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ORDER NO. PSC -2018 -0050 -TRF -EI DOCKET NO. 20170148 -EI PAGE 3 In addition, FPL requests that this Commission determine that there are quantifiable benefits to the general body of ratepayers from the exclusion of the existing non -storm hardened facilities cost from the CIAC calculation for the underground conversions. This determination would allow FPL, pursuant to Rule 25-6.115(12), F.A.C., to treat these existing facilities costs as net plant in service costs that can be recovered from all customers, just as they would if FPL implemented overhead hardening of the subject feeder facilities. FPL's response to Commission staff's first data request states that the municipalities of Palm Beach, Longboat Key, Palm Beach Shores, Key Biscayne, Sunny Isles Beach, and Fort Lauderdale are currently in discussion with FPL regarding potential overhead to underground conversion projects. FPL estimated that under the current CIAC formula, these six municipalities would pay a total CIAC amount of approximately $64.6 million. Under FPL's proposed CIAC calculation that excludes the existing facilities cost, the estimated CIAC amount would be $50.4 million, for a total CIAC difference of $14.2 million. FPL listed in its petition four benefits of excluding the existing facilities cost from the calculation of CIAC for underground conversions of the existing non -hardened overhead facilities, that otherwise would be subject to hardening. First, FPL asserts that such underground conversions will not result in additional costs for the general body of ratepayers because the existing facilities cost would be borne by the general body of ratepayers as a result of FPL's storm hardening activities. Second, FPL asserts that underground distribution facilities tend to be even more storm resilient than hardened overhead facilities. Thus the underground conversion will reduce the need for storm restoration work in the converted area and make restoration crew resources available to help more quickly in other parts of FPL's service territory. Third, FPL states that reliability will improve, as underground facilities have historically provided better reliability than overhead facilities. Finally, the company asserts that excluding the existing facilities cost from the CIAC calculation will reduce the cost of conversion, thereby incentivizing such conversions. T)F('TCT0N We agree with FPL that as a result of its approved storm hardening plan for the remaining distribution feeders, the existing non -hardened facilities cost would have been incurred and borne by the general body of ratepayers under FPL's current base rates as approved in FPL's 2016 rate case settlement.4 The term of the rate case settlement is January 1, 2017 through December 31, 2020. FPL asserts that underground facilities tend to be more storm resilient and provide better overall day-to-day reliability when compared to overhead faculties. In response to a staff data request, FPL explained that in 2016, during Hurricane Matthew, only 2.2 percent of FPL's underground facilities experienced outages, while 9.4 percent of hardened overhead facilities experienced outages and 13.8 percent of non -hardened overhead facilities experienced outages.5 FPL also provided reliability data for the five reliability indices for the regions/management areas that had overhead to underground conversion projects. The data provided by FPL supports 4 Id. 5 Staff's First Data Request, response to Question 5 C 3