Discussion
of Issues
Issue 1:
Should Seminole Waterworks, Inc.’s application for a
grandfather water certificate in Leon County be acknowledged?
Recommendation:
Yes. Seminole’s application should be acknowledged and the
Utility should be issued Certificate No. 672-W, effective June 20, 2017, to
serve the territory described in Attachment A. The resultant order should serve
as Seminole’s certificate and should be retained by the Utility. (M. Watts)
Staff Analysis:
The Utility’s application for a certificate under
grandfather rights to provide water service in Leon County is in compliance
with Section 367.171(2)(b), F.S., and Rule 25-30.035, F.A.C. The application
contains warranty deeds as proof of ownership of the land on which the Utility’s
facilities are located, accurate territory descriptions, and adequate service
territory and system maps. The territory descriptions are provided in
Attachment A.
As stated in
the case background, the area served by Seminole consists of six separate water
systems located in Leon County. The Utility does not currently have any
outstanding citations, violations, or consent orders on file with the Florida Department
of Environmental Protection.
The Utility
submitted its 2017 Annual Report pursuant to Rule 25-30.110, F.A.C., and is
aware of its obligation to remit regulatory assessment fees (RAFs) in
accordance with Order No. PSC-2018-0075-PAA-WU, issued February 12, 2018, in
the instant docket, and pursuant to Rule 25-30.120, F.A.C. In addition, the
Utility is aware that it must maintain its books and records according to the
National Association of Regulatory Commissioners’ Uniform System of Accounts.
Based on the above, staff recommends that Seminole be
granted Certificate No. 672-W to serve the territory described in Attachment A.
The resultant order should serve as Seminole’s certificate and should be
retained by the Utility.
Issue 2:
What rates and charges should be approved for Seminole
Waterworks, Inc.?
Recommendation:
The Utility’s monthly service rates and convenience charge
that were in effect when Leon County transferred jurisdiction to the
Commission, shown on Schedule No. 1, should be approved. The rates should be
effective for services rendered on or after the stamped approval date on the
tariff pursuant to Rule 25-30.475, F.A.C. The Utility should be required to
charge the approved rates and convenience charge until authorized to change
them by this Commission in a subsequent proceeding. (Friedrich)
Staff Analysis:
According
to its application, Seminole’s current rates were established December 1, 2015,
by Rowe Utilities, Inc., and Seminole has been charging the same rates since
acquisition. The Utility’s current monthly service rates include a base
facility charge and inclining block gallonage charges. When Seminole acquired
the Utility from Rowe Utilities, Inc. in February 2016, it implemented a
convenience charge of $2.60 consistent with other utilities regulated by this
Commission that are managed by U.S. Water. Staff
believes the Utility’s current monthly rates and convenience charge are
reasonable and should be approved.
Additionally,
within its application, the Utility indicated that it currently has
miscellaneous service, late payment, and non-sufficient funds (NSF) charges in
place, as well as customer deposits. However, some of these charges and
deposits do not appear to be based on cost or customer usage consistent with
Commission practice. Staff’s recommendations with respect to these charges and
deposits are discussed in Issues 3 through 6.
Based on the above, the Utility’s
monthly service rates and convenience charge that were in effect when Leon
County transferred jurisdiction to the Commission, shown on Schedule No. 1,
should be approved. The rates should be effective for services rendered on or
after the stamped approval date on the tariff pursuant to Rule 25-30.475,
F.A.C. The Utility should be required to charge the approved rates until
authorized to change them by this Commission in a subsequent proceeding.
Issue 3:
Should the miscellaneous service charges requested by
Seminole Waterworks, Inc. be approved?
Recommendation:
Yes. The Utility’s requested miscellaneous service charges should be
approved and are identified in Table 3-5. The charges should be effective on or
after the stamped approval date on the tariff pursuant to Rule 25-30.475,
F.A.C. In addition, the approved charges should not be implemented until staff
has approved the proposed customer notice and the notice has been received by
the customers. The Utility should provide proof of the date notice was given
within 10 days of the date of the notice. (Friedrich)
Staff
Analysis:
Seminole’s
current and requested miscellaneous service charges are displayed in Table 3-5.
The Utility’s current miscellaneous service charges were in place at the time
of acquisition. Within its application, the Utility acknowledged that some of
its existing miscellaneous service charges are higher than comparable
utilities. As a result, Seminole indicated that it is not opposed to revising
these charges to be consistent with Commission practice and the Utility’s
sister utilities. Section 367.091, F.S., authorizes the Commission to change
miscellaneous service charges. Seminole’s request was accompanied by its reason
for requesting the charges as well as the cost justification required by
Section 367.091(6), F.S.
