Case Background
St. John’s
River Club Utility Company, LLC (SJRC or Seller) is a Class C water and
wastewater utility providing service to approximately 85 customers in the Bayou
Club development located in Putnam County. SJRC is located in the St. Johns
River Water Management District (SJRWMD). The SJRWMD has implemented district
wide irrigation water use restrictions to encourage conservation. SJRC’s 2019 Annual Report indicates gross revenues of $14,644 and
$20,529 for water and wastewater, respectively, and net operating income of
$3,437 for water and $4,818 for the wastewater system.
The Florida Public Service Commission (Commission) granted
original water and wastewater certificates to Buffalo Bluff Utilities, Inc. in
1992.[1] The Commission
approved the transfer of Buffalo Bluff Utilities, Inc. to St. John’s River
Club, L.L.C. in 2005.[2] In 2007, the
Commission approved the transfer of the system to SJRC.[3] The rates for the Utility
were last set by the Commission in a staff-assisted rate case in 2000.[4]
On November 20, 2018,
American Retirement Communities (ARC) filed an application with the Commission for the transfer of Certificate
Nos. 542-W and 470-S from SJRC to St. Johns River Estates Utilities, LLC (SJR Estates,
Buyer or Utility) in Putnam County. After discussions with staff, the Buyer
resubmitted the application in its own name instead of its parent company, ARC,
on December 10, 2018.
This recommendation
addresses the transfer of the water and wastewater systems and Certificate Nos.
542-W and 470-S, the appropriate net book value of the water and wastewater
systems for transfer purposes, and the need for an acquisition adjustment. The
Commission has jurisdiction pursuant to Section 367.071, Florida Statutes (F.S.).
Discussion
of Issues
Issue 1:
Should the transfer of Certificate Nos. 542-W and
470-S in Putnam County from St. John's River Club Utility Company, LLC to St.
Johns River Estates Utilities, LLC be approved?
Recommendation:
Yes. The transfer of the water and wastewater
systems and Certificate Nos. 542-W and 470-S is in the public interest and
should be approved effective the date of the Commission’s vote. The resultant
order should serve as the Buyer’s certificate and should be retained by the
Buyer. The existing rates and charges, except the main extension charges, should
remain in effect until a change is authorized by the Commission in a subsequent
proceeding. The tariffs reflecting the transfer should be effective for
services rendered or connections made on or after the stamped approval date on
the tariffs, pursuant to Rule 25-30.475, Florida Administrative Code (F.A.C.).
The Seller is current with respect to annual reports and regulatory assessment
fees (RAFs) through December 31, 2019. The Buyer will be responsible for filing
annual reports and paying RAFs for 2020 and all future years. (Doehling, M.
Watts, J. Blocker, Sibley)
Staff Analysis:
On November 20, 2018, ARC filed an application on
behalf of SJR Estates for the transfer of Certificate Nos. 542-W and 470-S from
SJRC to SJR Estates in Putnam County. After discussions with staff in which
staff attempted to get clarification regarding the filing, SJR Estates chose to
submit a revised application on its own behalf. The revised application was
submitted on December 10, 2018. The application is in compliance with Section
367.071, F.S., and Commission rules concerning applications for transfer of
certificates. The sale to SJR Estates occurred on August 17, 2018, contingent
upon Commission approval, pursuant to Section 367.071(1), F.S.
Noticing, Territory, and Land
Ownership
SJR Estates provided notice of the application pursuant to
Section 367.071, F.S., and Rule 25-30.030, F.A.C. No objections to the transfer
were filed, and the time for doing so has expired. The application contains a
description of the service territory which is appended to this recommendation
as Attachment A. The Utility provided a copy of a 99 year lease agreement
effective August 9, 2018, as evidence that SJR Estates has rights to long-term
use of the land upon which the water and wastewater treatment facilities are
located pursuant to Rule 25-30.037(2)(s), F.A.C.
Purchase Agreement and Financing
Pursuant to
Rule 25-30.037(2)(i), and (j), F.A.C., the application contains a statement
regarding financing and a copy of the purchase agreement, which includes the
purchase price, terms of payment and a list of the assets purchased. There are
no developer agreements, customer deposits, or
customer advances that must be disposed of regarding the transfer. According to
the purchase agreement, the total purchase price for assets is $10,000.
