john t. butler - psc.state.fl.us · pdf filejohn t. butler assistant general counsel - regu...

• I= PL.

VIA HAND DELIVERY Ms. Carlotta S. Stauffer Division of the Commission Clerk and Administrative Services

Florida Public Service Commission Betty Easley Conference Center, Room 110 2540 Shumard Oak Boulevard Tallahassee, Florida 32399-0850

John T. Butler Assistant General Counsel - Regulatory Florida Power & Light Company 700 niverse Boulevard Juno Beach, FL 33408-0420 (561) 304-5639 (561) 691-7135 (Facsimile) Email: [email protected]

July 28, 2017

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Re: Florida Power & Light Company's Request for Confidential Classification of Certain Material Provided in Connection with the Monthly Fuel Filings Docket No. 20170001-EI

Dear Ms. Stauffer:

I enclose for filing in the above-referenced matter Florida Power & Light Company's ("FPL") Request for Confidential Classification. The Request includes Attachments A, B and C.

Attachment A contains the confidential inf01mation that is the subject of FPL's Request for Confidential Classification. Attachment A is submitted for filing separately and marked "ATTACHMENT A - CONFIDENTIAL." Attachment B is an edited version of Attachment A, in which the information FPL asserts is confidential has been redacted. Attachment C contains FPL's justification for its request for confidential classification.

In accordance with Rule 25-22.006(3)(d), FPL requests confidential treatment of the information in Attachment A pending disposition of FPL's request for Confidential Classification.

Please contact me should you or your Staff have any questions regarding this filing.

Enclosures cc: parties of record (w/Request for Confidential Classification)

BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION

In re: Fuel and purchased power cost recovery clause with generating performance incentive factor

Docket No. 2017000 l-EI Date: July 28, 2017

REQUEST FOR CONFIDENTIAL CLASSIFICATION

Pursuant to Section 366.093, Florida Statutes, and Rule 25-22.006, Florida Administrative

Code, Florida Power & Light Company ("FPL") requests confidential classification of certain

information on Florida Public Service Commission ("FPSC" or "Commission") Forms 423-1(a),

423-2, 423-2(a) and 423-2(b) for April/March, May/April and June/May. In support of this request,

FPL states as follows:

1. Petitioner' s principal business address is as follows:

Florida Power & Light Company 700 Universe Boulevard Juno Beach, Florida 33408

Orders, notices, or other pleadings related to this request should be served on:

Kenneth A. Hoffman Vice President Regulatory Affairs Florida Power & Light Company 215 S. Monroe Street, Suite 810 Tallahassee, FL 32301-1858 (850) 521-3919 (850) 521-3939 Fax Email: [email protected]

John T. Butler Assistant General Counsel - Regulatory Florida Power & Light Company 700 Universe Boulevard Juno Beach, FL 33408-0420 (561) 304-5639 (561) 691-7135 Fax Email : [email protected]

1

2. The following attachments are included herewith and made a part hereof:

a. Attachment A includes the complete and unedited version of Florida Power & Light Company's (FPL) April, May and June 2107 Form 423-l(a), St. Johns Rjver Power Park's (SJRPP) April, May and June 2017 Forms 423-2, 423-2(a) and 423-2(b) and R.W. Scherer's (Plant Scherer) March, April and May 2017 Forms 423-2, 423-2(a) and 423-2(b) which contain certain information that FPL asserts should be accorded confidential treatment. The information in Attachment A for which FPL seeks confidential classification has been highlighted. Attachment A is submitted separately in a sealed envelope marked "CONFIDENTIAL."

b. Attachment B is the edited version of Attachment A. All information that FPL asserts is entitled to confidential treatment has been redacted in Attachment B.

c. Attachment C identifies information for which confidential treatment is sought and, with regard to each item or type of information, contains a brief statement that explains the need for confidentiality and refers to the specific statutory basis or bases for the request.

3. Pursuant to section 366.093, FPL seeks confidential protection for the information

highlighted in Attachment A. FPL submits that such information is proprietary confidential business

information within the meaning of section 366.093(3). Pursuant to section 366.093, such materials

are entitled to confidential treatment and are exempt from the disclosure provisions of the public

records Jaw. Thus, once the Commission detennines that the information in question is proprietary

confidential business information, the Commission is not required to engage in any further analysis

or review such as weighing the harm of disclosure against the public interest in access to the

information.

4. The statutory bases and support for FPL's assertion of confidentiality with regard to

specific items or types of information are set forth in Attachment C. The information for which

confidential classification is sought is intended to be and is treated by FPL as confidential and, to the

best ofFPL's knowledge and belief, has not been publicly disclosed.

2

5. Upon a finding by the Commission that the material in Attachment A for which FPL

seeks confidential treatment is proprietary confidential business information within the meaning of

section 366.093(3), pursuant to section 366.093(4) such materials should not be declassified for

eighteen ( 18) months, or as otherwise extended by the Commission. Further, the materials should be

returned to FPL as soon as the information is no longer necessary for the Commission to conduct its

business.

WHEREFORE, for the above and foregoing reasons, including those set forth in the

supporting materials included herewith, Florida Power & Light Company respectfully requests that

its Request for Confidential Classification be granted.

Respectfully submitted, John T. Butler Assistant General Counsel - Regulatory Florida Power & Light Company 700 Universe Boulevard Juno Beach, Florida 33408-0420 Tel. : (56 1) 304-5639 Fax: (561) 69 1-7135 Email : John.Butler@ fpl.com

3

CERTIFICATE OF SERVICE Docket No. 20170001-EI

I HEREBY CERTIFY that a true and correct copy of FPL's Request for Confidential Classification has been furnished by electronic mail on this 28111 day of July 2017 to the following:

Suzanne Brownless, Esq. Danijela Janjic, Esq. Division of Legal Services Florida Public Service Commission 2540 Shumard Oak Blvd. Tallahassee, Florida 32399-0850 [email protected]. us [email protected]

Beth Keating, Esq. Gunster Law Firm Attorneys for Florida Public Utilities Corp. 2 15 South Monroe St., Suite 601 Tallahassee, Florida 32301-1804 bkeati ng@gunster .com

James D. Beasley, Esq. J. Jeffrey Wahlen, Esq. Ausley & McMullen Attorneys for Tampa Electric Company P.O. Box 391 Tallahassee, Florida 32302 [email protected] [email protected]

Robert Scheffel Wright, Esq. John T. La Via, Ill, Esq. Gardner, Bist, Wiener, et al Attorneys for Florida Retail Federation 1300 Thomaswood Drive Tallahassee, Florida 32308 [email protected] [email protected]

4

Andrew Maurey Michael Barrett Division of Accounting and Finance Florida Public Service Commission 2540 Shumard Oak Blvd. Tallahassee, Florida 32399-0850 amaurey@psc. state. fl. us m [email protected]. fl.. us

Dianne M. Triplett, Esq. Attorneys for Duke Energy Florida 299 First A venue North St. Petersburg, Florida 33701 [email protected]

Jeffrey A. Stone, Esq. Russell A. Badders, Esq. Steven R. Griffin, Esq. Beggs & Lane Attorneys for Gulf Power Company P.O. Box 12950 Pensacola, Florida 32591-2950 [email protected] [email protected] [email protected]

James W. Brew, Esq. Laura A. Wynn, Esq. Attorneys for PCS Phosphate - White Springs Stone Mattheis Xenopoulos & Brew, PC 1 025 Thomas Jefferson Street, NW Eighth Floor, West Tower Washington, DC 20007-5201 [email protected] laura. [email protected]

Robert L. McGee, Jr. Gulf Power Company One Energy Place Pensacola, Florida 32520 [email protected]

Matthew R. Bernier, Esq. Duke Energy Florida 106 East College A venue, Suite 800 Tallahassee, Florida 32301 [email protected]

J. R. Kelly, Esq. Patricia Christensen, Esq. Charles Rehwinkel , Esq. Office of Public Counsel c/o The Florida Legislature 1 11 West Madison Street, Room 812 Tallahassee, Florida 32399 [email protected] [email protected] [email protected]. us

Mike Cassel Director/Regulatory and Governmental Affairs Florida Public Utilities Company 91 1 South 8th Street Fernandina Beach, Florida 32034 mcassel@ fpuc.com

PauJa K. Brown, Manager Tampa Electric Company Regulatory Coordinator Post Oftice Box Ill Tampa, Florida 33601-0111 regdept@tecoenergy. com

Jon C. Moyle, Esq. Moyle Law Firm, P.A. Attorneys for Florida Industrial Power

Users Group 118 N. Gadsden St. Tallahassee, Florida 32301 [email protected]

*Copies of Exhibits B and C are available upon request.