The cost justification provided
reflects the same labor and transportation costs relied on to set miscellaneous
service charges for the Utility’s sister companies.[3]
The calculations for the Utility’s requested miscellaneous service charges are
shown in Tables 3-1 through 3-4. Table 3-5 displays the Utility’s current and
requested miscellaneous service charges rounded up to the nearest tenth.
Initial Connection
Charge
The initial connection charge is levied for
service initiation for new customers. A Seminole representative makes one trip
when performing the service of an initial connection. Based on labor and
transportation to and from the service territory, staff recommends initial
connection charges of $31.10 for normal hours and $36.20 for after hours.
Staff’s calculations are shown below in Table 3-1.
Table 3-1
Initial
Connection Charge Calculation
|
Activity
|
Normal Hours Cost
|
Activity
|
After
Hours Cost
|
|
Administrative Labor
($28/hr x1/4hr)
|
$7.00
|
Administrative Labor
($28/hr x1/4hr)
|
$7.00
|
|
Field Labor
($30.42/hr x 1/3 hr)
|
$10.14
|
Field Labor
($45.63/hr x 1/3 hr)
|
$15.21
|
|
Transportation
($0.535/mile x 26 miles-to/from)
|
$13.91
|
Transportation
($0.535/mile x 26 miles-to/from)
|
$13.91
|
|
Total
|
$31.05
|
Total
|
$36.12
|
Normal
Reconnection Charge
A normal reconnection charge is levied for
the reconnection of service subsequent to a customer requested disconnection. A
normal reconnection requires two trips, which includes one to turn service off
and the other to turn service on. Staff recommends normal reconnection charges
of $57.10 for normal hours and $64.70 for after hours. Staff’s calculations are
shown below in Table 3-2.
Table 3-2
Normal
Reconnection Charge Calculation
|
Activity
|
Normal Hours Cost
|
Activity
|
After
Hours Cost
|
|
Administrative Labor
($28/hr x1/4hr x 2)
|
$14.00
|
Administrative Labor
($28/hr x1/4hr)
|
$14.00
|
|
Field Labor
($30.42/hr x 1/4 hr x 2)
|
$15.21
|
Field Labor
($45.63/hr x 1/4hr x 2)
|
$22.81
|
|
Transportation
($0.535/mile x 26 miles-to/from x 2)
|
$27.82
|
Transportation
($0.535/mile x 26 miles-to/from x 2)
|
$27.82
|
|
Total
|
$57.03
|
Total
|
$64.63
|
Violation
Reconnection Charge
The violation reconnection charge is levied
prior to reconnection of an existing customer after discontinuance of service
for cause. The service performed for violation reconnection requires two trips,
which includes one trip to turn off service and a subsequent trip to turn on
service once the violation has been remedied. Staff recommends violation
reconnection charges of $57.10 for normal hours and $64.70 for after hours.
Staff’s calculations are shown below in Table 3-3.
Table 3-3
Violation Reconnection
Charge Calculation
|
Activity
|
Normal
Hours Cost
|
Activity
|
After
Hours Cost
|
|
Administrative Labor
($28/hr x1/4hr x 2)
|
$14.00
|
Administrative Labor
($28/hr x1/4hr x 2)
|
$14.00
|
|
Field Labor
($30.42/hr x 1/4 hr x 2)
|
$15.21
|
Field Labor
($45.63hr x 1/4 hr x 2)
|
$22.81
|
|
Transportation
($0.535/mile x 26 miles-to/from) x 2
|
$27.82
|
Transportation
($0.535/mile x 26 miles-to/from) x 2
|
$27.82
|
|
Total
|
$57.03
|
Total
|
$64.63
|
Premises
Visit Charge
The premises visit charge is levied when a
service representative visits the premises at the customer’s request for
complaint resolution and the problem is found to be the customer’s
responsibility. In addition, the premises visit charge can be levied when a
service representative visits a premises for the purpose of discontinuing
service for nonpayment of a due and collectible bill, and does not discontinue
service because the customer pays the service representative or otherwise makes
satisfactory arrangements to pay the bill. A premises visit requires one trip. Staff
recommends premises visit charges of $31.10 for normal hours and $36.20 for
after hours. Staff’s calculations are shown below in Table 3-4.