According to the Buyer, the sale took place on August 17, 2018, subject to
Commission approval, pursuant to Section 367.071(1), F.S.
Facility Description and
Compliance
The Utility’s water treatment plant is composed of three four-inch
wells with inline Venturi Aerators and hypo-chlorination used as the primary
form of treatment. The wastewater system consists of one lift station and an
extended aeration treatment facility with chlorinated effluent sent to two
percolation ponds. The last sanitary survey of the water treatment facility was
conducted on May 8, 2020, by the Department of Environmental Protection (DEP).
The last compliance inspection of the wastewater treatment facility was on
January 29, 2016. There were no deficiencies noted in either inspection and
both systems were determined to be in compliance with the DEP’s rules and
regulations.
Technical and Financial Ability
Pursuant to Rule 25-30.037(2)(l)
and (m), F.A.C., the application contains statements describing the technical
and financial ability of the Buyer to provide service to the proposed service
area. The application states that while the Buyer does not have experience in
the water or wastewater industry, it plans to continue to maintain the system
and will hire appropriate staff. Through its review of DEP records, staff has
verified that the same plant operator has been retained. The application also
includes financial statements supporting the financial ability of the Buyer to
provide service to the proposed service area. Based on its review, staff believes the Buyer has
demonstrated the technical and financial ability to provide service to the
existing service territory.
Rates and Charges
The
Utility’s rates and charges were last set in a staff-assisted rate case in 2000 and have remained
unchanged. Rule 25-9.044(1), F.A.C., provides that, in the case of a
change of ownership or control of a utility, the rates, classifications, and
regulations of the former owner must continue unless authorized to change by
the Commission. As discussed in Issue 3, due to the level of net contribution
in aid of construction (CIAC) to net plant, staff is recommending that the main
extension charge for both water and wastewater be discontinued. Therefore,
staff recommends that the Utility’s existing rates and charges, except the main
extension charges, remain in effect until a change is authorized by this Commission and are shown on Schedule No. 4.
Regulatory Assessment Fees and
Annual Reports
Staff has verified that the Seller is current with respect
to annual reports and RAFs through December 31, 2019. The Buyer will be
responsible for filing annual reports and paying RAFs for 2020 and all future
years.
Conclusion
Based on the foregoing, staff recommends the transfer of
the water and wastewater systems and Certificate Nos. 542-W and 470-S is in the
public interest and should be approved effective the date of the Commission’s
vote. The resultant order should serve as the Buyer’s certificate and should be
retained by the Buyer. The existing rates and charges, except the main extension charges, should
remain in effect until a change is authorized by the Commission in a subsequent
proceeding. The tariffs reflecting the transfer should be effective for
services rendered or connections made on or after the stamped approval date on
the tariffs, pursuant to Rule 25-30.475, F.A.C. The seller is current with
respect to annual reports and RAFs through December 31, 2019. The Buyer will be
responsible for filing annual reports and paying RAFs for 2020 and all future
years.
Issue 2:
What is the appropriate
net book value for the SJR Estates systems for transfer purposes and should an
acquisition adjustment be approved?
Recommendation:
The net book value (NBV) of the water and wastewater
systems for transfer purposes is $1,079 and $7,664, respectively, as of August
17, 2018. No positive acquisition adjustment should be included in rate base.
Within 90 days of the date of the final order, SJR Estates should be required
to notify the Commission in writing that it has adjusted its books in
accordance with the Commission’s decision. The adjustments should be reflected
in SJR Estates’ 2020 Annual Report when filed. (J. Blocker)
Staff Analysis:
Rate base was last established as of December 31,
2004, in Order No. PSC-2005-0431-PAA-WS. The purpose of establishing net book
value for both the water and wastewater systems for transfers is to determine
whether an acquisition adjustment should be approved. The NBV does not include
normal ratemaking adjustments for non-used and useful plant and working
capital. The NBV has been updated to reflect balances as of August 17, 2018.
Staff’s recommended NBV, as described below, is shown on Schedule Nos. 1, 2 and
3, attached to the recommendation.
