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ORDER NO. PSC-2020-0512-TRF-EI DOCKET NO. 20200170-EI PAGE 4 customers. Specifically, FPL stated that when comparing the average mileage efficiency of electric vehicles to gasoline-powered vehicles, the electricity price that equates to the same cost per mile is $0.31 per kWh. Furthermore, public fast charging prices in Florida offered by other providers, such as Tesla, EVgo, and Electrify America, average at $0.35 per kWh. However, FPL explained that the utility gave more consideration to the Tesla charging rate of $0.28 per kWh, because at the time the utility did the calculation, Tesla was the only EV provider charging on a per-kWh basis. EVgo and Electrify America offered per-minute charging rates and due to varying charging speeds may present a level of uncertainty when converting to a price per kWh.9 FPL asserts that the proposed $0.30 per kWh rate is reasonable compared to the equivalent cost per mile for gasoline-powered vehicles and the EV pricing options offered by non-utility providers. The proposed $0.30 per kWh rate is not cost-based. FPL stated that the utility currently does not have data regarding actual sales volumes and operating costs of utility-owned public charging stations and, therefore, developing cost-based rates would be conjectural at this time. To support the proposed "market-based" rates, FPL referred to a decision by the Washington Utilities and Transportation Commission, which approved a pilot tariff for fast charging rate that is comparable to rates being charged by other public charging facilities. Greenlots, the Edison Electric Institute, and Drive Electric in written comments support FPL's proposed UEV tariff. AEE filed comments in the docket on June 19, 2020. AEE explained that it represents a diverse set of businesses and supports the creation of beneficial EV-specific rates. However, AEE expressed concern that FPL's proposed rate of$0.30 per kWh is 15 percent lower than the average rate of$0.35 per kWh offered by non-utility providers, or third parties. AEE asserts that, based on a review of their members, there is "concern that the price differential could inadvertently create a tilted playing field that challenges third-party charging infrastructure development over time." Tesla filed comments on June 23, 2020. In its comments, Tesla suggests that the calculation of the FPL proposed rate should not include the price Tesla charges, or in the alternative the rate should be set on FPL's expected costs of providing charging services. As shown in Chart 1 on page 10 of FPL's petition, FPL included a Tesla charging rate of$0.28 per kWh in its calculation of the average charging rate of $0.35 per kWh offered by non-utility charging stations. Tesla asserts its business model for its charging network is "unique and not necessarily replicable by other charging operators." Electrify America, in its comments filed on August 14, 2020, advocated a shared- responsibility model for utility investment that can encourage third-party infrastructure development while limiting ratepayer risk. Electrify America states that it operates the nation's largest public fast charging network, including 110 chargers in Florida and several more projects currently under construction. Electrify America states that several jurisdictions have encouraged investment in public charging through the shared-responsibility model. Electrify America did not address the proposed$0.30 per kWh rate. 9 FPL stated that in October 2020,Electrify America announced a$0.43/kWh fast charging rate for Guest and Pass members and a$0.31/kWh rate for Pass+members.