Table 3-4
Premises
Visit Charge Calculation
|
Activity
|
Normal
Hours Cost
|
Activity
|
After
Hours Cost
|
|
Administrative Labor
($28.00/hr x1/4hr)
|
$7.00
|
Administrative Labor
($28.00/hr x1/4hr)
|
$7.00
|
|
Field Labor
($30.42/hr x 1/3 hr)
|
$10.14
|
Field Labor
($45.63/hr x 1/3 hr)
|
$15.21
|
|
Transportation
($0.535/mile x 26 miles-to/from)
|
$13.91
|
Transportation
($0.535/mile x 26 miles-to/from)
|
$13.91
|
|
Total
|
$31.05
|
Total
|
$36.12
|
Table 3-5
Miscellaneous Service
Charges
|
|
Current
|
Staff
Recommended
|
|
Normal
and
After
Hours
|
Normal
Hours
|
After
Hours
|
|
Initial Connection Charge
|
$50.00
|
$31.10
|
$36.20
|
|
Normal Reconnection Charge
|
$50.00
|
$57.10
|
$64.70
|
|
Violation Reconnection Charge
|
$165.00
|
$57.10
|
$64.70
|
|
Premises Visit
Charge
|
$10.00
|
$31.10
|
$36.20
|
Conclusion
Based on the above, the
Utility’s requested miscellaneous service charges should be approved and are
identified in Table 3-5 above. The charges should be effective on or after the
stamped approval date on the tariff pursuant to Rule 25-30.475, F.A.C. In
addition, the approved charges should not be implemented until staff has
approved the proposed customer notice and the notice has been received by the
customers. The Utility should provide proof of the date notice was given
no less than 10 days after the date of the notice.
Issue 4:
Should Seminole Waterworks, Inc.’s request to implement a
late payment charge of $6.50 be approved?
Recommendation:
Yes. Seminole’s request to implement a $6.50 late payment
charge should be approved. Seminole should be required to file a proposed
customer notice to reflect the Commission-approved charge. The approved charge
should be effective on or after the stamped approval date on the tariff sheet
pursuant to Rule 25-30.475(1), F.A.C. In addition, the approved charge should
not be implemented until staff has approved the proposed customer notice and
the notice has been received by customers. The Utility should provide proof of
the date notice was given no less than 10 days after the date of the notice.
(Friedrich)
Staff Analysis:
The
Utility is requesting a $6.50 late payment charge to recover the cost of
supplies, labor, and RAFs associated with processing late payment notices. The
Utility’s current late payment charge is 10 percent of the total bill owed.
However, the Utility is requesting a fixed charge for its late payment charge
consistent with Commission practice and its sister utilities managed by U.S.
Water. The purpose of this charge is not only to provide an incentive for
customers to make timely payment, thereby reducing the number of delinquent
accounts, but also to place the cost burden of processing delinquent accounts
solely upon those who are cost causers. Section 367.091, F.S.,
authorizes the Commission to establish, increase, or change a rate or charge
other than monthly rates or service availability charges.
Seminole calculated the actual
costs for its late payment charge to be $8.07. The Utility indicated that it
will take approximately 15 minutes to process each delinquent account. The
delinquent customer accounts will be processed by the administrative contract
employee with an hourly salary of $28.00, resulting in a labor cost of $7.00
($28.00 x 0.25hr). This is consistent with prior Commission decisions
where the Commission has allowed 10-15 minutes per account per month for the
administrative labor associated with processing delinquent customer accounts.[4] However, $8.07 would be the highest late payment charge amongst
all other water and wastewater utilities regulated by the Commission.
[5] Therefore, the Utility is requesting a charge of $6.50,
consistent with recent Commission decisions. The Utility’s calculation for its
requested late payment charge is shown below in Table 4-1.
Table 4-1
Late Payment Charge
|
Labor
|
$7.00
|
|
Supplies
|
$0.22
|
|
Postage
|
$0.49
|
|
Markup for RAFs
|
$0.36
|
|
Total
|
$8.07
|
Source:
Utility’s Cost Justification
Based on the above, Seminole’s request to implement a
$6.50 late payment charge should be approved. Seminole should be required to
file a proposed customer notice to reflect the Commission-approved charge. The
approved charge should be effective on or after the stamped approval date on
the tariff sheet pursuant to Rule 25-30.475(1), F.A.C. In addition, the
approved charge should not be implemented until staff has approved the proposed
customer notice and the notice
has been received by customers. The Utility should provide proof of the date
notice was given no less than 10 days after the date of the notice.