Utility Plant in Service (UPIS)
The
Utility’s general ledger reflected water and wastewater UPIS balances of
$99,234 and $132,899, respectively, as of August 17, 2018. Audit staff reviewed
UPIS additions since the last rate case proceeding and as a result of a lack of
proper supporting invoices, has decreased UPIS for water by $14,204 and
wastewater by $3,914. Therefore, staff recommends that the Utility’s water and
wastewater UPIS balances as of August 17, 2018, should be $85,030 and $128,985,
respectively.
Land
According
to the Utility’s general ledger, as of August 17, 2018, the water and
wastewater land balances were $4,152 and $10,960, respectively. Water and
wastewater land additions were noted in the general ledger for 2017 and 2018. Upon
discussion however, the Buyer stated that the Seller did not have any additions
during those periods and could not provide any supporting documentation. Audit
staff determined that water land was overstated by $3,049, and wastewater land
was overstated by $1,122. Therefore, staff recommends that the Utility’s water
and wastewater land balances as of August 17, 2018, should be $1,103 and
$9,838, respectively.
Accumulated Depreciation
The
Utility’s general ledger reflected an accumulated depreciation balance of
$83,867 for water and $126,343 for wastewater as of August 17, 2018. Audit
staff calculated water and wastewater accumulated depreciation using the rates
from Rule 25-30.140, F.A.C., and the audited plant additions and retirements as
of August 17, 2018. Based on this calculation, water and wastewater accumulated
depreciation is overstated by $3,189 and $831, respectively. As such, staff
recommends that the Utility’s accumulated depreciation balances should be
$80,678 for water and $125,512 for wastewater, as of August 17, 2018.
Contributions-in-Aid-of-Construction
(CIAC) and Accumulated Amortization of CIAC
As
of August 17, 2018, the Utility’s general ledger reflected CIAC balances of
$31,205 and $34,285 for the water and wastewater, respectively. Staff reviewed
the CIAC balances and has no adjustments. As of August 17, 2018, the Utility’s
general ledger reflected accumulated amortization of CIAC balances of $27,520
and $29,024 for water and wastewater, respectively. Staff recalculated
accumulated amortization of CIAC balances based on the approved rate from Order
No. PSC-2005-0431-PAA-WS. Based on staff’s recalculation, water and wastewater
accumulated amortization of CIAC was overstated by $691 and $386, respectively.
Therefore, staff recommends CIAC balances of $31,205 for water and $34,285 for
wastewater, and accumulated amortization of CIAC balances of $26,829 for water
and $28,638 for wastewater, as of August 17, 2018.
Net Book Value
The
Utility reflected a NBV for water of $15,834 and a NBV for wastewater of
$12,255. Based on the adjustments above, staff recommends a NBV $1,079 for
water and a NBV of $7,664 for wastewater, for a total NBV of $8,743.
Acquisition Adjustment
An
acquisition adjustment results when the purchase price differs from the NBV of
the assets at the time of the acquisition. The Utility and its assets were
purchased for $10,000. As stated above, staff recommends the appropriate total
NBV to be $8,743. Pursuant to Rule 25-30.0371, F.A.C., a positive acquisition
adjustment may be appropriate when the purchase price is greater than the NBV,
and a negative acquisition adjustment may be appropriate when the purchase
price is less than NBV. However, pursuant to Rule 25-30.0371(2), F.A.C., a
positive acquisition adjustment shall not be included in rate base unless there
is proof of extraordinary circumstances. The Buyer did not request a positive
acquisition adjustment. As such, staff recommends that no positive acquisition
adjustment be approved.
Conclusion
Based on the
above, staff recommends that the NBV of the Utility, for transfer purposes, is
$8,743 ($1,079 + $7,664), as of August 17, 2018. No positive acquisition
adjustment should be included in rate base. Within 90 days of the date of the final
order, the Buyer should be required to notify the Commission in writing that it
has adjusted its books in accordance with the Commission’s decision. The
adjustments should be reflected in SJR Estates’ 2020 Annual Report.
Issue 3:
Should the Utility’s main extension charge be
discontinued?
Recommendation:
Yes. The Utility’s main extension charge should be
discontinued for the water and wastewater systems. SJR Estates should provide notice to customers who have requested service
within 12 calendar months prior to the month the application was filed to the
present. The Utility should file revised tariffs reflecting the discontinuance
of the main extension charges. The revised tariffs should be effective for
connections made on or after the stamped approval date on the tariff sheets.
