Foreman to calculate wind
loading, please contact the CMC Hardening Group.
Docket No. 20200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-'l, APPENDIX D (Page 13 of 14)
@trFL
islf{ffi 1os MPH- jtso tr,tpx
ffir4sMPH
Extreme Wind Loading (EWL) 3 Zone Map
Wind
Zone County
105 Alachua
105 Baker
105 Bradford
130 Brevard
145 Broward
130 Charlotte
130 Clay
145 Collier
105 Columbia
145 Miami-Dade
130 De Soto
130 Duval
130 Flaqler
130 Glades
130 Hardee
130 Hendrv
130 Hiohlands
145 lndian River
130 Lee
130 Manalee
145 Martin
145 Monroe
130 Nassau
130 Okeechobee
130 Osceola
130 Oranqe
145 Palm Beach
130 Putnam
130 Sarasota
130 Seminole
130 St Johns
145 St Lucie
105 Suwannee
105 Union
130 Volusia
Docket No. 2O200O71-E\
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX D (Page 14 of 14)
Notification of FPL Facilities
Form 360, Notification of FPL Facilities, is to be used for allconetruetion projects. Please
include a copy of this form in negotiations with builders and developers. This form can be found
on the DCS Webeite under "Letters and Agreements", or in WMS on the "Reports" menu item
for the work request.
Docket No. 20200071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX E (Page 1 of 16)
APPENDIXE
(FPL's 2020 Project Level Detail)
Docket No. 202O0071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX E (Page 2 ol 16)
Appendix E: FPL 2020 Project Level Detail
Feeder Hardening (EWL) - Distribution Program
X
330 3.109 I $12,476
244 1.523: S 508.1 80
,oc!1 7802631 lJul-22
180 1461!S3.384.362
161 iDec-20 lAuo-23 1.080 86
X
50355? ;Jiln-14 ,Jan-21 3.267 6S9
X
34 2 1.S4S I S 39.220
I Mav-14503569 iDeG20
3030!s4.1S6.273
811361 lJuL14 lJun-21
1235:S16S4888 X
283
X
275 2.858 I S 394.865
lJul-19403239 lMav-22
3.278 : $ 3.213.746
;05763 lJan-18 1Ao.-22
3340; S 12.SS5 X
lDee20 iMar-23 'I 211
X
i.hin-2o ,OcL21 1 645 103
1.403 I $100 0763754
0062 IOcL14 IDee2l
249S: $ 2.301.662 X
lJun-1S706362 tMei22 1.624
I 376 I S 5867 X
483
X
2 062 72 2.134 i $20,791
'1.686 | $130.922
lAua-19700831 tJul22
1.526 I S 677.282
lJuLl I700833 tAud-22
1730,52247.506 X
lAua-14 tOeG21 967 1,080 I $941,114
6621$2.215 X
:Nov-221833lDeD20 65
X
52 '1.423 I S 1.448.431
c'1838 lAuo-14 lNoF21
1.335 : S 707.033
810434 lNov-15 ,Jtrl-22
1.2S4 : $16.748
{00734 lJul1g lJul-22
X
1.038 23
21331$814 6S4 X
81
x
1S5 14 907:$140,568
404232 lseo-19 lSer21
1.481 I $6S3.3t55S2
104240 :Oct-14 tMaF2l 1.1 83
1{73i$970.255 X
i02{68 iAuo-18,Auo-2'l 2.148
X
354 13
939 | $ 1.73'1.492