Issue 5:
Should Seminole
Waterworks, Inc. be authorized to collect NSF Charges
?
Recommendation:
Yes. Seminole should be authorized to collect NSF charges.
Staff recommends that the Utility revise its tariffs to reflect the NSF charges
currently set forth in Section 68.065, F.S. The NSF charges should be effective
on or after the stamped approval date on the tariff sheets pursuant to Rule
25-30.475(1), F.A.C. Furthermore, the charges should not be implemented until
staff has approved the proposed customer notice and the notice has been
received by customers. The Utility should provide proof of the date the notice
was given within 10 days of the date of the notice. (Friedrich)
Staff Analysis:
Seminole currently has existing NSF charges in place. However the Utility
is requesting NSF charges as set forth in Section 68.065(2), F.S. to be
consistent with Commission practice and its sister utilities managed by U.S.
Water. Section 367.091, F.S., requires rates, charges, and customer service
policies to be approved by the Commission. The Commission has authority to
establish, increase, or change a rate or charge. Staff believes that Seminole
should be authorized to collect NSF charges consistent with Section 68.065,
F.S., which allows for the assessment of charges for the collection of
worthless checks, drafts, or orders of payment. As currently set forth in
Section 68.065(2), F.S., the following NSF charges may be assessed:
1. $25, if the face value does not exceed
$50,
2. $30, if the face value exceeds $50 but
does not exceed $300,
3. $40, if the face value exceeds $300,
4. or five percent of the face amount of
the check, whichever is greater.
Approval
of NSF charges is consistent with prior Commission decisions.[6]
Furthermore, NSF charges place the cost on the cost-causer, rather than
requiring that the costs associated with the return of the NSF checks be spread
across the general body of ratepayers. As such, Seminole should be authorized
to collect NSF charges. Staff recommends that Seminole revise its tariff sheets
to reflect the NSF charges currently set forth in Section 68.065, F.S. The NSF
charges should be effective on or after the stamped approval date on the tariff
sheet pursuant to Rule 25-30.475(1), F.A.C. Furthermore, the NSF charges should
not be implemented until staff has approved the proposed customer notice and
the notice has been received by customers. The Utility should provide proof of
the date the notice was given within 10 days of the date of the notice.
Issue 6:
Should the requested initial customer deposits for
Seminole Waterworks, Inc. be approved?
Recommendation:
Yes. The appropriate initial customer deposit is $69.14 for the residential 5/8 inch x 3/4 inch meter size. The
initial customer deposit for all other residential meter sizes and all general service
meter sizes should be two times the average estimated bill. The approved
customer deposits should be effective for connections made on or after the
stamped approval date on the tariff sheets pursuant to Rule 25-30.475, F.A.C.
The Utility should be required to collect the approved initial customer
deposits until authorized to change them by the Commission in a subsequent proceeding.
(Friedrich)
Staff Analysis:
Rule
25-30.311, F.A.C., contains criteria for collecting, administering, and
refunding customer deposits. Rule 25-30.311(1), F.A.C., requires that each
company’s tariff shall contain its specific criteria for determining the amount
of initial deposits. Seminole currently has an initial customer deposit of $50.
However, this amount does not cover two months’ average bills. Customer
deposits are designed to minimize the exposure of bad debt expense for the
Utility and, ultimately, the general body of rate payers. In addition,
collection of customer deposits is consistent with one of the fundamental
principles of rate making—ensuring that the cost of providing service is
recovered from the cost causer.
Rule 25-30.311(7), F.A.C., authorizes utilities to collect new or
additional deposits from existing customers not to exceed an amount equal to
the average actual charge for water and/or wastewater service for two billing
periods for the 12-month period immediately prior to the date of notice. The
two billing periods reflect the lag time between the customer’s usage and the
Utility’s collection of the revenues associated with that usage. Commission
practice has been to set initial customer deposits equal to two months’ bills
based on the average consumption for a 12-month period for each class of
customers.[7] The
Utility indicated that the average monthly residential usage is 4,558 gallons
per customer. Therefore, the average residential monthly bill is approximately
$34.57.
