LTC 453-2021 CITY OF SOUTH MIAMI RESOLUTION NO. 130-21-15750MIAMI BEACH
OFFICE OF THE CITY CLERK
No. 453-2021
LETTER TO COMMISSION
TO : Mayor Dan Gelber and Members of the City Commission
FROM:
DATE:
Rafael E. Granado, City Clerk
October 26 , 2021
SUBJECT: CITY OF SOUTH MIAMI RESOLUTION NO. 130-21-15750
Attached for your information is Resolution No. 130-21-15750, adopted by the Mayor and City
Commission of City of South Miami on October 19, 202_1.
A RESOLUTION OF THE MAYOR AND CITY COMMISSIONERS OF THE CITY
OF SOUTH MIAMI, FLORIDA, URGING THE FLORIDA PUBLIC SERVICES
COMMISSION (PSC) TO REJECT FLORIDA POWER & LIGHT'S (FPL)
REQUEST TO INSTITUTION OF A $25 PER MONTH MINIMUM BILL AND TO
REJECT OR REDUCE THE AMOUNT OF THE RATE INCREASE THAT FPL IS
REQUESTING .
The City of South Miami Clerk has requested that a copy of this Resolution be provided to the
Miami Beach Mayor and Commissioners.
If you have any questions, please contact the Office of the City Clerk at 305 .673. 7 411.
REG/rg
Attachment
F:\CLER\$ALL\LILIA\L TC's -Transmittal's\South Miami\Resolution 130-21-15750 City of South Miami.docx
RESOLUTION NO. 130-21-15750
A Resolution of the Mayor and City Commissioners of the City of South Miami, Florida,
urging the Florida Public Services Commission (PSC) to reject Florida Power & Light's
(FPL) request to institution of a $25 per month minimum bill and to reject or reduce
the amount of the rate increase that FPL is requesting.
WHEREAS, on March 12, 2021, Florida Power & Light Company ("FPL") filed a Petition
for Base Rate Increase and Rate Unification with the Florida Public Service Commission (PSC)1;
and
WHEREAS, on August 10, 2021, FPL, Citizens through the Office of Public Counsel,
Florida Retail Federation, Florida Industrial Power Users Group, and Southern Alliance for Clean
Energy filed a Joint Motion for Approval of Settlement Agreement 2 for four years of pre-
approved rate increases totaling $1.53 billion 3; and
WHEREAS, if approved, it will be the largest utility rate increase in Florida history and
FPL customers can expect to see their energy bill increase by more than $200 per year4; and
WHEREAS, the timing of increased bills couldn't come at a worse time for many
Floridians who are coming out of the financial strains of the COVID-19 pandemic; and
WHEREAS, according to a study by SaveOnEnergy, Florida has the 14th highest average
monthly bill out of the 50 states in the U.S. at $131.74, which is higher than the $123.29
monthly average for the United States5; and
WHEREAS, in addition to the rate increase, FPL is proposing a $25 per month minimum
bill -meaning that a customer's monthly utility bill won't ever be lower than the minimum,
even if the property has solar and uses only a small amount, or none, of electricity from the
utility; and
WHEREAS, minimum bills unfairly target low energy users, such as part-time residents,
residents trying to age in place and, most importantly, solar customers who have made large
home improvement investments to cut their use of electricity that is generated by fossil fuels;
and
https://www.fpl.com/ content/ da m/fpl/us/ en/ rates/ pdf /01 %20FP L %20Petition%20for%20Base%20Rate%201 ncrea
se%20and%20Rate%20Unification%20-%2020210015-El.pdf
2 http://www.floridapsc.com/library/filings/2021/09057-2021/09057-202l.pdf
3 https://states.aa rp.org/flori da/fpl-customers-help-us-fight-for-lower-power-bi 11s
4 https://www.solarunitedneighbors.org/news/florida-utilities-add-new-charge-to-make-solar-less-profitable/
5 https://www.saveonenergy.com/learn ing-center /post/ electricity-bills-by-state/
Page 1 of 3
Res. No. 130-21-15750
WHEREAS, with the looming climate change crisis, people should be encouraged to use
less energy and covert to renewable energy such as solar panels, yet FPL's proposals will have
the opposite effect; and
WHEREAS, the proposal to charge a flat base fee runs counter to the Legislature's fight
against climate change which is to encouraged the development of solar energy in both
residential and commercial settings; and
WHEREAS, the FPL's proposed rate increase and minimum bill prov1s1on will only
increase financial burdens on many Floridians while making it harder for people to help fight
climate change by going solar; and
WHEREAS, the FPL's proposed will stifle the growth of the solar industry and it will make
the fight against climate change even more difficult to solve; and
WHEREAS, the Mayor and City Commission is in opposition to FPL's Petition for Base
Rate Increase and Rate Unification and the Joint Motion for Approval of Settlement Agreement
and any measures that discourages people from investing in solar energy.