500235 lFeb-lS iNov-21
1 1.364 I $618.1 56 X
lAuo-16308632 ;Jul-2'1
1106:$8.S91 X
1.885 172
X
70a432 ,Jan-22 1.292 71
X
5 1.513 : $4.785
765:$238.586
21
2963 i $ 4170618 X
50406d lSe&18 lMav-21 4.706 5.232 I $198,S12
357S: S 2520 X
466 15
1A'7
409764 lNoF18 ,Mav-22
2.620 i S 10.482
I Nov-18)263 lJun-21
1362i$55.010 X
lDeG2006s62 ,Ano-22
1 193: S 1.11S_1S3 X
iFebl S263 :Jul-21 2.053 91
X
:Nou18 anec.21 1 053 312 3
215
78 5 't.975 I $1 1.365
lma /
Matthew
Outaqe
2020 Project
cost
Docket No. 20200071-El
FPL's 2O2O-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX E (Page 3 of '16)
{05467 lNoF16 Jun-2'l
100434 lNos16 162 1
1.217 209 3
1 1.17e $ 201.'121
301139 lAuo-18
508061 lSeo-18 2.113 X
861
507465 lSeG15 Jun-21
t-21 28 3.451 X
Aud-21 1.847 I
20'1932 lJun-18 SeG2l 127 1,7 47 t
C1935 iSeclg Seo-22 1 .185 41
11 3.641 :61.811
707661 lDec-'17 l\,,lav-21 68S
Mar-23 825 318 1.173 8.072 X
1.224
702131 lFebl7 Mev-21 1S1 1 192 55.289 X
264
1.56605433:Jun-16 Jun-21 65 X
lJul-1s305439 DeG21 't64 l X
607 3 740 X
'Jun-19
,07 512
i01532 lDeGl7 Mau-22
At6-22 3.301 l
+00234 lSeo-17
{00240 lOcL15 r-21 373 I
X
/03531 lNos18 '1.535 2SS 2
I 1.S55 $ 38.462 X
Jul-21
s 616
102131 iOcL16 Mat-21 256 157 2
106S33 !Mer-lS 2 s75 $ 167.485
Jun-21 2.921 127
338.01Sr221.S43 l X
to4262 lDeo20
132 lNos18 ,Aau-22 1.636 125 '1.765 X
133S1
109837 iJun-19
o32 lJun-20 eo-21 1.386 161
{1 1032 I Nos18 Jul2l 137 209 646
2132,61.783 X
1,822 I
Estirnated /
Aclual Stan
Datelll
lrma /
Outaqe
Docket No. 20200071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX E (Page 4 of 16)
3 1.'180
122 1.112 ,46.876
500761 iDec-20 NoF22 1.160 25S
500768 lDec-20 Ma.-23 2.008 6
1 942 86 2 2.030 l
1727 I 453 522 X
808064 lJul-18 ec-21 8S9 219
07251 lMrr-18 lrn-21 2 124 s8 2.222 s 11.627
75 1.670 i 21.261
102132 :Jul-20
102131 :NoFl5 't 75
t06861 lSeG20 3eo-22 2.120 '103 1
2.n17 X
113 2 494 s 433 006 X
X
1.606 345 1
Aua-21 175 5 2.261
3 916 $ 10.s08
X
't 35 IMav-'l5
X
501138 lOcll I i-21 151 219
X
1.815
3 886 s 85.463 X
Sep-20
108363 lDeolg SeD-22
$ 1.354.416101 540 iFeb-1S SeG21 '|.876 204 2.080
2 $ 881.789
14837 lJun-'16
1.456 X
2 446 s 1 537.758 X
sR 60 107561 lMav-{4 191
407563 lMav-'19 Aor-22
2.221 227 2
85 1.902 s 835.298 X
806031 lMar-1 5
7S 1.15S s 1.720.558 X
lAuo-1 I404131
$ 11 365
lAuo-1 g807332 Jun-21 88
X
Jul-22 390 2,1
2 516 47 2.685 s 1 1.S44
2 279 6 812$X
)8762 lOc!'14
X
t04534 lDec-20 !ou22 1 .8S7 65
\ov-22 64 1 813
l'1032 lDee20
751.376$rn-23 3.1 33
X
70s162 lAuo-19
$ 3.3f3.S44 X911