Based on the above, the appropriate initial customer deposit is
$69.14 for the residential 5/8 inch x 3/4 inch meter size. The initial customer
deposit for all other residential meter sizes and all general service meter
sizes should be two times the average estimated bill. The approved customer
deposits should be effective for connections made on or after the stamped
approval date on the tariff sheets pursuant to Rule 25-30.475, F.A.C. The
Utility should be required to collect the approved initial customer deposits
until authorized to change them by the Commission in a subsequent proceeding.
Issue 7:
Should this docket be closed?
Recommendation:
If no person whose substantial interests are affected by
the proposed agency action portion of this recommendation files a protest
within 21 days of the issuance of the order, a consummating order should be
issued. The docket should remain open for staff’s verification that the revised
tariff sheets have been filed by the Utility and approved by staff. Once this
action is complete, this docket should be closed administratively. (Janjic, Crawford)
Staff Analysis:
If no person whose substantial interests are affected by
the proposed agency action portion of this recommendation files a protest
within 21 days of the issuance of the order, a consummating order should be
issued. The docket should remain open for staff’s verification that the revised
tariff sheets have been filed by the Utility and approved by staff. Once this
action is complete, this docket should be closed administratively.
DESCRIPTION OF TERRITORY
SERVED
Brewster Estates:
Commence at the Southwest corner
of Section 22 , Township 1 North, Range 1 East, Leon County, Florida, thence
run North 89° 50' 08" East 1,630.54 feet along the section line to the
Point of Beginning; then continue North 89° 50' 08" East 369.44 feet,
thence North 00° 03' 37" East 103.10 feet, continue North 00° 03' 59"
East 1,138.90 feet; thence South 89° 47' 25" East 70.96 feet , thence run
North 00° 48' 14" West 600.75 feet, thence run South 89° 28' 22" East
579.73 feet, thence run North 00° 13' 17'' East 594.69 feet, thence run North
89° 06' 29" East 43.61 feet, thence run North 03° 45' 23" West 230.41
feet, thence run North 89° 32' 05" West 208.55 feet , thence run South 00°
44' 21" West 19.24 feet, thence run North 88° 45' 44" West 392.16
feet, thence run South 10° 53' 36" West 218.20 feet, thence run North 89°
21' 44" West 397.73 feet, thence run South 00° 14' 14" West 655.39
feet, thence run North 89° 37' 07" West 1,355.00 feet, thence run South
00° 22' 53" West 316.79 feet, thence run South 89° 53' 45" East
1,356.38 feet, thence run South 00° 02' 03" West 1,478.91 feet to the
Point of Beginning.
Buck Lake Estates:
A subdivision lying in parts of
Sections 23 and 26, Township 1 North, Range 1 East, Leon County, Florida, and
lying beyond the city limits of Tallahassee, Florida.
Commence at the Southeast corner
of Section 23, Township 1 North, Range 1 East, Leon County, Florida (Point of
Beginning), and run thence North 00° 18' 00" East, 3,210.52 feet, thence
South 67° 30' 00" West, 553.22 feet, thence South 00° 18' 1.17'' West,
1,215.52 feet, thence North 89° 42' 00" West, 460.13 feet, thence South
00° 16' 30" West, 1,511.32 feet, thence South 88° 58' 49" West,
134.68 feet, thence North 89° 39' 12.56" West, 783.47 feet, thence South
00° 14' 30.82" West, 454.86 feet, thence South 89° 17' 5.08" East,
781.02 feet, thence North 84° 33' 20.21" East, 599.14 feet, thence North
76° 52' 22.72" East, 395.89 feet, thence North 78° 34' 00" East,
127.55 feet, thence North 0° 25' 53.24" East, 15.85 feet to the Point of
Beginning.
Meadow Hills:
A utility service territory
particularly described as follows: A tract or parcel of land lying in parts of
Section 26, Township 1 North, Range 1 East, Leon County, Florida and lying
beyond the City limits of Tallahassee, Florida.