NOW THEREFORE, BE IT RESOLVED BY THE MAYOR AND CITY COMMISSIONERS OF THE
CITY OF SOUTH MIAMI, FLORIDA:
Section 1. The foregoing recitals are hereby ratified and confirmed as being true and
correct and are hereby made a specific part of this resolution upon adoption hereof.
Section 2. The Mayor and City Commission of the City of South Miami hereby urge the
Florida Public Services Commission to reject Florida Power & Light's request to institute a $25
per month minimum charge and to reject or reduce Florida Power & Light's request to increase
rates.
Section 3: The City Clerk shall forward a copy of this Resolution to
Members of the Florida Public Service Commission;
Clerk of the Florida Public Service Commission;
Electronically file this resolution with the Clerk of the Florida Public Service
Commission
all municipalities in Miami-Dade County;
the members of the governing bodies of all 67 counties and their respective league of
cities;
the Florida League of Cities;
Miami-Dade County League of Cities; and
Miami-Dade County Board of County Commissioners
Page 2 of 3
Res. No. 130-21-15750
Section 4. Corrections. Conforming language or technical scrivener-type corrections
may be made by the City Attorney for any conforming amendments to be incorporated into the
final resolution for signature.
Section 5. Severability. If any section clause, sentence, or phrase of this resolution is for
any reason held invalid or unconstitutional by a court of competent jurisdiction, the holding will
not affect the validity of the remaining portions of this resolution.
Section 6. Effective Date. This resolution will become effective immediately upon
adoption.
PASSED AND ADOPTED this 19 th day of October, 2021.
ATTEST:
CITYC~
READ AND APPROVED AS TO FORM, COMMISSION VOTE:
Mayor Philips:
Commissioner Harris:
4.-1
Yea
Yea
Commissioner Gil: Yea
Commissioner Liebman: Nay
Commissioner Corey: Yea
Page 3 of 3
City Commission Agenda Item Report
Meeting Date : October 19 , 2021
Submitted by : Thomas Pepe
Submitting Department: City Attorney
Item Type: Resolution
Agenda Section :
Subject:
Agenda Item No :7 .
A Resolution of the Mayor and City Commissioners of the City of South Miami , Florida , urging the Florida Public
Services Commission (PSC) to reject Florida Power & Light's (FPL) request to institution of a $25 per month
minimum bill and to reject or reduce the amount of the rate increase that FPL is requesting. 3/5 (Mayor Philips)
Suggested Action:
Attachments:
Reso_re_FPL_Proposed_Rate_lncrease_Min_Bill_2021_.doc
Larson's Oppostion to 2021 rate increase .pdf
1
FILED 10/11/2021
DOCUMENT NO.12061-2021
FPSC -COMMISSION CLERK
BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
In re: Petition for rate increase by Florida
Power & Light Company.
DOCKET NO.: 20210015-EI
FILED: October 11, 2021
LARSON POST-HEARING STATEMENT OF POSITIONS
AND POST-HEARING BRIEF FOR SETTLEMENT CASE
Pursuant to Florida Public Service Commission ("FPSC" or "Commission") Order No.