708s33 lNoF16 Mau-21 218 1
X
lJsn-17700931 Atro-2z 1.489 1 .813
231A 72 4
3.122 X
317 s 83.S43
203637 lDec20
818 X
100331 lJul-1S 671 261- *--"7;{
lDeG'19100333 SeD-22 686 136 3
lrma /
Matrhew
Outage
2020 Project
cost
Docket No. 202O0071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX E (Page 5 of 16)
lNos18'02935 ,Jul-22 1.608 107 I
,Auo-18702S3S t Aor2l 2.257
2 224
2
,No*19208161 lSer22
208164 lSeo-20 :Auo-23 2 ASI 2S6
511 , S 277.250 x
:Od-14 ,A,or-21 1.162 X
1.670 I $ 1.744.401 x
too232 lDec-20 lNos22 607 43
700235 IDec20 tAvo-22 1S1 1.468 I S 1.522 X
1,{5
2.255 I S 5.237
12 2.572 t $064.048
lNoF'18500437 tFeb-22 1.44 262
:Auo-16701261 tJun-21 1.6S0 121
507063 lDe&20 tMat.23 2.673 : $ 30.911 X
lAor.1 5 :Now20202034 1.216 213 2
tJan-17 lDec-2 1804633
lNow22804636lDec20 779 25S
X
1.460 | S 304.521
38A!$21 245
1.777 ) S 2.139.286lNoF'18102638 1J[n-22
1.005: $208.58S
lAuo-18804335 ,Jen-22 1.688 121 2 1.811 : $827.797 X
{06861
'
i,,lav-1 8 tAor-21
06864 !Mav-l 8 aJun-23 X
40S534 lAuo-16 lAuo-21 2.8't3 | $113.052
509s61
'NoF20
tJun-23 1.151 352 21
lJun-16805136 lJul22 429 '|2.546 I $ 2.05S.638 X
40J931 lSeGl4 lMar-21
Cornmercial
Customers
hma I
Matthew
OutageDatelll
StadReqion
Docket No. 20200071-El
FPL's 2O20-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX E (Page 6 of 16)
X
iNou20800631lMetri 5 '1.8S4 174
lNoE22506666lDe..20 1.236 12 '1.535 I
172 5 722 237.938
107662 lDec'17 ,Jul-22
X
2.875 11
,10a262 lFebl g :Mav-21t-05\1 .352
101 3 2.035 i
300S62 lJul-18 ,Ao.-21
367.112
102232 lJun-2l ;Nov-21
350 454 X
102235 lJan-18 tJun-2l 1.S35
163 5 3.77 5 1 X
882.3433.700
':odl9702231 I Aua-22
702233 ;Jun-'lg alen-22 24 2
1.t1S 351 2
507 I 21.891
102531 lJul-l8 lAuo-21
X
102534 lSec20 :Seo-22 52
702731 lNov-1 8 lMau-22 1.1s8 21 1
1 483 1.603 I
702740 lNov-20 lNov-22 ff
31.8'17
:203931 lJun-20 lAuo-23
t00531 : Seo-19 :Seo-22
515 126 641
921 532 7 1.463 3.505
]11831 :Dec-20 I Nov-22
1.311 l 4.765
107237 lAuo-19 :Jun-2'1
117 898
:Jul-1 g lMat-22
506164 I NoF18 iNov-2'l L865 -_
?11
587
X
1 636 265 t.s04 962.314
:De.-20 :NoE22 1.583 12.010
X
808165 !oct-14 lJun-21
33035 :Mav-1 8 :Jun-23 1 .611 187 1.802
2j55!858.646
1
1.810 1 2.168$X
l[,,lav-19
'Se]21
'1'1 0
871.31 0
lOcllg202231 ISeo-22 1.610 I
(
201432 ,Seo-1 8 lJul-21 420 96 I
1 't 68 377.162$
s 744.611
t8333 : Nrar-1 5 1 Mav-21
i04061 :Now13 !Seo-20 2.111
5S7
2.344
04067 : Ocl-1 S 1 Auo-22 1 333 290 1 1.621
185 1.373
5 2.314 X
s 287 800 X
i0123S :SeG'18 iAuo-21
L'6Kffi--1 252 x
't.641 111 3
1.258 3
