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ORDER NO. PSC -2023 -0253 -TRF -EI DOCKET NO. 20230045 -El PAGE 6 conversions of existing non -hardened overhead feeder facilities and to include the waived existing facilities cost in net plant in service pursuant to Rule 25-6.115, F.A.C.S In this filing, FPL seeks to revise Tariff Sheet No. 6.300 to clarify that the costs for all existing non -storm hardened distribution facilities costs, which include both feeders and laterals, from the calculation of CIRC. The current tariff, as approved in Order No. PSC -2018 -0050 -TRF - EI, only refers to feeders. FPL further requests that we determine that there are quantifiable benefits to excluding the existing costs for all non -hardened overhead distribution facilities, i.e., both feeders and laterals. FPL also proposes to modify existing language and include additional language to its Underground Facilities Conversion Agreement, on Tariff Sheet No. 9.722. The proposed tariff modifications state that all facilities within the project must be converted to underground. In its petition, FPL stated that the proposed revisions are not a substantive change, but rather intended to clarify the scope of the underground conversion project and avoid or reduce customer confusion. A. Storm Protection Plan and Cost Recovery In February 2020, Rules 25-6.030, F.A.C., Storm Protection Plan (SPP), and 25-6.031, F.A.C., Storm Protection Plan Cost Recovery Clause (SPP Clause), were codified to implement Section 366.96, F.S. The SPPs cover the immediate 10 year planning period and are filed with us at least every three years. The plans must explain the systematic approach the utility will follow to achieve the objectives of reducing restoration costs and outage times associated with extreme weather events and enhancing reliability. The SPP Clause allows the utility to seek recovery from the general body of ratepayers for prudently incurred SPP costs through an annual proceeding. On April 11, 2022, FPL filed its proposed SPP for the period 2023-2032 for our approval, which was approved with modification by Order No. PSC-2022-0389-FOF-EI.6 B. Benefits to the General Body of RatepUers Order No. PSC -2018 -0050 -TRF -EI lists the benefits FPL provided to support excluding existing facilities costs from the calculation of CIAC for underground conversions of the existing non -hardened overhead facilities, that otherwise would be subject to hardening. In the instant petition, FPL listed similar benefits to the general body of ratepayers that the proposed revision to Tariff Sheet No. 6.300 would provide. First, FPL affirmed that the general body of ratepayers would pay no additional costs for the undergrounding conversions as the costs would have been included as a part of FPL's SPP to harden all overhead distribution facilities; Further, FPL asserted that due to the converting customer accelerating the timeline of whm FPL would have hardened the facilities, the general body of ratepayers would receive the benefits of such 50rder No. PSC -2018 -0050 -TRF -EI, issued January 22, 2018, in Docket No. 20170148 -EI, In re: Petition for determination under Rule 25-6.115, F.A.C., and approval of associated revised tariff sheet 6.300, by Florida Power & Light Company. "Order No. PSC-2022-0389-FOF-EI, issued November 10, 2022, in Docket No. 20220051 -EI, In re. Review of Storm Protection Plan, pursuant to Rule 25-6.030, F.A.C., Florida Power & Light Company. LF