PSC-2021-0116-PCO-EI, issued on March 24, 2021, as modified by Order Nos. PSC-2021-
0120-PCO-EI, PSC-2021-0120A-PCO-El, PSC-2021-0233-PCO-El, PSC-2021-0314-PCO-El,
and PSC-2021-0362-PHO-EI issued on April 1, April 8, June 28, August 20, and September 16,
2021 respectively, Mr. Daniel R. Larson and Mrs. Alexandria Larson ("Larsons"), by and though
undersigned counsel, hereby file their Post-Hearing Statement of Positions and Post-Hearing
Brief for the Settlement Case in the above captioned docket. In support thereof, the Larsons state
as follows:
SUMMARY OF ARGUMENT
The Commission should deny the Joint Motion for Approval of Settlement Agreement
("Joint Motion") filed by Florida Power & Light Company ("FPL), the Office of Public Counsel
("OPC"), the Florida Industrial Power Users Group ("FIPUG"), the Florida Retail Federation
("FRF"), and the Southern Alliance for Clean Energy ("SACE") on August 10, 2021, because the
proposed settlement is not in the public interest. Specifically, the Larsons oppose the Joint
Motion because:
( 1) The proposed settlement is not in the public interest;
(2) The proposed settlement will result in rates during the settlement period that are unfair,
unjust, and unreasonable;
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LARSON POST-HEARING BRIEF (SETTLEMENT CASE)
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(3) The proposed settlement unjustly subsidizes commercial customers at the expense of
residential customers;
(4) The Return on Equity ("ROE") under the proposed settlement is excessive and unjustified
in comparison to the recent settlements in the Duke and TECO electric rate cases;
(5) The additional ROE adjustment based upon the expected treasury interest rate increases
represent an another excessive and unjustified giveaway to FPL at the expense of FPL customers
who are forced to fuel corporate profits;
(6) The proposed settlement will result in rates which produce revenues that are far in excess
of what FPL requires to provide safe and reliable service and remain financially health during the
settlement period;
(7) The proposed settlement will result in intergenerational inequities and excessive rates
immediately following the settlement period as a result of depleting surplus depreciation funds to
maintain FPL earnings levels far in excess of what is required to maintain a fair and reasonable
Return on Equity ("ROE") in comparison to other Florida Investor Owned Utilities ("IOUs");
and
(8) The proposed settlement represents the largest, unjustified, electric rate increase and rate
case settlement in Florida's history.
The Larsons note for record that the positions taken by OPC within their prehearing
statement in July 2021 (specifically that the FPL request to increase rates was not justified, that
the FPL ROE request was excessive and unjustified, and that the Commission lacked the
authority to approve the mechanisms contained within the FPL rate request) completely
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LARSON POST-HEARING BRIEF (SETTLEMENT CASE)
DOCKET NO. 20210015-EI
PAGE3
contradict the egregious terms of the settlement to which OPC (Richard Gentry) acquiesced as a
signatory to the Joint Motion prior to the scheduled rate case hearing.
The Larsons believe that it is important to recognize that the prior Public Counsel (who
served the state admirably for 14 years) was conveniently forced out by the Florida Legislature
prior to the filing of the FPL rate case. In simple terms, a seasoned professional with 14 years of
experience in protecting the interests of Florida ratepayers was inexplicably replaced by a
lobbyist. Accordingly, the Larsons believe that newly minted Public Counsel (Richard Gentry)
effectively sold out FPL customers and has lost all credibility by agreeing to an egregious
settlement that completely contradicts the positions taken in its prehearing statement
In a famous "indecency" case, Supreme Court Justice Porter Stewart stated, "I know it
when I see it". Likewise, in the context of this proceeding, the Commission should equally know
an excessive and egregious settlement that is not in the public interest when they see it.
Approval of the proposed settlement (if left unmodified) represents the largest electric rate
increase in Florida's history and the largest electric rate case settlement in Florida's history.