149 2.977
lNoF14706663 IAot-21
119
1.461 -
-.,_9 2
lrma /
Matthew
Outage
Cornmercial
Customers
Current
Estimated
Completion
Docket No. 20200071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-'1, APPENDIX E (Page 7 of 16)
IOAKES !2280 S LJS#rsl
X
:OAKLAND PARK :NE38St&5Browad
$ 908.283
$ 1.554.186700461 lJul-1g lJan-22 317 15
!1S301 NE 281hDadeIOJUS
lMar-'15 , Auo-22804932 80s 4 860 X
11741 :NoF1g lJtrl-22
,OLYI\/PIA HEIGHTS t9750 SW36rh rlade
!508 53d Ave WesIONECO
30 X
t01231 lNoF15 tJen-21 1.768 260 2 2.030 $ 126.504
t01234 lDeo20 llrar-23 113 1 486
13885 Counlv Road 16-Nodh IORANGEDALE
13885 Counlv Road 16-Nodh IORANGEDALE
507362 lNoF16 lAor-21 3.271 3 X
'625
24lh Ave NIORANGETREE
1228 N O(North IORMOND 101132 lJun-20 iNov-21 167 914
1228 N O(Nodh toRtvtoND 101 1 35 lJan-18 :Aor-21
IPAHOKEE 1660 s stale MerkeEast
2AO 8 383 2.911$X
f00433 :Nov-l8 lDeG21 1.680 {48 4 1.A32 x
100435 lNoFl s lSeG22 I 062
2.863
'PALM
AIRE
X
201635 lDeG21lSeo-18 2.338 117 2.153
4S 3 214
X
16625 W 22nd 1lade
'
PALIUETTO
lNoF1818861 lJan-23 X
505361 iJun-18 lJun-21 2.S91 291 1 3.28S
IDeG15 iNou20 179
110307 uS HtrlPARRISH
3.01 1
201134 lSerl8 aSeo-2'1 '1.166 61 1.235 X
l1 123 N Tamiami TiI PAYNE iDeG20;o2a32 : Nov-22 1 243
lPAYNE
X
702137 ,Ocl-15 lAuo-22 1.846 125 1.S73 81 1 946$X
AO1237 ,Od-17 tMer22
Erowaro iPEHRY ldu99 PemDroke tnffiifr- IiFFFV-Tii66ffifriiiir 2.311
503031 lNov-20 lNoE22 1.810 239 2.O51
i2050 Fie!IPHILLIPPI
X
70033'1 iJun-l8 EJul-22 1.S13 44 4 1 961 s 2 490 242
Broward IPINEHURST thn-)1700334lOcL14 ?a6
X
109962 lNoF17 lADt-21 1.600 260 3 1 863
i4900 W Broward BlvBrowardIPLANTATION 701633 lMav-18 ,Jtrl-22
404631 lDeG20 iMar-23 I $13.03{X
: llar-1 5701233 ,Jun-21 2 360 260
,PLAYLAND 14750 SW42nlroward
lpt A7a
408963 1DeG17 llun-22 2.113 715 1 3.1 5S s 3.428 843
:POLO 1240'l Lakewood Ranc
X
:PORT ORANGE I3000 Soruce CreekNodh
100836 loct2o tAun-22 1.068 242 2 1.312 $14.806 X
IPORT SEWALL :4250 SE Feder€East I lrav-1 I101932 lMev-22 1 015 1S1 2 1 204 s 1 641 235
IPORT SEWALL :4250 SE Federal H,East 104S34 lDec20 lNos22
X
lrma /
l1.1afthew
Outage
2020 ProjectRegion
Docket No. 20200071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX E (Page B of 16)
305231 lAua-18 Se12'1 1.118
12.216 X
55532 lNoE18 Mev-22 1.83S
268 993
X
502 5 2.924 t
324 1S31:
70S261 lNo$18 rn-21 741
X
501531 :NoF18 1.22'7
1 553 155 7 1.715
1.368 l
806835 lDec-20 Ivlatr23
56S.582 X
106533 lSeo-18 Jun-21
1 913 3 1.946
1.611 t 20.673
705867 lDec20
9.251
703431 1NoF18 1.680
X
