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Florida Needs Energy Efficiency

published on: May 19, 2021

The below comments were shared by Climate and Clean Energy Advocate Zac Cosner during the Public Service Meeting on May 18, 2021. 

This past Tuesday, the Florida Public Service Commission held a workshop to consider changes to the rules which govern utilities’ obligations to provide energy efficiency under the Florida Energy Efficiency Conservation Act.

Energy efficiency is a vital public good that we have chronically underinvested in for decades in this state. Our energy efficiency policy can be described in three words: insufficient, inconsistent, and inhumane.

Florida ranks near the bottom of the pack when it comes to investment in energy efficiency. In aggregate, our utilities invest less than a fifth of the national average of 1% of sales on energy efficiency programs. The state’s largest utility, Florida Power & Light, spends an insultingly low .06% of sales revenue. FPUC invests approximately .01%, 100 times lower than the national average. The result is some of the highest rates of energy consumption in the nation.

There is major inconsistency across utilities in this state. TECO has wide participation, but shallow savings. Duke has deeper savings, but reaches only a small number of households, and FPL and Gulf, which serve over half of the customers in this state, have virtually no low-income programs to speak of.  We need specific goals and targets for these programs. Without leadership from the state level, our utilities will only continue to underinvest and invest in a chaotic and ad-hoc manner. Spending level targets or savings targets would be an excellent start. As other organizations have pointed out, abandoning the outdated Rate Impact Measure Test would go a long way and 2-year payback screen are also critical.

Our underinvestment in energy efficiency infrastructure is not just dangerous due to its effect on the environment, it imposes a real human cost on the people of Florida.

The danger in the lack of robust energy efficiency is only due to increase as average heat indexes in Florida continue to rise. Florida is one of the hottest states in the union, and it’s getting hotter. We currently average around 25 dangerous heat days annually, when temperatures exceed 103 degrees Fahrenheit . Experts project that by 2050, that number could exceed 130 such days each year. The rise in temperatures has already produced increased incidences of heat-related visits to emergency rooms in 37 counties.

Between March of 2020 and March of 2021, Florida’s largest utilities disconnected over 600,000 households from their power despite thousands of new cases of COVID-19 and hundreds of deaths occurring each day. Approximately 10% of these households did not receive subsequent reconnection. This shameful crisis of disconnections was undoubtedly exacerbated by our chronic underinvestment in energy efficiency.

There is a real human cost to lack of energy efficiency.

The Florida PSC must abandon the outdated Rate Impact Measure Test, which counts reduction in energy demand as a cost associated with the investment in efficiency. We can eliminate the 2-year payback screen that prohibits the use of efficiency methods that provide payback in less than two years, arbitrarily eliminating many of the easiest and most effective methods of increasing efficiency from consideration. Utilities justify this policy on the basis that customers should be paying for these improvements themselves. This answer shows a disturbing lack of understanding of what it means to experience poverty. We are the only state which uses such a screen, and we are the only state which still uses the Rate Impact Measure test.

The PSC has an opportunity to truly redefine the nature of our energy efficiency programs. 

Learn more about FEECA and energy efficiency at

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