Furthermore FPL, and the other signatories to the Joint Motion, failed to consult with the
Larsons prior to filing the Joint Motion required by Rule 28-106.204(3), Florida Administrative
Code. Despite expressly stating their desire and willingness to participate in any FPL settlement
discussions relating to the above captioned docket, the Larsons were not afforded the opportunity
to participate in the settlement discussions that led to the filing of the Joint Motion. Consistent
with the Alternative Dispute Resolution ("ADR") process encouraged by the Florida Public
Service Commission ("Commission" or "FPSC"), the Larsons believe that all parties to a
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LARSON POST-HEARING BRIEF (SETTLEMENT CASE)
DOCKET NO. 20210015-EI
PAGE4
contested docket should have been afforded the meaningful opportunity to participate in
settlement discussions in a good faith effort to reach a stipulated settlement agreement that could
be supported by all of the parties in a heavily contested docket.
Based upon the above, the Larsons believe that the proposed settlement (in its current
form) contained within the Joint Motion is not in the public interest and should be appropriately
denied by the Commission, or alternatively modified by the Commission such that the proposed
settlement is fair, just, and reasonable to FPL residential customers.
ISSUE 1:
ISSUES AND POSITIONS
Does the Commission have the statutory authority to grant FPL 's requested
storm cost recovery mechanism as part of the Stipulation and Settlement
Agreement?
*No. The Commission lacks the statutory authority to pre-approve a rate increase as a result of
the storm cost recovery mechanism requested by FPL.*
ARGUMENT
The Commission lacks the statutory authority to pre-approve a rate increase as a result of
the storm cost recovery mechanism requested by FPL.
ISSUE 2: Does the Commission have the statutory authority to approve FPL's
requested Reserve Surplus Amortization Mechanism (RSAM) as part of the
Stipulation and Settlement Agreement?
*No. The proposed settlement will result in intergenerational inequities and excessive rates
immediately following the settlement period as a result of depleting surplus depreciation funds to
maintain FPL earnings levels far in excess of what is required to maintain a fair and reasonable
There is no statutory basis for the Commission to include the accrued depreciation for
ratemaking purposes.*
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ARGUMENT
The Commission does not have the ability to establish non-cost-based rates. Recording
debits or credits to accumulated depreciation reserve unrelated to recording depreciation to
achieve a certain ROE is contrary to the definition of the Account I 08. Previous U .S. Supreme
Court rulings have found that the accumulated depreciation reserve "represent the consumption
of capital, on a cost basis" and cautions against using depreciation "to the extent, subscribers for
the telephone service are required to provide, in effect, capital contributions, not to make good
losses incurred by the utility in service rendered, and thus to keep its investment unimpaired, but
to secure additional plant and equipment upon which the utility experts a return. See, Lindheimer
v. Illinois Bell Tel. Co., 292 US 151 (1934) pp. 168-169. Furthermore, this concept is also
codified in Florida Statutes, Sections 366.06, Fla. Stat., which provides that after the
Commission has investigated and determined "the actual legitimate costs of the property of each
utility company, actually used and useful in the public service," only the net investment of the
honestly and prudently invested actual legitimate costs used and useful, less the accrued
depreciation, shall be used for ratemaking purposes . There is no statutory basis for the
Commission to include the accrued depreciation for ratemaking purposes. Allowing the RSAM
would effectively impact the amount of money FPL is allowed to keep from the established rates
during the 4-year term -thus, would be used for ratemaking purposes . Additionally, it would
require any of the RSAM amount used from the accrued depreciation would have to be
recollected from future customers. Therefore, using the excess accumulated depreciation a
manner that allows them to keep the excess contribution of accumulated depreciation to increase
profits allowed by rates is contrary to Supreme Court case law and Florida Statutes.
9
ISSUE 3:
LARSON POST-HEARING BRIEF (SETTLEMENT CASE)
DOCKET NO. 20210015-EI
PAGE6
Does the Commission have the statutory authority to approve FPL's
requested Solar Base Rate Adjustment mechanism for 2024 and 2025 as part
of the Stipulation and Settlement Agreement?