207935 :Aun-1 I ot-21 655 125 780
211 1.510
I Feb-1 I407035
1.501.774 X
800537 :Jul-18
X
: oct-1 I701432 \uo-22 2.180
170 2.O20
517 5 1.S60 1 5,86S
t06331 lJul-16
al.231 X
t06335 lAuo-16
X
\ov-20 214 38
1.399 :
2.160 a 154.111
'038 iOcLl 5 Nov-20
2701 I s.332
108168 lDeG20 2,36€
X
505261 lDeG20 Auo-23
X
1.809 329
4 1.890 l
1 124 91.949$
lJun-'1 I701011
3.621.151
oct-21 1.009 219
X
NoE22 2.094
Seo-22 137 2 1.809
500132 lJun-18
796.723
3 1 237 $ 64 1.787
204133
'J6n-18
tul-21 1.596
s I 471 637 X
)an-22 67 1 68
t07 464 lNov-18
2.290
]03631 lOct-1 4
$ 3.404.1092 460
t761 lFeUlg
X
108534 :Aon15 Jtrn-21
X
4 69
1.006 116 1 1.123
371 3.521 X
:SeG15t06063
2 $10.750
iOcLl g708561 52
iJun-1 680s936 rl22 1.711 141
X
Jun-2f 115 3 *.*2ij9.
3 495
823 100 1 924
1 414 1.483 X
Project lrma /
Matthew
Outage
Docket No. 2O2O0071-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX E (Page I of 16)
5031 34 lDec-'15 tn-21 1.501 2AO 5 1786JS 225.370 X
503136 ! Nov-16 ow2l 1.032 1 1.213 | $s75.722
11001 Bav SiSORRENTO 2
2.241 , $10,f 11
:100'l BavSORRENTO
Nodh
129 7 1.31'1 I S 1.186.710 X
102437 :NoF18 ul22 1.062 202 8 1.272 t $398.387
503434 :DeG20 un-23 1 724 302 2028: $14 60S x
:9781 SWPr.SOUTHFORK 30s1 : $a2 249
1 X
705564
'DeG20
ov-22 1.895 2 2.060 ! $16 263
!8801 NW44rhSPRINGTREE
X
15831 Aimod RSPRUCE
X
107732 ,Jan-18 lec-21 L5A7 257 1 1 A45 , 5 1.261 241
107735 :Jun-18 17401$356 324
!onh
X
I Nowlg100236 3eo-22 1.084 309 I 1.402 ; S 211.81r X
13'l61 lAua-18 85 x
Brcward STIRLING
XSroward
Baoward
704763 lAuo-14 Jul-21 2.301 257 I 2.567 : S 33.857
qf wq|q
iJun-1 g704765
i6600 S FlaminooSTONEBRIDGE lDec17704747
Dade
2.864 I $348.034 X
lodh
,NTREE lJul-19201361 NoF21 56S 110
)ade t13655 NWSU/EETWATER t0s765 :Auo-l 8
1t-22 X
odh
Oct-21 1.069 '1.'t60 ! s 2.013.570 X
205S33 lJun-20 ou-21 s6 123 1_085 i $a41.921 X
IARTAN lN/O SR 804 on M 2 308
Nodh
836 'ls 855'$176.887 x
402134 lJul-18
:ast I3290 SE SoulhbenTESORO ,t-21
2.431 a S 2.138.76S X
501835 lOcLl 8 2743
15300 S tlnivenTIIMBERLAKE I Feb-1S705232
212 3 1.821 1 S 3.371.556 X
70523't lAuo-f6 Me!-21 1 929 175 2 2106!$93 245 X
\onh :917 TroDicTITUSVILLE
308 2.211 ) $ 1.011.579 X
aUS*f AND BeefeloTOLOMATO
Nov-21 668 172 6 846t$585.43S X
:S/O Saddle ClubTRACE
X
Sroward
785!S 277.134 X
1061 66 IMar-16 Uats21
Broward !4501 PoweT\A/lNLAKES
2561$95.1 85 X
IJ ul-f gs12382 qoF21 485 63S:$25 201
VALENCIA lOcLl s706262
^uo-22
2 907
X
Broward ,200VALENCIA
L580 '196 '1.777 : S 6.00S.S85 X
!oF21 387 3.S67 : $616.O77 x
lma /
Maflhew