607!001

5

ATTACHMENT ''A"

CONFIDENTIAL FILED UNDER SEPARATE COVER

FPL FPSC FORM 423-l(a)

SJRPP FPSC FORMS 423-2

423-2 (a) 423-2 (b)

R.W. SCHERER FPSC FORMS 423-2

423-2 (a) 423-2 (b)

ATTACHMENT ''B"

EDITED VERSION

FPL FPSC FORM 423-l(a)

SJRPP FPSC FORMS 423-2

423-2 (a) 423-2 (b)

R.W. SCHERER FPSC FORMS 423-2

423-2 (a) 423-2 (b)

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FPSC FORM NO. 423-1

1. REPORTING MONTH: APR YEAR: 2017

MONTHLY REPORT OF COST AND QUALITY OF FUEL OIL FOR ELECTRIC PLANTS ORIGIN, VOLUME, DELIVERED PRICE AND AS RECEIVED QUANTITY

3. NAME, TITLE _TELEPHONE NUMBER OF CONTACT PERSON CONCERNING DATA

SUBMITIED ON THIS FORM: RENAE DEATON, REGULATORY AFFAIRS, (561) 691-2839

2. REPORTING COMPANY: FLORIDA POWER & LIGHT COMPANY 4. SIGNATURE OF OFFICIAL SUBMITIING REPORT: 24:/ld:::::-::: 5. DATE COMPLETED: 05/30/2017

LINE PURCHASE DELIVERY DELIVERY TYPE NO PLANT SUPPLIER SHIPPING POINT TYPE LOCATION DATE OIL SULFUR(%)

LAUDERDALE GT S APEC NA-TRUCK DELIVERY 04/30/2017 F03 N/A

2 FT. MYERS APEC NA-TRUCK DELIVERY 04/19/2017 F03 NIA

3 WEST COUNTY EC PORT NA-TRUCK DELIVERY 04/30/2017 F03 N/A

4 MARTIN INDIANTOWN NA-TRUCK DELIVERY STC 04/17/2017 PRO N/A

FPSC FORM NO. 423-1 (04/2017)

BTU CONTENT VOLUME PRICE

(BTU/GAL) (BBLS) ($/BBL)

N/A 9092 75.1363

N/A 20447 76.8364

N/A 19632 73.1260

N/A 11 63.5136

or 1

FPSC FORM NO. 423-1 (a)

1. REPORTING MONTH: APR YEAR: 2017

2. REPORTING COMPANY: FLORIDA POWER .LIGHT COMPANY

(A) (B) (C) (D) (E)

LINE DELIVERY DELIVERY NO. PLANT SUPPLIER LOCATION DATE

1 GFL APEC 04/26/2017

2 GFL APEC 04/30/2017

3 PFM APEC 04/19/2017

4PWC PORT 04/28/2017

5PWC PORT 04/30/2017

8 PMR INDIANTOWN 04/17/2017

FPSC FORM NO. 423-1 (a) (0412017)

MONTHLY REPORT OF COST AND QUALITY OF FUEL OIL FOR ELECTRIC PLANTS

DETAIL OF INVOICE AND TRANSPORTATION CHARGES

3. NAME, TITLE _TELEPHONE NUMBER OF CONTACT PERSON CONCERNING DATA SUBMmED ON THIS FORM: RENAE DEATON, REGULATORY AFFAIRS, (561) 691-2839

4. SIGNATURE OF OFFICIAL SUBMITTING REPORT: ~ 5. DATE COMPLETED: 0513012017

(F) (G) (H) (I) (J) (K} (L) (M) (N) (0) (P)

INVOICE INVOICE NET NET QUALITY EFFECTIVE TRANSP ADDITIONAL TYPE VOLUME PRICE AMOUNT DISCOUNT AMOUNT PRICE ADJUST. PUR PRICE TO TERM TRANS CHGS

OIL (BBLS) ($/BBL) ($) ($) {$/BBL) ($/BBL) {$/BBL) {$/BBL) {$188L) ,,, F03 7378 0.0000

F03 1714 0.0000

F03 20447 0.0000

F03 18391 0.0000

F03 1441 0.0000

PRO 11 0.0000

REDACTED

(Q)

OTHER CHGS ($188L)

EDITED COPY

(R)

DELIVERED PRICE ($/BBL)

74.1093

79.5574

78.8364

73.3336

70.4729

63.5136

of 1

FPSC FORM NO. 423-1(b)

1. REPORTING MONTH: April YEAR:

2. REPORTING COMPANY: FLORIDA POWER & LIGHT COMPANY

FORM ORIGINAL OLD LINE MONTH PLANT LINE VOLUME

NO. REPORTED NAME SUPPLIER NUMBER (BBLS)

® rel .{g LQl ill ill

1 NONE

2017

COLUMN FORM DESIGNATOR NO • & TITLE

!m. ilil

MONTLY REPORT OF COST AND QUAUTY OF FUEL OIL FOR ELECTRIC PLANTS REPORT OF ADJUSTMENTS TO PREVIOUS OIL DELIVERIES

3. NAME, TITLE, & TELEPHONE NUMBER OF CONTACT PERSON CONCERNING DATA SUBMITTED ON THIS FORM: tREN~E DEATON, REGULATORY AFFAIRS, (561) 691-2839

4. SIGNATURE OF OFFICIAL SUBMITTING REPORT:

5. DATE COMPLETED: 5/26/2017

NEW DELIVERED

OLD NEW PRICE VALUE VALUE ($/BBL) REASON FOR REVISION

ill ill ill ill

FPSC Form No. 423-2 MONTHLT REPORT OF COAST AND QUALITY OF COAL FOR ELECTRIC PLANTS

ORIGIN, TONNAGE, DELIVERED PRICE AND AS RECEIVED QUALITY

1. Report for Month/Year: April 2017

2. Reporting Company: Florida Power & light

3. Plant Name: St. Johns River Power Park (SJRPP)

Transpor-

Line Mine Purchase tation

No. Supplier Name Location Type Mode

(a) (b) (c) (d) (e)

1. COAL MARKETING COMPANY IM,999 LTC oc

FPSC Form No. 423-2

4. Name, Title & Telephone Number of Contact

Person Concerning Date Submitted on t his Form: Renae Deat on (561-691-2839)

5. Signature of Official Submitting Report:

6. Date Completed:

Effect ive Total

Purchase Trans

Price Cost

Tons ($/Ton) ($/Ton)

(f) (g) (h)

12,164

May 2, 2017

As Received Coal Quality

FOB

Plant Sulfur Btu Ash Moisture

Price Content Content Content Content

($/Ton) ~%! (Btu/lb) (%! !%!

(i) m (k) (I) (m)

80.91 0.63 10,988 10.89 12.43

EDITED COPY

NOTES: 1} SJRPP reported coal volumes represents

FPL's 20% share of coal receipts.

FPSC Form No. 423-2 (a) MONTHLT REPORT OF COAST AND QUALITY OF COAL FOR ELECTRIC PLANTS

DETAIL OF INVOICE PURCHASE PRICE

1. Report for Month/Year: April2017

2. Reporting Company: Florida Power & Light


Line M ine Purchase

No. Supplier Name location Type Tons

(a) (b) (c) (d) (e)

1. COAL MARKETI NG COMPANY IM,999 LTC 12,164

FPSC Form No. 423-2 (a)

4. Name, Title & Telephone Number of Cont act

Person Concerning Date Submitted on this Form: Renae Deaton (561-691-2839)


6. Date Completed: May 2, 2017

Retro-

FOB Short Original active Quality Effective

Mine Haul & Invoice Price Base Adj ust- Purchas

Price Loading Price Increases Price ments Price

($/Ton) Char~e ($/Ton) ($/Ton) ($/Ton) ($/Ton) ($/Ton)

(f) (g) (h) (i) Ol (k) (I)

0.00 0.00 0.00

EDITED COPY

NOTES: 1) SJRPP reported coal volumes represents


FPSC Form No. 423-2 (b)

1. Report for Month/Year:

2. Reporting Company:

3. Plant Name:

Line

No. Supplier Name

(a) (b)

MONTHLT REPORT OF COAST AND QUALITY OF COAL FOR ELECTRIC PLANTS

DETAIL OF TRANSPORTATION CHARGES

Apr il 2017

Florida Power & light

St. Johns River Power Park (SJRPP)


Person Concerning Date Submitt ed on this Form:


6. Date Completed:

Renae Deaton (561-691-2839)

May 2, 2017

Short I Roll Charges I Waterborne Charges

I Effective Haul & Other River Trans· Ocean Other Total FOB

Transpor- Purchas Loading Rail Rail Barge loading Barge Water Related Transport Plant

Mine Shipping tation Price Charge Rate Charges Rate Rat e Rat e Charges Charges Charges Price

Location Point Mode Tons {$/Ton) {$/Ton) {$/Ton) {$/Ton) {$/Ton) {$/Ton) ($/Ton) {$/Ton) {$/Ton) ($/Ton) ($/Ton)

(c) (d) (e) (f) (g) (h) (i) (j) (k) (I ) (m) (n) (o) (p) (q)

1. COAL MARKETING COMPANY IM,999 El Cerrejon oc 12,164 0.00 0.00 0.00 0.00 0.00 0.00 0.00 80.91


EDITED COPY



FPSC Form No. 423-2 MONTHLY REPORT OF COST AND QUALITY OF COAL FOR ELECTRIC PLANTS

ORIGIN, TONNAGE, DELIVERED PRICE, AND AS RECEIVED QUALITY

1. Reporting Month: March Year: 2017 4. Name, TiUe & Telephone Number of Contact Person Concerning Data Submitted on this Form: Renae Deaton 561 691-2839

5. Signature of Official Submitting Report: ~.t-v'\ .l3 )

6. Date Completed: 12-May-17

2. Reporting Company: FLORIDA POWER & LIGHT COMPANY

3. Plant Name: R.W.SCHERER

Effective Total Purchase Transport FOB Plant Sulfur Btu Ash Moisture

Line Mine Purchase Transport Price Charges Price Content Content Content Content

No. Supplier Name Lo!;ation ~ Mode Tons ($!Toni ($!Toni IS!Tonl 00 (Btu/lbl 00 00

(a) (b) (c) (d) (e) (f) (g) (h) (i) (j) (k) (I) (m)