*No. The FPL Solar Base Rate Adjustment proposal circumvents the required showing that FPL
is earning outside the range of reasonableness, thus cannot be approved by the Commission.*
ARGUMENT
While the Commission "may adopt rules for the determination of rates in a full revenue
requirement proceeding which rules provide for adjustments of rates based on revenues and costs
during the period new rates are to be in effect and for incremental adjustments in rates for
subsequent periods," the Commission has no such rules. See, Section 366.076, Fla. Stat..
Moreover, Section 366.071, Fla. Stat., the interim statute section, only provides for interim rates
based on a showing that utility is earning outside its range of reasonableness. Thus, the
Commission can grant an interim rate increase only after a showing that the Company is earning
outside the range of reasonableness. The FPL Solar Base Rate Adjustment proposal would not
require the necessary demonstration that they are earning outside the range of reasonableness,
thus cannot be approved.
ISSUE 4: Does the Commission have the statutory authority to adjust FPL's
authorized return on equity based on FPL's performance as part of the
Stipulation and Settlement Agreement?
*No. There is no statutory basis for the Commission to adjust the authorized return on equity for
performance except under Section 366 .82(9), Fla. Stat. which provides that the Commission is
only authorized to allow an investor-owned electric utility an additional return on equity of up to
50 basis points for exceeding 20 percent of their annual load-growth through energy efficiency
and conservation measures.
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ARGUMENT
Sections 366.06 and 366.07, Fla. Stat., provide for rate changes only "after public
hearing" where the Commission has investigated and determine "the actual legitimate costs ... "
and finds that rates are insufficient that then the Commission "by order" can "fix the fair and
reasonable rates." There is no statutory basis for the Commission to adjust the authorized return
on equity for performance except under Section 366.82(9), F.S . Section 366.82(9), F.S., provides
that the Commission is authorized to allow an investor-owned electric utility an additional return
on equity of up to 50 basis points for exceeding 20 percent of their annual load-growth through
energy efficiency and conservation measures.
ISSUE 5: Does the Commission have the statutory authority to include non-electric
transactions in an asset optimization incentive mechanism as part of the
Stipulation and Settlement Agreement?
*No . Pursuant to Section 366 .05(2), Fla. Stat., the Commission lacks the statutory authority to
include non-electric transactions within any incentive mechanism for rated being charged.*
ARGUMENT
Under Section 366.05(2), Fla. Stat., "Every public utility, ... , which in addition to the
production, transmission, delivery or furnishing of heat, light, or power also sells appliances or
other merchandise shall keep separate and individual accounts for the sale and profit deriving
from such sales. No profit or loss shall be taken into consideration by the commission from the
sale of such items in arriving at any rate to be charged for service by any public utility."
ISSUE 5(a): Does the Commission have the authority to approve FPL's requested
proposal for a federal corporate income tax adjustment that addresses a
change in tax if any occurs during or after the pendency of this proceeding as
part of the Stipulation and Settlement Agreement?
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LARSON POST-HEARING BRIEF (SETTLEMENT CASE)
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PAGE8
*No. FPL's request for a tax adjustment for a speculative future tax change is premature and thus
prohibited based on the Commission's decision in Order No. PSC-2017-0099-PHO-EI. Should
federal tax changes occur in the future, the issue should be addressed at the appropriate time in a
separate proceeding by the Commission .*
ARGUMENT
No. FPL's request for a tax adjustment for a speculative future tax change is premature
and thus prohibited based on the Commission's decision in Order No . PSC-2017-0099-PHO-EI
as the Commission ruled in identical circumstances in 2017 when speculation was rampant about
possible statutory tax rate changes in the absence of passed legislation . As the Commission
stated then, and as it stands now, the issue is premature and not ripe for consideration at this
time. Should federal tax changes occur in the future, the issue should be addressed at the
appropriate time in a separate proceeding .
ISSUE 6: Does the Commission have the statutory authority to grant FPL's requested
four year plan as part of the Stipulation and Settlement Agreement?