Outage
2020 Project
cost
Total
Custolners
Docket No. 2O2O0O71-EI
FPL's 2020-2O29 Storm Protection Plan
Exhibit MJ-1 , APPENDIX E (Page 10 of 16)
X
lod-14 lMav-21 720 6 8l,563
lJun-21 '180
r337 INov-18 lNov-2 1
160 1.128
'
$ 2.754.368
700635 I oc!1 I lAuq-22 903
17s41s3.367.516
00540 I Ocl-i S ,Avo-22 75
x
229 2
1.{64 : $70.42771
878:S 268.558
31 1431 iJun-19 ,SeD-21
359: $ I ofS760 X
11433 lJun-1S :Seo-21 64
'138 lS 1 1 3.593
t00138 lSeo-20 ,Jul22
8781S
lJun-1S703933 iAor-21 888 tssgl$ 12.955 X
lDeG20703S37 lMar-23 983
X
211
:Ju1-18104034 lDec-21
667i$125.526
101131 iNow18 !Jun-22
iNoEl8500833 :DeG21 1.732
264 3
111
ISeo-17505465 lJun-23
12115 3S6.298
703237 lNoulS lJul22
3525 I $ 2.352.858
'DeG19
10s034 !seo-22
X
lMav-217364
'
Feb16 1.679 '100
214 3.255 : $ 1.516.027
Slan
Date{tr
lrma /
[.rlanh€w
Outaqe
Residenlial
Custorners
{s&si
(1) Staddate rcflecb eslimaled/actual datewhen inilial pqect costs wiil begln to accte (e,9,, preliminar engineeing/design, site Neparalions, customet outeach)
(2) completion date reflecb lhe estinated date when all prciect costs wiil be final
Docket No. 20200071-El
FPL'S 2O2O-2O29 Storm Protection Plan
Exhibit MJ-1, APPENDIX E (Page 11 of 16)
Appendlx E: FPL 2O2O Project Level Detail
Lateral Hardening (Undergrounding) - Distribution Program
103
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-_-999191"
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I
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1SI X
lnna / Maflhew
Outage
Current
Estimated
Docket No. 2O2O0071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX E (Page 12 of 16)
ls tTT-' - f*-
t1 : x
iegl! l!un-29 l *46
20
21 |e€1 2
31 I3eG20 3 34
5;tc-21 1
108 !\ct1 37
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23
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153 IMatt$I
t9
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015 I X
Cuilent
Estimated
Completion
Date{2)
Project lma / Manhew
Outage
lndustrial
Customers
Commercial
Customers
Docket No. 202O0O71-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX E (Page 13 of 16)
31;
1-)
1t
2bt
11(
18t
6(
ry
2
21 X
:IMPERIAL
1
16
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321-"T6
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n-20 lDec-21 25 X
iliami-Dade I87360slg30gE :Desidn & ourreach 1807731
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:ellthan llllnodo2nqlN lnFeidn & arilr.,.h llo8n61
t9 lJun-20
X
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lDeG21 11Fl9