(1) COAL SALES, LLC 19NJY/5 s UR 79,393.58 37.730 0.38 8,388 5.46 29.54

(2) BUCKSKIN MINING COMPA 19NJY/5 s UR 79,343.28 37.831 0.27 8,503 4.29 29.44

(3) ARCH COAL SALES CO, IN( 19NJY/5 s UR 20,215.56 38.067 0.30 8,299 5.66 30.24

EDITED COPY

FPSC Form No. 423-2(a) MONTHLY REPORT OF COST AND QUALITY OF COAL FOR ELECTRIC PLANTS

DETAILED PURCHASED COAL INVOICE INFORMATION

1. Reporting Month: March Year: 2017 4. Name, Title & Telephone Number of Contact Person Concerning Data Submitted on this Form: Renae Deaton

2. Reporting Company: FLORIDA POWER & LIGHT COMPANY 561 691-2839

3. Plant Name: R.W.SCHERER 5. Signature of Official Submitting Report:

6. Date Completed: 12-May-17

FOB Shorthaul Original Retroactive

Mine & Loading Invoice Price Base Quality

Line Mine Purch. Price Charges Price Increase Price Adjustments

NQ.: Su~~lier Name Location ~ 12M ($/Ton) ($/Ton} ($/Ton} ($/Ton) ($/Ton) ($/Ton)

(a) (b) (c) (d) (e) (f) (g) (h) (i) G) (k)

(1) COAL SALES, LLC 19/WY/5 s 79,393.58 0.150 0.095

(2) BUCKSKIN MINING COMPP 19/INY/5 s 79,343.28 0.135 (0.067)

(3) ARCH COAL SALES CO, IN• 19/WY/5 s 20,215.56 0.148 (0.111)

Effective Purchase

Price ($/Ton)

(I)

EDITED COPY

FPSC Form No. 423-2(b)

1. Reporting Month: March Year: 2017



Line Mine Shipping Transport

.N2. :iYIIIllil[ f:!IWI I.2W12n f2in1 Mode

(a) (b) (C) (d) {e)

(1) COAL SALES. LLC 191WY/5 CABALLO JCT, 'M UR

(2) BUCKSKIN MINING COW 191WY/5 BUCKSKIN JCT, V.. UR

{3) ARCH COAL SALES CO. 191WYI5 THUNDER JCT, W UR

MONTHLY REPORT OF COST AND QUALITY OF COAL FOR ELECTRIC PLANTS DETAILED TRANSPORTATION INVOICE INFORMATION

4. Name. nue & Telephone Number or Contact Person Conceming Data Submitted on this Form: Renae Deaton 561 691-2839

5. Signature of Official Submitting RePOrt:

6. Date Completed: 12-May.17

Additional I Rail Charges Waterborne Charges Effective Shorthaul Other River Trans-

Purchase & Loading Rail Rail Barge loading

Price Charges Rate Charges Rate Rate

I2nl Wil!o.l Wil!o.l lJli2lll I.UI2nl ~ l.lli2nl (f) (g) (h) (Q (j) (k) (I)

79,393.58

79,343.28

20,215.56

Total Ocean Other Other Transpor-Barge Water Related uotlon Rate Charges Charges Charges

Wil!o.l Wil!o.l Wil!o.l lJli2lll (m) (n) (o) (p)

EDITED COPY

'

FOB Plant Price

OOQn1 {q)

37.730

37.831

38.067

of 1

FPSC FORM NO. 423-1

1. REPORTING MONTH: MAY YEAR: 2017

MONTHLY REPORT OF COST AND QUALITY OF FUEL OIL FOR ELECTRIC PLANTS ORIGIN, VOLUME, DELIVERED PRICE AND AS RECENED QUANTITY

3. NAME, TITLE .TELEPHONE NUMBER OF CONTACT PERSON CONCERNING DATA SUBMITTED ON THIS FORM: RENAE DEATON, REGULATORY AFFAIRS, (561) 691·2839

2. REPORTING COMPANY: FLORIDA POWER & LIGHT COMPANY 4. SIGNATURE OF OFFICIAL SUBMITTING REPORT: ~--,. ····-· 5. DATE COMPLETED: 06/07/2017

LINE PURCHASE DELIVERY DELIVERY TYPE

NO PLANT SUPPLIER SHIPPING POINT TYPE LOCATION DATE OIL SULFUR(%)

LAUDERDALE GT S APEC NA-TRUCK DELIVERY 05/23/2017 F03 NIA

2 WEST COUNTY EC PORT NA-TRUCK DELIVERY 05117/2017 F03 N/A

3 MANATEE SUBURBAN NA-TRUCK DELIVERY STC 0510112017 PRO NIA

FPSC FORM NO. 423·1 (06/2017)


(BTU/GAL) (BBLS) ($/BBL)

N/A 46205 68.8386

N/A 25014 68.5733

NIA 1144 53.2967

of 1

FPSC FORM NO. 423-1 (a)

1. REPORTING MONTH: MAY YEAR: 2017


(A) (B) (C) (D) (E)


1 GFL APEC 05/23/2017

2PWC PORT 05/17/2017

3 PMT SUBURBAN 05/01/2017

FPSC FORM NO. 423-1 (a) (05/2017)



3. NAME, TITLE .TELEPHONE NUMBER OF CONTACT PERSON CONCERNING DATA

SUBMITIED ON THIS FORM: RENAE DEATON, REGULAT RY AFFAIRS, (561) 691-2839

4. SIGNATURE OF OFFICIAL SUBMITIING REPORT::_,L_~~2{__:~~::=:=-


(F) (G) (H) (I) (J) (K) (L) (M) (N) (0)

INVOICE INVOICE NET NET QUALITY EFFECTIVE TRANSP TYPE VOLUME PRICE AMOUNT DISCOUNT AMOUNT PRICE ADJUST. PUR PRICE TO TERM

OIL (BBLS) ($/BBL) ($) ($) ($/BBL) ($/BBL) ($/BBL) ($/BBL)

F03 46205 0.0000

F03 25014 0.0000

PRO 1144 0.0000

(P) (Q)

ADDITIONAL OTHER TRANSCHGS CHGS

($/BBL) ($/BBL)

EDITED COPY

(R)

DELIVERED PRICE ($/BBL)

68.8386

68.5733

53.2967

I i

I I

of 1

FPSC FORM NO. 423·1(b)

1. REPORTING MONTH: May YEAR:


FORM ORIGINAL OLD LINE MONTH PLANT LINE VOLUM E NO. REPORTED NAME SUPPLIER NUMBER (BBLS)

!Al w Kl. fQl. ill ill

1 NONE

2017

COLUMN FORM DESIGNATOR

NO. & TITLE .(§1 llil

MONTLY REPORT OF COST AND QUALITY OF FUEL OIL FOR ELECTRIC PLANTS REPORT OF ADJUSTMENTS TO PREVIOUS OIL DELIVERIES

3. NAME, TITLE, & TELEPHONE NUMBER OF CONTACT PERSON CONCERNING DATA SUBMITTED ON THIS FORM: : ~tr•ta.fo·E~TO·N: .REGU~TPRY AFFAIRS, (561) 691-2839



NEW DELIVERED


ill ill 00 ill


ORIGIN, TONNAGE, DELIVERED PRI~E AND AS RECEIVED QUALITY

1. Report for Month/Year: May 2017



Transpor-

Line M ine Purchase tation

No. sueelier Name Location Type Mode

(a) (b) (c) (d) (e)


FPSC Form No. 423-2


Person Concerning Date Submitted on this Form:


6. Date Completed:

Effective Total FOB

Purchase Trans Plant

Price Cost Price

Tons {$/Ton) ($/Ton) !S/Ton)

(f) (g) (h) (i)

79,675 80.02


June 8, 2017


Sulfur Btu Ash Moisture

Conte.nt Content Content Content

!%) !Btu/lb) (%) !%l

Ul (k) (I) (m)

0.52 10,982 9.51 13.38

EDITED COPY





1. Report for Month/Year: May 2017



Line Mine Purchase

No. Su~~lier Name Location Ty~e Tons

(a) (b) (c) (d) (e)

1. COAL MARKETING COMPANY IM,999 LTC 79,675



Person Concerning Date Submitted on this Form: Renae Deaton (561-691-2839)


6. Date Completed: June 8, 2017

Retro-


M ine Haul& Invoice Price Base Adjust- Purchas


($/Ton) Char~e ($/Ton) ($/Ton) ($/Ton) ($/Ton) ($/Ton)

(f) (g) (h) (i) Ul (k) (I)

0.00 0.00 0.00

EDITED COPY






3. Plant Name:

Line No. Supplier Name

(a) (b)

MONTHLT REPORT OF COAST AND QUALITY OF COAL FOR ElECTRIC PLANTS


May 2017

Florida Power & Light

St. Johns River Power Park (SJRPP)


Person Concerning Date Su bmitted on this Form:


6. Date Completed :


June 8, 2017

Rail Charges Waterborne Charges

Short Effective Haul & Other River Trans- Ocean Other Total FOB

Transpor- Purchas Loading Rail Rail Barge loading Barge Water Related Transport Plant Mine Shipping tat ion Price Charge Rate Charges Rate Rate Rate Charges Charges Charges Price

Location Point Mode Tons ($/Ton) ($/Ton) ($/Ton) ($/Ton) ($/Ton) ($/Ton) ($/Ton) ($/Ton) ($/Ton) ($/Ton) ($/Ton)

(c) (d) (e) (f) (g) (h) (i) U) (k) (I) (m) (n) (o) (p) (q)

1. COAL MARKETING COMPANY IM,999 El Cerrejon oc 79,675 0.00 0.00 0.00 0.00 0.00 0.00 0.00 80.02


EDITED COPY


FPL's ZO% share of coal receipts.

