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Direct Testimony of Natalie A. Mims and Karl R. Rabago on Behalf of Southern Alliance for Clean Energy before the Florida Public Service Commission

Valuation, Analysis, BCA   
Florida Public Service Commission Docket No. 130199-EI thru 130199-EI. This testimony presents the Commission with an evaluation of Florida Power and Lighting (“FPL”), Duke Energy Florida (“DEF”), Gulf Power Company (“GPC”) and TECO’s (collectively, the “Utilities”) Petition for Approval of Numeric Conservation Goals. Specifically, the testimony: 1. discusses why it is inappropriate and against precedent and legislative intent to use the Ratepayer Impact Measurement (“RIM”) test scores to set energy efficiency goals in Florida; 2. reviews the recommendations made in the recent review of the FEECA statute and discusses the findings; 3. discusses the Utilities historic program costs and show how they are inflated; 4. explains why a two-year payback screen is an flawed proxy for free-ridership and is not used in any other state; 5. discusses the flaws with the Utilities technical, economic, and achievable potential; 6. discusses FPL and DEF’s inadequate incorporation of energy efficiency into their resource plans; and 7. makes recommendations for policy and methodology improvements in Florida.