*No . The Commission cannot waive its own statutory obligations to hold a public hearing to
determine just and reasonable rates upon receipt of a legally sufficient request to review the rates
being charged.*
ARGUMENT
Under Section 366 .06(2), Fla. Stat., if the Commission finds, upon its own motion or
request made by another, that such rates are insufficient to yield reasonable compensation for the
services rendered, or that such rates yield excessive compensation for services rendered, the
Commission shall order and hold a public hearing to determine the just and reasonable rates to be
charged. The Commission cannot waive its own statutory obligations to hold a public hearing to
determine just and reasonable rates upon receipt of a legally sufficient request to review the rates
being charged.
12
ISSUE 9:
LARSON POST-HEARING BRIEF (SETTLEMENT CASE)
DOCKET NO. 20210015-EI
PAGE9
Has Floridians Against Increased Rates, Inc. demonstrated individual and/or
associational standing to intervene in this proceeding?
*The Larsons take no position on this issue.*
ARGUMENT
Not Applicable.
ISSUE A: Should the Stipulation and Settlement Agreement dated August 9, 2021, be
approved?
*No. The Commission should deny the Joint Motion for approval of the proposed settlement
because the proposed settlement agreement is not in the public interest. Alternatively, the
Commission should modify the proposed settlement to ensure that the electric rates being
charged are fair, just, and reasonable to FPL residential customers.*
ARGUMENT
The Commission should deny the Joint Motion for approval of the proposed settlement
because the proposed settlement agreement is not in the public interest. Alternatively, the
Commission should modify the proposed settlement to ensure that the electric rates being
charged are fair, just, and reasonable to FPL residential customers. The Commission has the
ability to reject and modify a proposed settlement agreement as discussed within the Decision
section of Commission Order No. PSC-13-0023-S-EI (Exhibit 62 I). Specifically, the Larsons
oppose the proposed Stipulation and Settlement Agreement because:
(I) The proposed settlement is not in the public interest;
(2) The proposed settlement will result in rates during the settlement period that are unfair,
unjust, and unreasonable;
(3) The proposed settlement unjustly subsidizes commercial customers at the expense of
residential customers;
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LARSON POST-HEARING BRIEF (SETTLEMENT CASE)
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PAGE 10
(4) The Return on Equity ("ROE") under the proposed settlement is excessive and unjustified
in comparison to the recent settlements in the Duke and TECO electric rate cases;
(5) The additional ROE adjustment based upon the expected treasury interest rate increases
represent an another excessive and unjustified giveaway to FPL at the expense of FPL customers
who are forced to fuel corporate profits;
(6) The proposed settlement will result in rates which produce revenues that are far in excess
of what FPL requires to provide safe and reliable service and remain financially health during the
settlement period;
(7) The proposed settlement will result in intergenerational inequities and excessive rates
immediately following the settlement period as a result of depleting surplus depreciation funds to
maintain FPL earnings levels far in excess of what is required to maintain a fair and reasonable
Return on Equity ("ROE") in comparison to other Florida Investor Owned Utilities ("IOUs");
and
(8) The proposed settlement represents the largest, unjustified, electric rate increase and rate
case settlement in Florida's history.
The Larsons note for record that the positions taken by OPC within their prehearing
statement in July 202 l (specifically that the FPL request to increase rates was not justified, that
the FPL ROE request was excessive and unjustified, and that the Commission lacked the
authority to approve the mechanisms contained within the FPL rate request) completely
contradict the egregious terms of the settlement to which OPC (Richard Gentry) acquiesced as a
signatory to the Joint Motion prior to the scheduled rate case hearing. Simply put, the Larsons
believe that OPC (Richard Gentry) sold out FPL customers and has lost all credibility by
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LARSON POST-HEARING BRIEF (SETTLEMENT CASE)
DOCKET NO. 20210015-EI
PAGE 11
agreeing to an egregious settlement that completely contradicts the positions taken by OPC in
their prehearing statement.