FPSC Form No. 423-2

1. Reporting Month:


3. Plant Name:

line No. Supplier Name (a) (b)

(1) COAL SALES, LLC

(2) ARCH COAL SALES CO, IN(

(3) BUCKSKIN MINING COMPA

MONTHLY REPORT OF COST AND QUALITY OF COAL FOR ELECTRIC PLANTS ORIGIN, TONNAGE, DELIVERED PRICE, AND AS RECEIVED QUALITY

April Year: 2017 4. Name, Title & Telephone Number of Contact Person Concerning Data Submitted on this Form: Renae Deaton

FLORIDA POWER & LIGHT COMPANY 561691-2839 ::r- ] R.W.SCHERER 5. Signature of Official Submitting Report: -W"l

6. Date Completed: 26-Jun-17

Effective Total Purchase Transport FOB Plant Sulfur Btu

Mine Purchase Transport Price Charges Price Content Content location ~ Mode Tons ($/Ton) {$/Ton) {$/Ton) 00 !Btu/lbl

(c) (d) (e) (f) (g) (h) (i) 0) (k)

19/WY/5 s UR 63,130.14 37.558 0.35 8,354

19/WY/5 s UR 67,505.98 38.009 0.31 8,275

19/WY/5 s UR 27,614.13 38.361 0.27 8,480

Ash Content

00 (I)

5.69

5.70

4.17

EDITED COPY

Moisture Content

00 (m)

29.45

30.49

29.64



1. Reporting Month: April Year: 2017 4. Name, Title & Telephone Number of Contact Person Concerning Data Submitted on this Form: Renae Deaton

2. Reporting Company: FLORIDA POWER & LIGHT COMPANY 561 691-2839

3. Plant Name: R.W.SCHERER 5. Signature of Official Submitting Report

6. Date Completed: 26-Jun-17

FOB Shorthaul Original Retroactive Effective Mine & Loading Invoice Price Base Quality Purchase

Line Mine Purch. Price Charges Price Increase Price Adjustments Price No. Su~~lier Name Location ~ Tons csrron) csrron) csrron) csrronl M2nl csrronl M2nl (a) (b) (c) (d) (e) (f) (g) (h) (i) 0) (k) (I)

(1) COAL SALES, LLC 19NVY/5 s 63,130.14 0.150 (0.157)

(2) ARCH COAL SALES CO, IN 19NVY/5 s 67,505.98 0.148 (0.139)

(3) BUCKSKIN MINING COMP.t 19NVY/5 s 27,614.13 0.135 0.079

EDITED COPY

FPSC Form No. 423-2(b)

1. Reporting Month: April Year: 2017



Line Mine Shipping Transport

ti2. lilllll!lllt ~1m1 .I..2Wi2.n ~ Mode (a) (b) (c) (d) (e)

(1) COAL SALES. LLC 19NN/5 CABALLO JCT. W'o UR

(2) ARCH COAL SALES CO. 19/WY/5 THUNDER JCT. W UR

(3) BUCKSKIN MINING COW 19NN15 BUCKSKIN JCT, V\ UR


4. Name. Tide & Telephone Number of Contact Person Concerning Data Submitted on this Form: Renae Deaton ~ _ • ~

5. :g1

~:::::ff~aiSubmmngRepOO: d -h ~~ ~ 6. DateCompleted: 2~u~17 ~ v

Additional I Rail Cha!JieS Waterborne Cha!lle• Effective Shorlhaul Other River Trans- Oc:ean Other Pure hue & Loading Rail Rail Barge loading Barge Water

Price Charges Rate Charges Rate Rate Rate Charges

Il1.!11 {SLI.Qol {SLI.Qol {SLI.Qol {SLI.Qol {Jli2nl {Jli2nl {SLI.Qol {SLI.Qol (f) (g) (h) (l) 0> (k) (I) (m) (n)

63,130.14

67,505.98

27.614.13

Total Other Transpor-

Related tatlon Charges Charges {SLI.Qol {SLI.Qol

(o) (p)

EDITED COPY

FOB Plant Priee

Lllil!n.l (q)

37.558

38.009

38.361

ol 1

FPSC FORM NO. 423·1

1. REPORTING MONTH: JUN YEAR: 2017

MONTHLY REPORT OF COST AND QUALITY OF FUEL OIL FOR ELECTRIC PLANTS ORIGIN, VOLUME, DELIVERED PRICE AND AS RECEIVED QUANTITY

3. NAME, TITLE .TELEPHONE NUMBER OF CONTACT PERSON CONCERNING DATA

SUBMITIED ON THIS FORM: RENAE DEATON, REGULATORY AFFAIRS, (561) 691·2839

2. REPORTING COMPANY: FLORIDA POWER & LIGHT COMPANY 4. SIGNATURE OF OFFICIAL SUBMITIING REPORT: ,~ 5. DATE COMPLETED: 07/24/2017

LINE PURCHASE DELIVERY DELIVERY TYPE

NO PLANT SUPPLIER SHIPPING POINT TYPE LOCATION DATE OIL SULFUR (~•)

MARTIN APEC NA-TRUCK DELIVERY 06/30/2017 F03 N/A

2 PT. EVERGLADES TOC NA-TRUCK DELIVERY 06/3012017 F03 N/A

3 MANATEE SUBURBAN NA-TRUCK DELIVERY STC 06/07/2017 PRO N/A

4 MANATEE SUBURBAN NA-TRUCK DELIVERY STC 06/2112017 PRO N/A

FPSC FORM NO. 423-1 (0612017)


(BTU /GAL) (BBLS) ($/BBL)

N/A 7135 65.9221

N/A 19473 67.1364

NIA 5 59.0680

NIA 14 53.7564

ol1

FPSC FORM NO. 423·1 (a)

1. REPORTING MONTH: JUN YEAR: 2017


(A) (B) (C) (D) (E)


1 PMR APEC 06/28/2017

2 PMR APEC 06/30/2017

3 PFL roc 06/26/2017

4 PFL roc 06/30/2017



FPSC FORM NO. 423·1 (a) (0612017)



3. NAME. TITLE .TELEPHONE NUMBER OF CONTACT PERSON CONCERNING DATA SUBMITIED ON THIS FORM: RENAE DEATON, REGULATORY AFFAIRS, (561) 691·2839

4. SIGNATURE OF OFFICIAL SUBMITTING REPORT: ·~ 5. DATE COMPLETED: 07/W2017

(F) (G) (H) (I) (J) (K) (L) (M) (N) (0)

INVOICE INVOICE NET NET QUALITY EFFECTIVE TRANSP TYPE VOLUME PRICE AMOUNT DISCOUNT AMOUNT PRICE ADJUST. PUR PRICE TO TERM

OIL (BBLS) ($/BBL) ($) ($) ($/BBL) ($/BBL) ($/BBL) ($/BBL)

F03 5533 0.0000

F03 1602 0.0000

F03 10892 0.0000

F03 8581 0.0000

PRO 5 0.0000

PRO 14 0.0000

(P) (Q) (R)

ADDITIONAL OTHER DELIVERED TRANS CHGS CHGS PRICE

($/BBL) ($/BBL) ($/BBL)

85.7897

66.3792

65.1392

69.6715

59.0680

53.7664

EDITED COPY

of 1

FPSC FORM NO. 423·1(b)

1. REPORTING MONTH: June YEAR:


FORM ORIGINAL OLD LINE MONTH PLANT LINE VOLUME NO. REPORTED NAME SUPPLIER NUMBER (BBLS)

~ 00 LQ !.Q1 ill .!£1

1 NONE

2017

COLUMN FORM DESIGNATOR

NO. & TITLE {§1 llil

MONTL Y REPORT OF COST AND QUALITY OF FUEL OIL FOR ELECTRIC PLANTS REPORT OF ADJUSTMENTS TO PREVIOUS OIL DELIVERIES

3. NAME, TITLE, & TELEPHONE NUMBER OF CONTACT PERSON CONCERNING DATA SUBMITIED ON THIS FORM: : RENA~ DEATOt.-J, .REGl,ll.4if{:>RY AFFAIRS, (561) 691·2839



NEW DELIVERED


ill ill !lS.l. ill


ORIGIN, TONNAGE, DELIVERED PRICE AND AS RECEIVED QUALITY

1. Report for Month/Year: June 2017

2. Reporting Company: Florida Power & light


Transpor-

Line Mine Purchase tation

No. Su~e l ier Name Location T~ee Mode

(a) (b) (c) (d) (e)


FPSC Form No. 423-2


Person Concerning Date Submitted on this Form:


6. Date Completed:

Effective Total FOB

Purchase Trans Plant

Price Cost Price

Tons ($/Ton) ($/Ton) ($/Ton)

(f) (g) (h) (i)

39,657 80.02


July 10, 2017


Sulfur Btu Ash Moisture

Content Content Content Content

(%) (Btu/lb) (%) (%)

Ul (k) (I) (m)

0.60 11,038 9.93 12.76

EDITED COPY



--------~~~~~~~~~~~~~~~~~------------------------------------------------------------------------------------~



1. Report for Month/Year: June 2017


3. Plant Name: St. Johns River Power Park (SJRPP}

Line Mine Purchase

No. Supplier Name Location Type Tons

(a) (b) (c) (d) (e)