The Utility should provide proof of the date notice was given within 10 days of
the date of the notice. (Hudson)
Staff Analysis:
The Utility’s existing service availability charges
include main extension charges of $545 for water and $935 for wastewater. A
main extension charge allows the Utility to recover a portion of the cost of
the Utility’s distribution and collection lines from future customers.
Currently, the Utility is not built out and can accommodate approximately 20
additional connections.
Rule 25-30.580, F.A.C., establishes guidelines for
designing service availability charges. Pursuant to the Rule, the maximum
amount of contributions-in-aid-of construction (CIAC), net of amortization, should
not exceed 75 percent of the total original cost, net of accumulated
depreciation, of the utility’s facilities and plant when the facilities and
plant are at their designed capacity. The minimum amount of CIAC should not be
less than the percentage of such facilities and plant that is represented by
the water transmission and distribution and wastewater collection systems. The
maximum guideline is designed to ensure that the Utility retains an investment
in the system.
Staff’s recommended net book values yield contribution
levels of 100 percent for water and 163 percent for wastewater. As a result,
because the Utility has fully recovered the cost of the Utility’s distribution
and collection lines and the contribution levels exceed the maximum guideline
in Rule 25-30.580, F.A.C., staff recommends that the Utility’s main extension
charge should be discontinued for the water and wastewater systems.
Based on the above, the Utility’s main extension charge
should be discontinued for the water and wastewater systems. SJR Estates should provide notice to customers who have requested
service within 12 calendar months prior to the month the application was filed
to the present. The Utility should file revised tariffs reflecting the
discontinuance of the main extension charges. The revised tariff should be
effective for connections made on or after the stamped approval date on the
tariff sheets. The Utility should provide proof of the date notice was given
within 10 days of the date of the notice.
Issue 4:
Should this docket be closed?
Recommendation:
Yes. If no protest
to the proposed agency action is filed by a substantially affected person
within 21 days of the date of the issuance of the order, a consummating order
should be issued and the docket should be closed administratively upon
Commission staff’s verification that the Buyer has notified the Commission in
writing that it has adjusted its books in accordance with the Commission’s
decision. (Stiller)
Staff Analysis:
If no protest to the proposed agency action is filed
by a substantially affected person within 21 days of the date of the issuance
of the order, a consummating order should be issued and the docket should be
closed administratively upon Commission staff’s verification that the Buyer has
notified the Commission in writing that it has adjusted its books in accordance
with the Commission’s decision.
ST. JOHNS RIVER ESTATES UTILITIES, LLC
DESCRIPTION OF TERRITORY SERVED
A part of
Sections 33 and 34, Township 10 South, Range 26 East and a part of Section 39,
Township 10 South, Range 26 East and part of Section 39, Township 11 South,
Range 26 East, Putnam County, Florida, being more particularly described as
follows: For a point of reference
commence at the point of intersection of the northerly line of said Section 39,
Township 10 South, Range 26 East, said point being 100.00 feet easterly of as
measured at right angles to the center line of the CSX Transportation right-of-way
as now established; thence S 28˚27'00" E, a distance of 1226.87 feet
to the northeasterly right-of-way of County Road 309-B as now established to
the POINT OF BEGINNING; thence northwesterly along said northeasterly right-of-way
line, along the arc of a curve concave northeasterly and have a radius of
1860.08 feet, a chord bearing of N 53˚28'26" W and a chord distance
of 118.36 feet; thence N 28˚27'00" W, a distance of 1281.54 feet;
thence N 61˚33'00" E, a distance of 50.00 feet; thence N
28˚27'00" W, along the easterly right-of-way line of the CSX
Transportation right-of-way, said right-of-way line being 100.00 feet easterly
of as measured at right angles to said center line as now established, a
distance of 1404.97 feet; thence N 73˚28'46" E, a distance of 478.55
feet; thence N 01˚09'00" W, a
distance of 210.00 feet; thence N 88˚51'00" E, a distance of 210.00
feet; thence N 01˚09'00" W, a distance of 600 feet more or less to
the waters of Murphy Creek; thence southeasterly along said waters of Murphy
Creek a distance of approximately 4700 feet to the easterly line of Section 39,
Township 10 South, Range 26 East; thence S 26˚14'14" E, along said
easterly line of said Section 39, Township 10 South, Range 26 East and the easterly
line of said Section 39, Township 11 South, Range 26 East, a distance of 1447
feet more or less; thence S 74˚31'16" W a distance of 1674.27 feet,
to the northeasterly right-of-way line of County Road 309-B as now established;
thence N 59˚08'00" W along said northeasterly right-of-way line a
distance of 203.67 feet; thence northwesterly along the northeasterly
right-of-way line, along the arc of a curve concave northeasterly and having a
radius of 1860.08 feet, a chord bearing of
N 57˚11'47" W and a chord distance of 125.6 feet to the POINT
OF BEGINNING.