Commence at the Northeast corner
of Section 26, Township 1 North, Range 1 East, Leon County, Florida, and run
South 03° 06' 34" West, 91.11 feet, to the Point of Beginning, thence
South 00° 30' 00" West, 1,219.47 feet, thence North 89° 28' 00" West,
2,291.80 feet, thence South 01° 32' 40" West, 109.24 feet, thence North
89° 11' 55" West, 398.83 feet, thence North 40° 18' 53" West, 106.49
feet, thence North 88° 44' 51" West, 157.05 feet, thence North 01° 05'
58" East, 333.84 feet, thence South 89° 13 ' 45" East, 178.45 feet,
thence North 01° 08' 23" East, 173.18 feet, thence North 89° 13' 41"
West, 179.47 feet, thence North 01° 11' 06" East, 226.34 feet, thence
North 88° 53' 54" West, 28.11 feet, thence North 15° 35' 38' West, 208.33
feet, thence North 89° 00' 13" East, 122.59 feet, thence North 03° 32'
13" West, 170.65 feet, thence South 86° 27' 50" East, 219.37 feet,
thence South 87° 09' 24" East, 266.08 feet, thence South 89° 02' 55"
East, 1,102.32 feet, thence South 88° 18' 01" East, 193.33 feet, thence
North 89° 36' 08" East, 213.07 feet, thence North 83° 48' 05" East,
208.73 feet, thence North 82° 24' 51" East, 197.62 feet, thence North 77°
12' 35" East, 213.31 feet, thence North 73° 47' 30" East, 64.90 feet,
thence North 77° 01' 59" East, 205.19 feet, thence North 89° 15' 06"
East, 20.04 feet to the Point of Beginning.
North Lake Meadows:
A subdivision located lying
within Sections 19, 20, and 29, Township 2 North, Range 1 West, Leon County,
Florida.
Commence from the Point of
Beginning being the Southeast corner of Section 19, Township 2 North, Range 1
West, Leon County, Florida, and thence South 86° 29' 21.56" West, 239.9
feet, thence North 00° 09' 38.37" West, 348.72 feet, thence North 89° 59'
21.36" West, 650.76 feet, thence North 00° 35' 41.22" East, 908.85
feet, thence North 89° 36' 43.88" East, 658.38 feet, thence North 89° 36'
5.98" East, 1,115.21 feet, thence South 04° 04' 11.91" West, 304.08
feet, thence South 03° 42' 12.80" West, 223.82 feet, thence South 1° 49'
57.68" West, 249.25 feet, thence South 00° 55' 1.01" West, 468.33
feet, thence South 41° 03' 18.72" West, 14.17 feet, thence South 86° 51'
10.45" West, 192.75 feet, thence South 87° 00' 13.46" West, 203.14
feet, thence South 87° 27' 24.86" West, 193.67 feet, thence South 89° 31'
42.52" West, 241.93 feet, thence North 00° 26' 47.13" West, 31.38
feet to the Point of Beginning.
Plantation Estates:
A subdivision located within a
portion of the East half of the East half of Section 17, Township 1 North,
Range 2 East, Leon County, Florida.
Commence at the Northeast corner
of Section 17, Township 1 North, Range 2 East, Leon County, Florida, and run
thence South 00° 17' 48" East 1,439.85 feet; thence South 80° 08' 34"
West 388.67 feet to the Point of Beginning. From said Point of Beginning
continue South 80° 08' 34" West 944.56 feet; thence South 00° 13' 48"
West 3,093.14 feet; thence South 75° 12' 50" East 63.95 feet; thence North
63° 37' 07" East 446.96 feet; thence North 00° 24' 56" East 161.70
feet; thence South 89° 49' 32" East 352.90 feet; thence South 00° 06'
43" East 133.76 feet; thence North 89° 53' 17'' East 115.16 feet; thence
South 00° 06' 09" East 99.55 feet; thence South 33° 09' 45" East 142.72 feet; thence North 89° 39' 55" East 319.32 feet; thence North 00° 00' 20" West
2,032.54 feet; thence South 89° 50' 36" West 431.26 feet; thence North 03° 17' 14" West 434.81 feet;
thence North 04° 59' 07" East 800.18 feet to the Point of
Beginning.
Sedgefield:
A utility service territory
located within Section 19, Township 1 North, Range 2 East, and Section 24,
Township l North, Range 1 East, more particularly described as follows:
Commence at the Southwest corner of Section 19, Township 1
North, Range 2 East, Leon County, Florida, and run thence North 66° 21'
25.10" East 99.21 feet to the Point of Beginning. From said Point of
Beginning run North 00° 04' 20.44" West 1,599.73 feet; thence North 89°
59' 21.00" West 9.55 feet; thence North 00° 04' 30.0" West 468.17
feet; thence South 89° 51' 19.20" West 1,071.46 feet; thence South 00° 06'
44.70" East 2,059.79 feet; thence South 89° 42' 46.55" East 1,079.61
feet to the Point of Beginning.