1. COAL MARKETING COMPANY IM,999 LTC 39,657



Person Concerning Date Submitted on this Form: Renae Deaton (561-691-2839}


6. Date Completed: July 10, 2017

Retro-


Mine Haul& Invoice Price Base Adj ust- Purchas


($/Ton) Charge ($/Ton) ($/Ton) ($/Ton) {$/Ton) ($/Ton)

(f) (g) {h) (i) (j) (k) (I)

0.00 0 .00 0 .00

EDrfED COPY






3. Plant Name:

Line

No. Supplier Name

(a) (b)

MONTHLT REPORT OF COAST AND QUALITY OF COAL FOR ELECTRIC PLANTS


June 2017

Florida Power & Light

St. Johns River Power Pa rk {SJRPP)


Person Concerning Date Submitted on t his Form:


6. Date Completed:


I%AM&f12t July 10, 2017

Short I R•il Chocg" I Waterborne Charges

I Effective Haul& Other River Trans- Ocean Other Total FOB

Transpor- Purchas Loading Rail Rail Barge loading Barge Water Related Transport Plant

Mine Shipping tat ion Price Charge Rate Charges Rate Rate Rat e Charges Charges Charges Price

Location Point Mode Tons {$(Ton) ($/Ton) {$(Ton) ($(Ton) {$(Ton) {$/Ton) ($(Ton) ($(Ton) ($(Ton) ($/Ton) ($(Ton)

(c) (d) (e) (f) (g) (h) (i) OJ (k) (I) (m) (n) (o) (p) (q)

1. COAL MARKETING COMPANY IM,999 El Cerrejon oc 39,657 0.00 0.00 0 .00 0.00 0.00 0.00 0.00 80.02


EDITED COPY



FPSC Form No. 423-2

1. Reporting Month:


3. Plant Name:

Line No. Supplier Name (a) (b)

(1) COAL SALES, LLC


(3) ARCH COAL SALES CO, IN(


MONTHLY REPORT OF COST AND QUALITY OF COAL FOR ELECTRIC PLANTS ORIGIN, TONNAGE, DELIVERED PRICE, AND AS RECEIVED QUALITY

May Year: 2017 4. Name, Title & Telephone Number of Contact Person Concerning Data Submitted on this Form: Renae Deaton

FLORIDA POWER & LIGHT COMPANY 561 691-2839

q{~l3 R.W.SCHERER 5. Signature of Official Submitting Report:

6. Date Completed: 20-Jul-17

Effective Total Purchase Transport FOB Plant Sulfur Btu

Mine Purchase Transport Price Charges Price Content Content Location ~ Mode Tons ($fTonl ($fTonl ($fTonl rill. IBtu/lbl

(c) (d) (e) (f) (g) (h) (i) 0) (k)

19NVY/5 s UR 15,878.29 37.320 0.36 8,363

19NVY/5 s UR 95,229.43 37.977 0.32 8,470

19NVY/5 s UR 74,144.1 8 37.946 0.31 8 ,244

19NVY/5 s UR 27,529.25 38.319 0.32 8,468

Ash Content

rill. (I)

5.31

4 .42

5.39

4.45

EDITED COPY

Moisture Content

!.%1 (m)

29.80

29.63

31.03

29.49



1. Reporting Month: May Year: 2017 4. Name, Title & Telephone Number of Contact Person Concerning Data Submitted on this Form: Renae Deaton 561691 -2839 ~

5. Signature of Official Submitting Report: J) bs1



6. Date Completed: 20-Jul-17

FOB Shorthaul Original Retroactive Mine & Loading Invoice Price Base Quality

Line Mine Purch. Price Charges Price Increase Price Adjustments No. Su[mlier Name Location ~ Tons ($/Ton) ($/Ton) ($/Ton) ($/Ton) ($/Toni ($/Toni (a) (b) (c) (d) (e) (f) (g) (h) (i) (j) (k)

(1) COAL SALES, LLC 19NVY/5 s 15,878.29 0.150 (0.285)

(2) BUCKSKIN MINING COMPP 1gNVYJ5 s 95,229.43 0.135 0.069

(3) ARCH COAL SALES CO, IN•19NVY/5 s 74,144.18 0.148 (0.162)

(4) BUCKSKIN MINING COMPP 19NVY/5 s 27,529.25 0.135 0.097

EDITED COPY

Effective Purchase

Price ($/Ton)

(I)

FPSC Form No 423-2(b)

1. RepMing Month: May Year: 2017

2. RepMing Company: FLORIDA POWER & LIGHT COMPANY


Line Mine Shipping Transport H2. ~plier Name .I.2Wl2ll f2!nl ~ (8) (b) (c) (d) (e)

(1) COAL SALES, LLC 191WY/5 CABALLO JCT, 'M UR

(2) BUCKSKIN MINING COM 191WY/5 BUCKSKIN JCT, VI UR

(3) ARCH COAL SALES CO. 19/WY/5 THUNDER JCT, W UR

(4) BUCKSKIN MINING COM 19/WY/5 BUCKSKIN JCT, VI UR


I2.o.l (f)

15,878.29

95,229.43

74,144,18

27,529.25

4. Name, Title & Telephone Number ol Contact Person Concerning Data Submitted on this Form: Renae Deaton 561 691-2839

5. Signature of OffiCial Subm~ting Report:

6. Date Completed:

Additional Effective Shorthaul Purchase & Loading

Price Charges lSli2nl M2nl

(g) (h)

20-Jul-17

Rail Charges

Rail Rate

(Slilml (1)

Other Rail

Charges (Slilml

OJ

Waterborne Charges River Trans-Barge loading Rate Rate

M2nl (Slilml (k) (I)

Ocean Barge Rate

(Slilml (m)

Other Water

Charges l.lffi!.ol

(n)

Other Related Charges (Slilml

(o)

Total Tranapor

tatlon Charges I.IIIs!lll

(p)

EDITED COPY

FOB Plant Price

l.lffi!.ol (q)

37.320

37.977

37.946

38.319

ATTACHMENTC Docket No. 20170001-EI

Justification for Confidentiality for Florida Power & Light Company Report of April 2017:

FORM LINE(S) COLUMN RATIONALE

423-l(a) 1-6 H (1)

423-l(a) 1-6 I (2)

423-1 (a) 1-6 J (2), (3)

423-1 (a) 1-6 K (2)

423-1 (a) 1-6 L (2)

423-l(a) 1-6 M (2), (4)

423-1 (a) 1-6 N (2), (5)

423-1 (a) 1-6 p (6), (7), (8)

423-1 (a) 1-6 Q (6), (7), (8)

Rationale for confidentiality:

(1) This information is contractual information which, if made public, "would impair the efforts of [FPL] to contract for goods or services on favorable terms." Section 366.093(3)(d), Fla. Stat. The information delineates the price per barrel FPL has paid for fuel oil for specific shipments from specific suppliers. This information would allow suppliers to compare an individual supplier's price with the market quote for that date of delivery and thereby determine the contract pricing formula between FPL and that supplier.

Contract pricing formulas generally contain two components, which are: ( 1) a markup in the market quoted price for that day; and (2) a transportation charge for delivery at an FPL chosen port of delivery. Discounts and quality adjustment components of fuel price contract formulas are discussed in paragraphs 3 and 4. Disclosure of the invoice price would allow suppliers to determine the contract price formula of their competitors. The knowledge of others' prices (i.e., contract formulas) among fuel oil suppliers is reasonably likely to cause the suppliers to converge on a target price, or to fo llow a price leader, effectively eliminating

Attacbment C Docket No. 20170001-EI

any opportunity for a major buyer like FPL to obtain price concessions from any one supplier. The end result is reasonably likely to be increased fuel oil prices and therefore increased electric rates.

(2) The contract data found in Columns I through N are an algebraic function of Column H. That is, the publication of these Colwnns together, or independently, could allow a supplier to derive the invoice price of oil.

(3) If FPL fuel contracts provide for an early payment incentive in the form of a discount from the invoice price, the existence and amount of such discount is confidential for the reasons stated in paragraph (1) relative to price concessions.

(4) For fuel that does not meet contract requirements, FPL may reject the shipment, or accept the shipment and apply a quality adjustment. The amount of the quality adjustment is, in effect, a pricing term which is as important as the price itself and is therefore confidential for the reasons stated in paragraph (1) relative to price concessions.

(5) Column N is as important asH from a confidentiality standpoint because of the relatively few times that there are quality or discount adjustments. That is, Column N will equal Column H most of the time. Consequently, Column N needs to be protected for the same reasons as set forth in paragraph (1).

(6) Column R is used to mask the delivered price of fuel such that the invoice or effective price of fuel cannot be determined. Columns P and Q are algebraic variables of Column R. Consequently, disclosure of Columns P and Q would allow a supplier to calculate the invoice or effective purchase price of oil (Columns Hand N) by subtracting these columnar variables from Column R.

(7) Terminaling and transportation services in Florida tend to have the same, if not more severe, oligopolistic attributes of fuel oil suppliers. Due to the small demand in Florida for both of these services, market entry is difficult. In instances in which FPL has attempted to determine the level of interest in bidding either or both of these services, FPL has found only a very few qualified parties with such an interest. Consequently, disclosure of these contract data is reasonably likely to result in increased prices for terminaling and transportation services.

(8) Petroleum inspection services also have the market characteristics of an oligopoly. Due to the limited number of fuel terminal operations, there are correspondingly few requirements for fuel inspection services. In FPL' s last bidding process for petroleum inspection services, only six qualified bidders were found for FPL' s bid solicitations. Consequently, disclosure of these contract data is reasonably likely to result in increased prices for petroleum inspection services.

