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ORDER NO. PSC-2020-0512-TRF-EI DOCKET NO. 20200170-EI PAGE 7 as a low load factor customer. Charging stations with higher kWh sales, i.e., high load factor customers are able to spread the billed demand cost over more energy sales and are, therefore, more likely to recover their costs. FPL asserts that the demand charge included in standard demand rate schedules creates a barrier to entry during the early years of the EV market. FPL further states that fast charging providers and potential public charging site hosts have expressed concerns over their ability to recover costs in the early years of the EV market adoption. To address the challenges FPL identified for public fast charging stations, the utility proposed tariffs that include a demand limiter mechanism. Under the tariffs, the amount of demand billed to the customer would be the lesser of the measured demand or the limited demand as calculated by dividing the kWh sales by a fixed constant of 75 hours. Mathematically, applying the 75 hours constant to the kWh sales results in a reduction in the demand billed to a customer with a load factor of less than ten percent. Customers with a load factor above ten percent would pay the standard demand charges contained in the GSD and GSLD rate schedules and would not receive a reduction in the electric bill. Greenlots, the Edison Electric Institute, and Drive Electric in written comments support FPL's proposed GSD-1EV and GSLD-1EV tariffs. EVgo Services supports FPL's proposal; however, EVgo suggests increasing the demand limiter of 75 hours to a limiter of 100 to 200 hours and increasing the term of the pilot program from five to ten years. Tesla, Electrify America, and AEE also stated that increasing the demand limiters would help improve fast charging stations' finances. Several interested persons referred to other states that have approved demand limiters of 100 or 200 hours, tariffs that reduce or eliminate demand charges, or no demand charges. The proposed tariffs are not-cost based as FPL will not fully recover its demand-related, or fixed, costs from customers with low load factor fast charging stations. The demand limiter is designed to provide rate relief that will facilitate and encourage the development of EV fast charging infrastructure during this nascent stage of EV adoption and EV charging market development. We find that the proposed demand limiter pilot tariffs represent a balanced approach to encourage third-party market development at these early market stages, while limiting ratepayer risk. We find that this also aligns with the legislative intent to encourage the installation of EV infrastructure. The proposed tariff could have an impact on the general body of ratepayers. Based on 2019 usage data of 41 fast charging stations, FPL estimated the annual lost revenues to be approximately $157,000. However, FPL asserts that if the proposed tariffs are successful in accelerating the adoption of EV use, any additional revenues will contribute to the recovery of fixed costs, reducing the impact on the general body of ratepayers. As discussed above, some interested persons expressed a desire for a larger reduction in the demand charges. However, a larger incentive would have the potential of shifting more costs to the general body of ratepayers. We find that FPL's proposed demand limiter balances the