FLORIDA PUBLIC SERVICE COMMISSION
Authorizes
St. Johns River
Estates Utilities, LLC
pursuant to
Certificate Number 542-W
to provide water service in Putnam County in accordance
with the provisions of Chapter 367, Florida Statutes, and the Rules,
Regulations, and Orders of this Commission in the territory described by the
Orders of this Commission. This authorization shall remain in force and effect
until superseded, suspended, cancelled or revoked by Order of this Commission.
Order Number Date
Issued Docket Number Filing Type
PSC-92-0330-FOF-WS 5/11/92 19910646-WS Original Certificate
PSC-05-0431-PAA-WS 4/20/05 20041096-WS Transfer
PSC-07-0195-FOF-WS 3/05/07 20060703-WS Transfer
* * 20180214-WS Transfer
*Order Numbers and
dates to be provided at time of issuance.
FLORIDA PUBLIC SERVICE COMMISSION
Authorizes
St. Johns River Estates
Utilities, LLC
pursuant to
Certificate Number 470-S
to provide wastewater service in Putnam County in
accordance with the provisions of Chapter 367, Florida Statutes, and the Rules,
Regulations, and Orders of this Commission in the territory described by the
Orders of this Commission. This authorization shall remain in force and effect
until superseded, suspended, cancelled or revoked by Order of this Commission.
PSC-92-0330-FOF-WS 5/11/92 19910646-WS Original Certificate
PSC-05-0431-PAA-WS 4/20/05 20041096-WS Transfer
PSC-07-0195-FOF-WS 3/05/07 20060703-WS Transfer
* * 20180214-WS Transfer
*Order Numbers and dates to be provided at time of issuance
St. Johns River Estates Utilities,
LLC
Schedule of Net Book Value as of
August 17, 2018
Water System
|
Description
|
Balance
Per Utility
|
Adjustments
|
Staff
Recommended
|
|
Utility Plant in Service
|
$99,234
|
($14,204)
|
$85,030
|
|
Land & Land Rights
|
4,152
|
(3,049)
|
1,103
|
|
Accumulated Depreciation
|
(83,867)
|
3,189
|
(80,678)
|
|
CIAC
|
(31,205)
|
-
|
(31,205)
|
|
Accumulated Amortization
of CIAC
|
27,520
|
(691)
|
26,829
|
|
Total
|
$15,834
|
($14,755)
|
$1,079
|
Wastewater System
|
Description
|
Balance
Per Utility
|
Adjustments
|
Staff
Recommended
|
|
Utility Plant in Service
|
$132,899
|
($3,914)
|
$128,985
|
|
Land & Land Rights
|
10,960
|
(1,122)
|
9,838
|
|
Accumulated Depreciation
|
(126,343)
|
831
|
(125,512)
|
|
CIAC
|
(34,285)
|
-
|
(34,285)
|
|
Accumulated Amortization
of CIAC
|
29,024
|
(386)
|
28,638
|
|
Total
|
$12,255
|
($4,591)
|
$7,664
|
Explanation
of Staff’s Recommended
Adjustments
to Net Book Value as of August 17, 2018
|
Explanation
|
|
|
|
Water
|
Wastewater
|
|
Utility
Plant in Service
|
|
|
|
|
To
reflect appropriate amount of utility plant in service.
|
($14,204)
|
($3,914)
|
|
|
|
|
|
Land
|
|
|
|
|
To
reflect appropriate amount of land.
|
($3,049)
|
($1,122)
|
|
|
|
|
|
Accumulated
Depreciation
|
|
|
|
|
To
reflect appropriate amount of accumulated depreciation.