2

Attachment C Docket No. 20170001-El

Justification for Confidentiality for St. Johns River Power Park (S.JRRP) Report of April 2017:

FORM LINE(S) COLUMNS RATIONALE

423-2

423-2 1-2

Rationale for Confidentiality:

G,H

H

(1)

(2)

(1) Disclosure of the effective purchase price "would impair the efforts of (JEA, acting on its own behalf and as agent for FPL] to contract for goods or services [at the St. Johns River Power Park (SJRPP)] on favorable terms." Section 366.093(3)(d), Fla. Stat. The data informs other potential coal suppliers as to the price SJRPP is paying for coal. Disclosure of this information, which is particularly sensitive given SJRPP's reliance on long term contracts with fixed price provisions or short term spot transactions, could adversely affect FPL's interests in subsequent solicitations for coal and/or in negotiating coal supply agreements. JEA maintains this information as confidential pursuant to section 163.01 (15)(m), Fla. Stat. Additionally, providing the purchase price would enable one to ascertain the total transportation charges in Column 1-1 by subtracting the effective purchase price from the delivered price at the transfer facility, shown in Column I.

(2) Disclosure of the total transportation cost "would impair the efforts of[JEA acting on its own behalf and as agent for FPL] to contract for goods or services [at SJRPP] on favorable terms." Section 366.093(3)(d), Fla Stat. Moreover, the service provider itself typically designates the transportation costs in the contract as confidential. JEA maintains this information as confidential pursuant to section 163.01 ( 15)(m), Fla. Stat. Further, disclosure of this information would enable potential coal suppliers to calculate Column G which FPL seeks to protect by subtracting Column H from Column I.

J ustification for Confidentiality for St. Johns River Power Park (SJRRP) Report of April 2017:


423-2(a) F (1)

423-2(a) H (1)

3

Attachment C Docket No. 201 70001 -EI

423-2(a)

423-2(a)


1 J

1 L

(1)

(2)

( 1) The information presented in these columns are algebraic derivations of the information in column L that FPL seeks to protect.

(2) Disclosure of the effective purchase price "would impai r the efforts of [JEA, acting on its own behalf and as agent for FPL] to contract fo r goods or services [at the St. Johns River Power Park (SJRPP)] on favorable terms." Section 366.093(3)(d), Fla. Stat. The data informs other potential coal suppliers as to the price SJRPP is paying for coal. Disclosure of this information could adversely affect FPL's interests in subsequent solicitations for coal and/or in negotiating coal supply agreements. JEA maintains this information as confidential pursuant to section 163.01(15)(m), Fla. Stat. Additionally, providing the purchase price would enable one to ascertain the total transportation charges in Column H on Form 423-2, which FPL seeks to protect, by subtracting the effective purchase price from the delivered price at the transfer faci lity shown in Column I on Form 423-2.

Justification for Confidentiality for St. Johns River Power Park (SJRRP) Report of April 2017:

FORM

423-2(b)

423-2(b)

423-2(b)

LJNE(S)


COLUMN RATIONALE

G (1)

I (2)

p (2)

(1) Disclosure of the effective purchase price "would impair the efforts of [JEA, acting on its own behalf and as agent for FPL] to contract for goods or services [at the St. Johns River Power Park (SJRPP)] on favorable terms." Section 366.093(3)(d), Fla. Stat. The data informs other potential coal suppliers as to the price SJRPP is paying for coal. Disclosure of this information, which is particularly sensitive given SJRPP's reliance on long term contracts with fixed price provisions or short term spot transactions, could adversely affect FPL's interests in subsequent solicitations for coal and/or in negotiating coal supply agreements. JEA maintains this information as confidential pursuant to section 163.01(15)(m), Fla. Stat. Additionally, providing the purchase price would enable one to

4

Attachment C Docket No. 20170001 -El

ascertain the total transportation charges in Column P, which FPL seeks to protect, by subtracting the effective purchase price from the delivered price at the transfer facility shown in Column Q.

(2) Disclosure of the total transportation cost "would impair the efforts of [ JEA acting on its own behalf and as agent for FPL] to contract for goods or services [at SJRPP] on favorable terms." Section 366.093(3)(d), Fla Stat. Moreover, the service provider itself typically designates the transportation costs in the contract as confidential. JEA maintains this information as confidential pursuant to section 1 63.01(15)(m), Fla. Stat. Further, disclosure of this information would enable potential coal suppliers to calculate Column G whichFPL seeks to protect, by subtracting Column P from Column Q.

Justification for Confidentiality for R.W. Scherer (Plant Scherer) Report of March 2017:

FORM LJNE (S) COLUMNS RATIONALE

423-2 1-3 G, H (1)


(1) On Apri l 1, 2010, FPL was contacted by the BNSF Railway, which transports coal to Plant Scherer, concerning FPL' s disclosure of BNSF transportation rate information on FPL's Form 423 filing. BNSF has asserted that the transportation rate information is confidential pursuant to its Rail Transportation Agreement BNSF-C-12339 with Georgia Power Company ("GPC") and that FPL is obligated to maintain the confidentiality of that infonnation. Accordingly, FPL is designating as confidential certain information in the Form 423 filing that, by itself or in conjunction with other information in the filing, would reveal publicly BNSF transportation rate information. FPL argues that this infonnation is confidential under Sections 366.093(3)(d) and 366.093(3)(e), Fla. Stat. , because its disclosure would "impair the efforts of [GPC, as agent for FPL] to contract fo r goods and services on favorable terms" and would " impair the competitive business of' BNSF.

Justification for Confidentiality for R.W. Scherer (Plant Scherer) Report of March 2017:


423-2(a) ] -3 F, H, 1, L (1 )

5

Attachment C Oockct No. 20170001-El


( 1) On April 1, 2010, FPL was contacted by the BNSF Railway, which transports coal to Plant Scherer, concerning FPL's disclosure of BNSF transportation rate information on FPL's Form 423 filing. BNSF has asserted that the transportation rate information is confidential pursuant to its Rail Transportation Agreement BNSF-C-12339 with Georgia Power Company ("GPC") and that FPL is obligated to maintain the confidentiality of that information. Accordingly, FPL is designating as confidential certain infonnation in the Form 423 filing that, by itself or in conjunction with other information in the filing, would reveal publicly BNSF transportation rate information. FPL argues that this information is confidential under Sections 366.093(3)(d) and 366.093(3)(e), Fla. Stat. , because its disclosure would " impair the efforts of[GPC, as agent for FPL] to contract for goods and services on favorable terms" and would "impair the competitive business of' BNSF.

Justification for Confidentiality for R. W. Scherer (Plant Scherer ) Report of March 2017:


423-2(b) 1-3 G, 1, P (1)


(1) On April I, 2010, FPL was contacted by the BNSF Rai lway, which transports coal to Plant Scherer, concerning FPL's disclosure of BNSF transportation rate information on FPL's Fom1 423 filing. BNSF has asserted that the transportation rate information is confidential pursuant to its Rail Transportation Agreement BNSF-C-12339 with Georgia Power Company ("GPC") and that FPL is obligated to maintain the confidentiality of that infonnation. Accordingly, FPL is designating.as confidential certain information in the Fonn 423 filing that, by itself or in conjunction with other information in the filing, would reveal publicly BNSF transportation rate information. FPL argues that this information is confidential under Sections 366.093(3)(d) and 366.093(3)(e), Fla. Stat. , because its disclosure would "impair the efforts of[GPC, as agent for FPL] to contract for goods and services on favorable terms" and would "impair the competitive business of' BNSF.

6


Justification for Confidentiality for Florida Power & Light Company Report of May 2017:


423-1 (a) 1-3 H (1)

423-1 (a) 1-3 I (2)

423-1 (a) 1-3 J (2), (3)

423-1 (a) 1-3 K (2)

423-1 (a) 1-3 L (2)

423-l(a) 1-3 M (2), (4)

423-l(a) 1-3 N (2), (5)

423-1 (a) 1-3 p (6), (7), (8)

423-1 (a) 1-3 Q (6), (7), (8)


(2) This information is contractual information wruch, if made public, "would impair the efforts of [FPL] to contract for goods or services on favorable terms." Section 366.093(3)(d), Fla. Stat. The information delineates the price per barrel FPL has paid for fuel oil for specific shipments from specific suppliers. This information would allow suppliers to compare an individual supplier's price with the market quote for that date of delivery and thereby determine the contract pricing formula between FPL and that supplier.

Contract pricing formulas generally contain two components, wruch are: (1) a markup in the market quoted price for that day; and (2) a transportation charge for delivery at an FPL chosen port of delivery. Discounts and quality adjustment components of fuel price contract formulas are discussed in paragraphs 3 and 4. Disclosure of the invoice price would allow suppliers to determine the contract price formula of their competitors. The knowledge of others' prices (i.e., contract fo rmulas) among fuel oil suppliers is reasonably likely to cause the suppliers to converge on a target price, or to follow a price leader, effectively eliminating any opportunity for a major buyer like FPL to obtain price concessions from any one

7

Attachment C Docket No. 20170001- EI

supplier. The end result is reasonably likely to be increased fuel oil prices and therefore increased electric rates.

(2) The contract data found in Columns I through N are an algebraic function of Column H. That is, the publication of these Columns together, or independently, could allow a supplier to derive the invoice price of oil.


(4) For fuel that does not meet contract requirements, FPL may reject the shipment, or accept the shipment and apply a quality adjustment. The amount of the quality adjustment is, in effect, a pricing term which is as important as the price itself and is therefore confidential for the reasons stated in paragraph (l) relative to price concessions.

