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ORDER NO. PSC-2020-0508-TRF-EI <br /> DOCKET NO. 20200209-EI <br /> PAGE 5 <br /> based on an anticipated 30-year life. Use of accelerated depreciation is appropriate in instances <br /> where an asset has become obsolete or not cost-effective to maintain. However, obsolescence is <br /> not the reason for accelerating the depreciation in this case insofar as these assets would not be <br /> retired early but are expected to be in service, on average, an additional 17 years after program <br /> termination.12 <br /> We considered two reasons why it may be appropriate for these assets to be depreciated <br /> on an accelerated basis as proposed by FPL. First, accelerated depreciation would reduce the <br /> likelihood of non-participant rate impacts during this program extension if FPL's participant <br /> attrition rates are reasonably accurate. The total participant contributions associated with the <br /> program over its 11 year period (2014-2025), based on the $9 monthly charge and FPL's <br /> anticipated customer attrition rates of 2-3 percent per month, are sufficient to allow the recovery <br /> of all program costs incurred over the period from the program participants, including full <br /> recovery of the SolarNow assets. Achieving full recovery of the SolarNow assets prior to the <br /> program's conclusion protects the general body of ratepayers by removing any future <br /> depreciation expense and return on rate base that could potentially be transferred to them. <br /> Second, the primary purposes of the assets placed in service for the SolarNow pilot program are <br /> expected to be realized by the end of the program in 2025. Those purposes include offering <br /> FPL's customers an opportunity to contribute to new solar photovoltaic generation facilities and <br /> to promote customer education and solar awareness objectives as the solar market developed. <br /> FPL's recently approved SolarTogether program provides customers with an opportunity to <br /> contribute to solar development. <br /> FPL provided a calculation of the depreciation expense at current rates and the proposed <br /> accelerated rates.13 Those calculations reflect an annual increase in depreciation expense of <br /> $3,960,140 for the final five years of the program.14 The utility also provided a calculation <br /> showing that the increased revenue requirement, due to the accelerated depreciation, would <br /> exceed the customer contributions and system savings for the remaining years of the program.ls <br /> However, according to FPL, the program produced a surplus of revenue from previous years. <br /> This surplus would largely offset the revenue shortfall through the end of the program, if the <br /> utility's participant attrition rates are accurate. <br /> We find that FPL's forecast of the SolarNow expenses through 2025 have a relatively <br /> high degree of certainty,while the forecast of program revenues based on customer contributions <br /> is much less certain. In its petition, the utility projects a participant attrition rate of 2-3 percent <br /> per month over the final five years of the program. This attrition rate could be partially offset by • <br /> new participants joining the program. However, if the utility's planned cessation of new solar <br /> construction for purposes of this program or any other factors cause that attrition rate to be <br /> higher than anticipated, the utility's projected revenue surplus at the conclusion of the program <br /> may not materialize and may in fact result in a revenue shortfall. We agree with FPL that it is <br /> 12 Document No. 11292-2020. <br /> 13 Id. <br /> 14 Increase in depreciation expense for 2021 equals $4,843,915 - $883,775 and for 2022-2025 equals $4,834,459 - <br /> $874,319. <br /> 'Document No. 11292-2020. <br />