lnna / Mathew
Outaqe
Rasidenlial
Customers
Current
Estimaled
Completion
Docket No. 2O200071-El
FPL's 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX E (Page 14 of 16)
f,n
lr!Cegt'-iDec-21 21 ieGlg 21
lDec-2i 15;15 i
iMatto 197 ,4luo-1S 201
51 I 9lI Dee2l 60
)v-19 10 t t!:D€G21 11
un-'19 30!!Auo-20 30
uo-lS It1 I 8i 11SiDec-21
'h-l9 55:lMar-?0 I 55
uo-1S 30 IlMar-20 I 30
4trn-20 lDec-21 13
38 I 2,tntO :Dec-21 40
54 I 1'rl-19 i SeD-20
37tinJSlMav-20 I 37
11 I 11uo-19 lDec-21 I
201un-10 lDer2i I 20
201ud-19 I DeG21 20
39iild-19 I Dc.-21
21 |uo-19 lDec-21 21
201rh-19 lDec-21 20
85 I 1tua-19 lllar-20 66
uFl9 I Dec-21 13 I 13
tDec21 35 I 9'lun-20 44
10 t 2\3b-20 JDec21 12
111:ab20 :De021 14
t4 IeL20lDeG21 14
12,:eL20 lDec-21 12
159 i 5!:20 I D€c-21 l 164
16l 1i-20 lDec-21 I 17
Fet}.2o iDec-21 :17!1tI
274F20lDe.rl I l 27
11 i 11JanAO:Dec-21 l l
lDe12'l 14Jan-20 i 14
lnec'l 18:1Po l8
!!9!-
-g!ges*
Auo-19 24 I:Oct-20 24
21 1 21
Auo-19 37t 2liMar-20
117 1 11/Jan-20 iDec-21
276 I 9iJunto1Dec21 285
i15 i 6i 121.?o :Dce-21
51 IJan-1S i Nov-20 51
36:2iI Nov-20 38
Region
Project
Completion
Date('r
lnna / Mathew
Outaqe
Current
Estamated
Docket No. 20200071-El
FPL's 202O-2029 Storm Protection Plan
Exhibit MJ-1 , APPENDIX E (Page 15 of 16)
rst
lroward SOUTHSIDE
Naples
Plantation
41'-"trft
11
S0utnwesI Kancnes$iiiffiaiF;;6;;-
S0utnwest Rancness;nfi;6in;;fr;;
\*
--x-*-
Southwest Ranchessiiffi;rffi;;6;*
Southwest Ranches
;ui6west R;rcfis3;;;ffi*-
-Ifi
X:*r
*'--*--n*----
aoe;a;-
,inecfest
,irwdG.6
*J
202-nT
537^*-m
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77
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. -3J1.,- 437,
261.
iami GardensiffFt;a;;;-
lrth
Prolect lma / Mafrhew
Outaqe
/Vots;
(1) Sta|l date reflecb stimatedlactual datewhen initial prcject cosls will begin lo accrue (e,9,, prelininary ehgineefng/d$igh, slte prpatalions, customet outeach)
(2) Completloh date feflects the $tihaled/actual date when all prcject cosb will be linal
Docket No. 2020007 1-El
FPL'S 2020-2029 Storm Protection Plan
Exhibit MJ-1, APPENDIX E (Page 16 of 16)
Appendix E: FPL 2020 Project Level Detail
Substation Storm Surge, Flood Mitigation Program
Total
Cust0mersRegion
P rojeclEslimated /
Staft Dateh)
/Volesi
(1) Stad date rfec's estimate.ttactual date when initlal prject costs wii begln lo accre (e,g., prliminar englneeing/deslgn, slte prepatatlons, customer outrach)
(2) complellon date rcflects lhe $timated dale when all prciect costs wiil be flnal