(5) Column N is as important as H from a confidentiality standpoint because of the relatively few times that there are quality or discount adjustments. That is, Column N will equal Column H most of the time. Consequently, Column N needs to be protected for the same reasons as set forth in paragraph (I).

(6) Column R is used to mask the delivered price of fuel such that the invoice or effective price of fuel cannot be determined. Columns P and Q are algebraic variables of Column R. Consequently, disclosure of Columns P and Q would allow a supplier to calculate the invoice or effective purchase price of oil (Columns Hand N) by subtracting these columnar variables from Column R.

(9) Terminaling and transportation services in Florida tend to have the same, if not more severe, oligopolistic attributes of fuel oil suppliers. Due to the small demand in Florida for both of these services, market entry is difficult. In instances in which FPL has attempted to determine the level of interest in bidding either or both of these services, FPL bas found only a very few qualified parties with such an interest. Consequently, disclosure of these contract data is reasonably likely to result in increased prices for terminating and transportation services.

( 1 0) Petroleum inspection services also have the market characteristics of an oligopoly. Due to the limited number of fuel terminal operations, there are correspondingly few requirements for fuel inspection services. In FPL's last bidding process for petroleum inspection services, only six qualified bidders were found for FPL's bid solicitations. Consequently, disclosure of these contract data is reasonably likely to result in increased prices for petroleum inspection services.

8


Justification for Confidentiality for St. Johns River Power Park (SJRRP) Report of May 2017:


423-2 1

423-2 1


G, H

H

(1)

(2)

(3) Disclosure of the effective purchase price "would impair the efforts of (JEA, acting on its own behalf and as agent for FPL] to contract for goods or services [at the St. Johns River Power Park (SJRPP)] on favorable terms." Section 366.093(3)(d), Fla. Stat. The data informs other potential coal suppliers as to the price SJRPP is paying for coal. Disclosure of this information, which is particularly sensitive given SJRPP's reliance on long term contracts with fixed price provisions or short term spot transactions, could adversely affect FPL's interests in subsequent solicitations for coal and/or in negotiating coal supply agreements. JEA maintains this information as confidential pursuant to section 163.01 (15)(m), Fla. Stat. Additionally, providing the purchase price wouJd enable one to ascertain the totaJ transportation charges in Column H by subtracting the effective purchase price from the delivered price at the transfer facility, shown in Column I.

( 4) Disclosure of the total transportation cost "would impair the efforts of[JEA acting on its own behalf and as agent for FPL] to contract for goods or services [at SJRPP] on favorable terms." Section 366.093(3)(d), Fla Stat. Moreover, the service provider itself typically designates the transportation costs in the contract as confidential. JEA maintains this infonnation as confidential pursuant to section 163.01 (15)(m), Fla. Stat. Further, disclosure of this infom1ation would enable potential coal suppliers to calculate Column G which FPL seeks to protect by subtracting Column H from Column I.



423-2(a) F (1)

423-2(a) 1 H (1)

9

Attachment C Docket No. 20 170001-Ef

423-2(a)

423-2(a)


l J

L

(1)

(2)

(I) The infom1ation presented in these columns are algebraic derivations of the information in column L that FPL seeks to protect.

(2) Disclosure of the effective purchase price "would impair the etrorts of [JEA, acting on its own behalf and as agent for FPL] to contract for goods or services [at the St. Johns River Power Park (SJRPP)] on favorable terms." Section 366.093(3)(d), Fla. Stat. The data informs other potential coal suppliers as to the price SJRPP is paying for coal. Disclosure of this information could adversely affect FPL's interests in subsequent solicitations for coal and/or in negotiating coal supply agreements. JEA maintains this infom1ation as confidential pursuant to section 163.01(15)(m), Fla. Stat. Additionally, providing the purchase price would enable one to ascertain the total transportation charges in Column H on Form 423-2, which FPL seeks to protect, by subtracting the effective purchase price from the delivered price at the transfer facility shown in Column I on Form 423-2.


FORM

423-2(b)

423-2(b)

423-2(b)

LINE(S)


COLUMN

G

I

p

RATIONALE

(1)

(2)

(2)

(3) Disclosure of the effective purchase price "would impair the efforts of [ JEA, acting on its own behalf and as agent for FPL] to contract for goods or services [at the St. Johns River Power Park (SJRPP)] on favorable terms." Section 366.093(3)(d), Fla. Stat. The data informs other potential coal suppliers as to the price SJRPP is paying for coal. Disclosure of this information, which is particularly sensitive given SJRPP's reliance on long term contracts with fixed price provisions or short tenn spot transactions, could adversely affect FPUs interests in subsequent solicitations for coal and/or in negotiating coal supply agreements. JEA maintains this information as confidential pursuant to section 163.01(15)(m), Fla. Stat. Additionally, providing the purchase price :would enable one to

10


ascertain the total transportation charges in Column P, which FPL seeks to protect, by subtracting the effective purchase price from the delivered price at the transfer facility shown in Column Q.

( 4) Disclosure of the total transportation cost "would impair the efforts of [JEA acting on its own behalf and as agent for FPL] to contract for goods or services [at SJRPP] on favorable terms." Section 366.093(3)(d), Fla Stat. Moreover, the service provider itself typically designates the transportation costs in the contract as confidential. JEA maintains this information as confidential pursuant to section 163.01 (15)(m), Fla. Stat. Further, disclosure of this information would enable potential coal suppliers to calculate Column G which FPL seeks to protect, by subtracting Column P from Column Q.

Justification for Confidentiality for R .W. Scherer (Plant Scherer) Report of April 2017:


423-2 1-3 G, H (1)


(1) On April 1, 2010, FPL was contacted by the BNSF Railway, which transports coal to Plant Scherer, concerning FPL's disclosure of BNSF transportation rate information on FPL's Form 423 filing. BNSF has asserted that the transportation rate information is confidential pursuant to its Rai l Transportation Agreement BNSF-C-12339 with Georgia Power Company ("GPC") and that FPL is obligated to maintain the confidential ity of that information. Accordingly, FPL is designating as confidential certain information in the Form 423 filing that, by itself or in conjunction with other information in the filing, would reveal publicly BNSF transportation rate information. FPL argues that this information is confidential under Sections 366.093(3)(d) and 366.093(3)(e), Fla. Stat., because its disclosure would " impair the efforts of[GPC, as agent for FPL] to contract for goods and services on favorable terms" and would " impair the competitive business of' BNSF.

Justification for Confidentiality for R.W. Scherer (Plant Scherer) Report of April2017:


423-2(a) 1-3 F, H, J, L (I)

11

Attachment C Docket No. 20170001-EJ


( l) On April l , 20 I 0, FPL was contacted by the BNSF Railway, which transports coal to Plant Scherer, concerning FPL's disclosure of BNSF transportation rate information on FPL' s Form 423 filing. BNSF has asserted that the transportation rate information is confidential pursuant to its Rai I Transportation Agreement BN SF -C- I 23 3 9 with Georgia Power Company ("GPC") and that FPL is obligated to maintain the confidentiality of that information. Accordingly, FPL is designating as confidential certain information in the Form 423 filing that, by itself or in conjunction with other information in the filing, would reveal publicly BNSF transportation rate information. FPL argues that this infonnation is confidential under Sections 366.093(3)(d) and 366.093(3)(e), Fla. Stat., because its disclosure would "impair the efforts of[GPC, as agent for FPL] to contract for goods and services on favorable terms" and would "impair the competitive business of'' BNSf.

Justification for Confidentiality for R.W. Scherer (Plant Scherer) Report of April 2017:


423-2(b) 1-3 G, I, P (1)


(1) On April l , 2010, FPL was contacted by the BNSF Railway, which transports coal to Plant Scherer, concerning FPL 's disclosure of BNSF transportation rate information on FPL's Form 423 fi ling. BNSF has asserted that the transportation rate information is confidential pursuant to its Rail Transportation AgreementBNSF-C-12339 with Georgia Power Company ("GPC") and that FPL is obligated to maintain the confidentiality of that information. Accordingly, FPL is designating as confidential certain infonnation !n the Form 423 filing that, by itself or in conjunction with other information in the filing, would reveal publicly BNSF transportation rate information. FPL argues that this information is confidential under Sections 366.093(3)(d) and 366.093(3)(e), Fla. Stat., because its disclosure would "impair the efforts of[GPC, as agent for FPL] to contract for goods and services on favorable terms" and would " impair the competitive business of' BNSF.

12

Attachment C Docket No. 20170001 -EI

Justification for Confidentiality for Florida Power & Light Company Report of June 2017:


423-1 (a) 1-6 H (I)

423-1 (a) 1-6 I (2)

423-1 (a) 1-6 J (2), (3)

423-1 (a) 1-6 K (2)

423-1 (a) 1-6 L (2)

423-1 (a) 1-6 M (2), (4)

423-1 (a) 1-6 N (2), (5)

423-1 (a) 1-6 p (6), (7), (8)

423-1 (a) 1-6 Q (6), (7), (8)


(3) This infom1ation is contractual information which, if made public, "would impair the efforts of [FPL] to contract for goods or services on favorable terms." Section 366.093(3)( d), Fla. Stat. The information delineates the price per barrel FPL has paid for fuel oil for specific shipments from specific suppliers. This information would allow suppliers to compare an individual supplier's price with the market quote for that date of delivery and thereby determine the contract pricing formula between FPL and that supplier.