Furthermore, the ROE under the proposed settlement is excessive, well in excess of what
OPC claimed it should be, and well in excess of the ROE set forth under the recent Duke and
TECO settlements. Based upon its strong balance sheet and high equity ratio, FPL should be
perceived as having lower market risk to investors compared to other Florida electric utilities
resulting in an lower ROE requirement and W ACC .1 Likewise, RSAM does not constitute cost-
based ratemaking if approved by the Commission. The egregiousness of the proposed settlement
is clearly evidenced by the fact that proposed ROE, ROE adjustment mechanism , and RSAM
represent a windfall giveaway to FPL that is well in excess of what FPL requires to provide safe
and reliable service and remain financially health during the settlement period.
Accordingly , the Commission should deny the Joint Motion for approval of the proposed
settlement because the proposed settlement agreement is not in the public interest. Alternatively,
the Commission should modify the proposed settlement to ensure that the electric rates being
charged are fair, just, and reasonable to FPL residential customers. The Commission should not
approve an egregious settlement unjustly subsidizes FPL commercial customers at the expense of
FPL residential customers. The Commission has the ability to reject and modify a proposed
settlement agreement as discussed within the Decision section of Commission Order No. PSC-
13-0023-S-EI (Exhibit 621 ).
1 Beta is approximately 0 .7 for NEE common stock.
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LARSON POST-HEARING BRIEF (SETTLEMENT CASE)
DOCKET NO. 20210015-EI
PAGE 12
WHEREFORE, the Larsons respectfully request that the Commission deny the Joint
Motion for approval of the proposed settlement because the proposed settlement agreement is not
in the public interest. Alternatively, the Larsons respectfully request that the Commission
modify the proposed settlement to ensure that the electric rates being charged are fair, just, and
reasonable to FPL residential customers.
Respectfully submitted this 11 th day of October 2021.
Isl Nathan A. Skop
Nathan A. Skop, Esq.
Florida Bar No. 36540
420 NW 50 th Blvd.
Gainesville, FL 32607
Phone: (561) 222-7455
E-mail: n_skop@hotmail.com
Attorney for the Larsons
16
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been filed with
the Commission Clerk and furnished to the parties of record indicated below via electronic mail
on October 11, 2021 :
Florida Power & Light Company
Mr. Ken Hoffman
215 South Monroe Street, Suite 810
Tallahassee, FL 32301-1858
Phone: (850) 521-3900
Fax: (850) 521 -3939
E-mail: ken .hoffman@fpl.com
Florida Power & Light Company
Wade Litchfield/I. Bumett//M. Moncada
700 Universe Boulevard
Juno Beach, FL 33408-0420
Phone: (561) 691-2512
Fax: (561) 691-7135
E-mail: wade.litchfield@fpl.com
E-mail : john.l.bumett@fpl.com
E-mail: maria.moncada@fpl.com
Gulf Power Company
Russell A. Badders
One Energy Place
Pensacola, FL 32520-0100
Phone: (850) 444-6550 .
Email: russell . badders@nextcraenergy.com
Isl Nathan A. Skop
Nathan A. Skop, Esq.
Florida Bar No . 36540
420 NW 50th Blvd.
Gainesville, FL 32607
Phone: ( 561) 222-7455
E-mail: n_skop@hotmail.com
Attorney for the Larsons
Office of Public Counsel
R. Gentry/C. Rehwinkel/P . Christensen/A . Pirrello
c/o The Florida Legislature
111 W. Madison Street, Room 812
Tallahassee, FL 32399-1400
Phone: (850) 488-9330
E-mail: gentry .richard@leg.state.fl.us
E-mail: rehwinkel.charles@leg.state.tl.us
E-mail: christensen.patty@leg.state.tl.us
E-mail: pirrello.anastacia@leg.state.tl .us
Florida Public Service Commission
Office of the General Counsel
Keith Hetrick/Suzanne Brownless
2540 Shumard Oak Boulevard
Tallahassee, FL 32399
Phone: (850) 413-6 l 99
E-mail: khetrick@psc .state.tl.us
E-mail: sbrownle@psc.state.fl.us
Florida Industrial Power Users Group
Jon C. Moyle, Jr./ Karen A. Putnal
Moyle Law Firm, PA
118 North Gadsden Street
Tallahassee, FL 32301
Phone : (850) 681-3828
Fax: (850) 681-8788
Email: jmoyle@moylelaw.com
E-mail: kputnal@moylelaw.com
17
Florida Internet and Television Association, Inc. William C. Gamer
Floyd R . Self Law Office of William C. Gamer, PLLC
Berger Singerman, LLP 3425 Bannerman Road, Unit 105, #414
313 N . Monroe St., Suite 301 Tallahassee, FL 32312
Tallahassee, FL 32301 E-mail : bgamer@weglawoffice .com
E-mail : fself@bergersingerman .com
On behalf of: The Cleo Institute, Inc.