Contract pricing formulas generally contain two components, which are: ( 1) a markup in the market quoted price for that day; and (2) a transportation charge for delivery at an FPL chosen port of delivery. Discounts and quality adjustment components of fuel price contract formulas are discussed in paragraphs 3 and 4. Disclosure of the invoice price would allow suppliers to determine the contract price formula of their competitors. The knowledge of others' prices (i.e., contract formulas) among fuel oil suppliers is reasonably likely to cause the suppliers to converge on a target price, or to follow a price leader, effectively eliminating any opportunity for a major buyer like FPL to obtain price concessions from any one supplier. The end result is reasonably likely to be increased fuel oil prices and therefore increased electric rates.

13

Attachment C Docket No. 20 170001 -ET

(2) The contract data found in Columns I through N are an algebraic function of Column H. That is, the publication of these Columns together, or independently, could allow a supplier to derive the invoice price of oil.


(4) For fuel that does not meet contract requirements, FPL may reject the shipment, or accept the shipment and apply a quality adjustment. The amount of the quality adjustment is, in effect, a pricing term which is as important as the price itself and is therefore confidential for the reasons stated in paragraph (1) relative to price concessions.

(5) Column N is as important asH from a confidentiality standpoint because of the relatively few times that there are quality or discount adjustments. That is, Column N wi11 equal Column H most of the time. Consequently, Column N needs to be protected for the same reasons as set forth in paragraph ( 1 ).

(6) Column R is used to mask the delivered price of fuel such that the invoice or effective price of fuel cannot be determined. Columns P and Q are algebraic variables of Column R. Consequently, disclosure of Columns P and Q would al low a suppLier to calculate the invoice or effective purchase price of oil (Columns Hand N) by subtracting these columnar variables from Column R.

( 11) Tenninaling and transportation services in Florida tend to have the same, if not more severe, oligopolistic attributes of fuel oil suppliers. Due to the small demand in Florida for both of these services, market entry is difficult. In instances in which FPL has attempted to determine the level of interest in bidding either or both of these services, FPL has found only a very few qualified parties with such an interest. Consequentl y, disclosure of these contract data is reasonably likely to result in increased prices for terminaling and transportation services.

(12) Petroleum inspection services also have the market characteristics of an oligopoly. Due to the limited nwnber of fuel terminal operations, there are correspondingly few requirements for fuel inspection services. In FPL's last bidding process for petroleum inspection services, only six qual ified bidders were found for FPL's bid solicitations. Consequently, disclosure of these contract data is reasonably likely to result in increased prices for petroleum inspection services.

14

Attachment C Docket No. 20170001-EI

Justification for Confidentiality for St. Johns River Power Park (SJRRP) Report of J une 2017:


423-2

423-2


G,H

H

(1)

(2)

(5) Disclosure of the effective purchase price "would impair the efforts of [JEA, acting on its own behalf and as agent for FPL] to contract for goods or services [at the St. Jolms River Power Park (SJRPP)] on favorable terms." Section 366.093(3)(d), Fla. Stat. The data informs other potential coal suppliers as to the price SJRPP is paying for coal. Disclosure of this information, which is particularly sensitive given SJRPP's reliance on long term contracts with fixed price provisions or short term spot transactions, could adversely affect FPL's interests in subsequent solicitations for coal and/or in negotiating coal supply agreements. JEA maintains this information as confidential pursuant to section 163.01(15)(m}, Fla. Stat. Additionally, providing the purchase price would enable one to ascertain the total transportation charges in Column H by subtracting the effective purchase price from the delivered price at the transfer facility, shown in Column I.

( 6) Disclosure of the total transportation cost "would impair the efforts of [JEA acting on its own behalf and as agent for FPL] to contract for goods or services [at SJRPP] on favorable terms." Section 366.093(3)(d), Fla Stat. Moreover, the service provider itself typically designates the transportation costs in the contract as confidential. JEA maintains this information as confidential pursuant to section 163.01 (15)(m), Fla. Stat. Further, disclosure of this infom1ation would enable potential coal suppliers to calculate Column G which FPL seeks to protect by subtracting Column H from Column I.

Justification for Confidentiality for St. Johns River Power Park (SJRRP) Report of June 2017:

FORM

423-2(a)

423-2(a)

LINE(S) COLUMN

F

H

15

RATIONALE

(I)

(1)


423-2(a) J (1)

423-2(a) L (2)

Rationale for C onfidentiality:

( 1) The .information presented in these columns are algebraic derivations of the information in column L that FPL seeks to protect.

(2) Disclosure of the effective purchase price "would impair the efforts of [JEA, acting on its own behalf and as agent for FPL] to contract for goods or services [at the St. Johns River Power Park (SJRPP)] on favorable terms." Section 366.093(3)(d), Fla. Stat. The data informs other potential coal suppliers as to the price SJRPP is paying for coal. Disclosure of this information could adversely affect FPL's interests in subsequent solicitations for coal and/or in negotiating coal supply agreements. JEA maintains this information as confidential pursuant to section 163.01(15)(m), Fla. Stat. Additionally, providing the purchase price would enable one to ascertain the total transportation charges in Column H on Form 423-2, which FPL seeks to protect, by subtracting the effective purchase price from the delivered price at the transfer facility shown in Column I on Form 423-2.

Justifica tion for Confidentiality for St. Johns River Power Park (SJRRP) Report of J une 2017:


423-2(b) G (1)

423-2(b) 1 I (2)

423-2(b) p (2)


(5) Disclosure of the effective purchase price "would impair the efforts of [JEA, acting on its own behalf and as agent for FPL] to contract for goods or services [at the St. Johns River Power Park (SJRPP)] on favorable terms." Section 366.093(3)(d), Fla. Stat The data informs other potential coal suppliers as to the price SJRPP is paying for coal. Disclosure of this information, which is particularly sensitive given SJRPP's reliance on long term contracts with fixed price provisions or short term spot transactions, could adversely affect FPL's interests in subsequent solicitations for coal and/or in negotiating coal supply agreements. JEA maintains this information as confidential pursuant to section 163.01(15)(m), Fla. Stat. Additionally, providing the purchase price would enable one to

16


ascertain the to tal transportation charges in Column P, which FPL seeks to protect, by subtracting the effective purchase price from the delivered price at the transfer facility shown in Column Q.

(6) Disclosure of the total transportation cost " would impair the efforts of [ JEA acting on its own behalf and as agent for FPL] to contract for goods or services [at SJRPP] on favorable terms." Section 366.093(3)(d), Fla Stat. Moreover, the service provider itself typically designates the transportation costs in the contract as confidential. JEA maintains this information as confidential pursuant to section 163.01 (15)(m), Fla. Stat. Further, disclosure of this information would enable potential coal suppliers to calculate Column G which FPL seeks to protect, by subtracting Column P from Column Q.

Justification for Confidentiality for R.W. Scherer (Plant Scherer) Report of May 2017:


423-2 1-4 G, H (I)


( 1) On April I, 20 I 0, FPL was contacted by the BNSF Railway, which transports coal to Plant Scherer, concerning FPL's disclosure of BNSF transportation rate information on FPL's Form 423 filing. BNSF has asserted that the transportation rate information is confidential pursuant to its Rail Transportation Agreement BNSF-C-12339 with Georgia Power Company ("GPC") and that FPL is obligated to maintain the confidentiality of that information. Accordingly, FPL is designating as confidential certain information in the Form 423 filing that, by itself or in conjunction with other information in the fi li ng, would reveal publicly BNSF transportation rate information. FPL argues that this information is confidential under Sections 366.093(3)(d) and 366.093(3)(e), Fla. Stat., because its di sclosure would "impair the efforts of [GPC, as agent for FPL] to contract for goods and services on favorable terms'" and would "impair the competitive business of' BNSF.



423-2(a) 1-4 F, H, J, L (1)

17



(1) On April! , 2010, FPL was contacted by the BNSF Railway, which transports coal to Plant Scherer, concerning FPL's disclosure of BNSF transportation rate information on FPL's Form 423 filing. BNSF has asserted that the transportation rate information is confidential pursuant to its Rail Transportation Agreement BNSF-C-12339 with Georgia Power Company ("GPC") and that FPL is obligated to maintain the confidentiality of that information. Accordingly, FPL is designating as confidential certain information in the Form 423 filing that, by itself or in conjunction with other information in the filing, would reveal publicly BNSF transportation rate information. FPL argues that tlus information is confidential under Sections 366.093(3)(d) and 366.093(3)(c), Fla. Stat., because its di sclosure would " impair the efforts of [GPC, as agent for FPL] to contract for goods and services on favorable terms" and would " impair the competit ive business of' BNSF.



423-2(b) 1-4 G, 1, P (1)


( 1) On April l , 20 I 0, FPL was contacted by the BNSF Rai lway, which transports coal to Plant Scherer, concerning FPL's disclosure of BNSF transportation rate information on FPL's Form 423 filing. BNSF has asserted that the transportation rate information is confidential pursuant to its Rail Transportation Agreement BNSF-C-12339 with Georgia Power Company ("GPC") and that FPL is obligated to maintain the confidentiality of that information. Accordingly, FPL is designating as confidential certain information in the Form 423 filing that, by itself or in conjunction with other information in the filing, would reveal publicly BNSF transportation rate information. FPL argues that this information is confidential under Sections 366.093(3)(d) and 366.093(3)(e), Fla Stat., because its disclosure would " impair the efforts of [GPC, as agent for FPL] to contract for goods and services on favorable terms" and would " impair the competitive business of' BNSF.

6071003

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john t. butler - psc.state.fl.us · pdf filejohn t. butler assistant general counsel - regu...

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