T. Scott Thompson
Mintz, Levin ,Cohn , Fenis, Glovshy and Popeo, P.C.
701 Pennsylvania Ave. "NW Suite 900
Washington, D .C. 20004
E-mail : sthompson@mintz.com
Earthjustice Federal Executive Agencies
Bradley Marshall/Jordan Luebkemann T. Jernigan/Maj . H. Buchanan/Capt. R. FriedmanffSgt.
Christina Reichert A . Braxton/E. Payton
111 S. Martin Luther King Jr. Blvd. 139 Barnes Drive, Suite 1
Tallahassee FL 32301 Tyndall AFB FL 32403
Phone: (850) 681-0031 Phone:(850)283-6663
Phone: ( 850) 681-0020 E-mail: ebony.payton.ctr@us .af.mil
E-mail: bmarshall@earthjustice.org E-mail: thomas.jernigan .3@us.af.mi1
E-mail: jluebkemann@earthjustice.org E-mail : ulfsc.tyndall@us.af.mil
E-mail: creichert@eanhjustice .org E-mail: holly.buchanan. l@us .af.mil
E-mail: flcaseupdates@earthjustice .org E-mail: robert.friedman.5@us.af.mi1
E-mail : arnold .brax1on@us.af.mil
On behalf of: Florida Rising, Inc ., League of Latin
American Citizens of Florida, Environmental
Confederation of Southwest Florida, Inc .
Walmart Florida Retail Federation
Stephanie Eaton/Barry Naum 227 South Adams St.
Spilman Thomas & Battle, PLLC Tallahassee FL 32301
110 Oakwood Drive , Suite 500 Phone: (850) 222-4082
Winston-Salem, NC 27103 Phonc:(850)226-4082
E-mail: seaton@spilmanlaw.eom
E-mail: bnaum@spilmanlaw.com Represented By: Stone Law Firm
Gardner Law Firm George Cavros
Robert Scheffel Wright/John T . La Via, III 120 E. Oakland Park Blvd ., Suite 105
1300 Thomaswood Drive Fort Lauderdale FL 33334
Tallahassee FL 32308 Phone : (954) 295-5714
Phone: (850) 385-0070 E-mail: george@cavros-law.com
Phone: (850) 385-5416
E-mail : schef@gbwlegal.com On behalf of: Southern Alliance for Clean Energy
E-mail: jlavia@gbwlcgal.com
On behalf of: Floridians Against Increased Rates , Inc .
Smart Thermostat Coalition Vote Solar
Madeline Fleisher/Jonathan Secrest Katie Chiles Ottenweller
Dickinson Wright PLLC 838 Barton Woods Rd NE
150 E. Gay St. Suite 2400 Atlanta GA 30307
Columbus, OH 43215 Phone : (706) 224-8017
E-mail: mfleisher@dickinsonwright.com E-mail : katie@votesolar.org
E-mail : jsecrest@dickinsonwright.com
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Stone Law Firm
James Brew/Laura Baker/Joseph Briscar ·
I 025 Thomas Jefferson St., NW, Ste. 800 West
Washington DC 20007
Phone: (202) 342-0800
Phone: (202) 342-0807
E-mail: jbrew@smxblaw.com
E-mail: lwb@smxblaw.com
E-mail : jrb@smxblaw.com
On behalf of: Florida Retail Federation
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