|
$3,189
|
$831
|
|
|
|
|
|
Accumulated
Amortization of CIAC
|
|
|
|
|
To
reflect appropriate amount of Accumulated Amortization of CIAC.
|
($691)
|
($386)
|
|
|
|
|
|
Total
Adjustments to Net Book Value as of August 17, 2018
|
($14,755)
|
($4,591)
|
St. Johns River Estates Utilities,
LLC
Schedule of Staff’s Recommended
Account Balances as of August 17, 2018
Water System
|
Account
No.
|
Description
|
UPIS
|
Accumulated
Depreciation
|
|
304
|
Structures & Improvements
|
$3,825
|
($3,825)
|
|
307
|
Wells & Springs
|
13,229
|
(13,229)
|
|
311
|
Pumping Equipment
|
10,924
|
(10,505)
|
|
320
|
Water Treatment Equipment
|
854
|
(854)
|
|
330
|
Distribution Reservoirs
|
7,350
|
(7,350)
|
|
331
|
Transmission & Distribution
Mains
|
33,346
|
(29,853)
|
|
333
|
Services
|
8,530
|
(8,322)
|
|
334
|
Meters & Meter Install
|
6,972
|
(6,740)
|
|
|
|
|
|
|
Total
|
$85,030
|
($80,678)
|
Wastewater System
|
Account
No.
|
Description
|
UPIS
|
Accumulated
Depreciation
|
|
354
|
Structures & Improvements
|
$49,635
|
($49,635)
|
|
360
|
Collection Sewers - Force
|
8,681
|
(8,681)
|
|
361
|
Collection Sewers - Gravity
|
20,587
|
(19,360)
|
|
363
|
Services to Customers
|
2,414
|
(2,355)
|
|
370
|
Receiving
Wells
|
6,614
|
{6,614)
|
|
380
|
Treatment & Disposal - Equipment
|
12,965
|
(10,779)
|
|
381
|
Plant Sewers
|
28,089
|
(28,089)
|
|
|
|
|
|
|
|
Total
|
$128,985
|
($125,512)
|
St. Johns River Estates Utilities, LLC
Monthly Water Rates
|
Residential and
General Service
|
|
|
|
Base Facility Charge
by Meter Size
|
|
|
|
5/8” x 3/4"
|
|
$7.91
|
|
3/4”
|
|
$11.87
|
|
1"
|
|
$19.78
|
|
1 1/2”
|
|
$39.55
|
|
2”
|
|
$63.28
|
|
3”
|
|
$126.56
|
|
4”
|
|
$197.75
|
|
6”
|
|
$395.50
|
|
|
|
|
|
Charge Per 1,000
gallons
|
|
$3.63
|
|
Initial Customer Deposits
|
|
|
Residential and General Service – 5/8" X 3/4"
|
|
$50.00
|
|
|
All Other Meter
Sizes
|
|
2x average estimated
bill
|
|
|
|
|
|
Miscellaneous
Service Charges
|
|
|
|
|
|
Initial Connection Charge
|
|
$25.00
|
|
Normal Reconnection Charge
|
|
$25.00
|
|
Violation Reconnection Charge
|
|
$25.00
|
|
Premises Visit Charge (in lieu of disconnection)
|
|
$25.00
|
|
Service
Availability Charges
|
|
Meter Installation Charge
|
|
|
|
5/8” x 3/4”
|
|
$110.00
|
|
All Others Per Gallon
|
|
Actual Cost
|
St. Johns River Estates Utilities, LLC
Monthly Wastewater Rates
|
Residential
Service
|
|
|
|
Base Facility Charge –
All Meter Sizes
|
|
$11.09
|
|
|
|
|
|
Charge Per 1,000
gallons
|
|
$3.84
|
|
8,000 gallon cap
|
|
|
|
|
|
|
|
General
Service
|
|
|
|
Base Facility Charge
by Meter Size
|
|
|
|
5/8” x 3/4"
|
|
$11.09
|
|
3/4”
|
|
$16.64
|
|
1"
|
|
$27.73
|
|
1 1/2”
|
|
$55.45
|
|
2”
|
|
$88.72
|
|
3”
|
|
$177.44
|
|
4”
|
|
$277.25
|
|
6”
|
|
$554.50
|
|
|
|
|
|
Charge Per 1,000
gallons
|
|
$4.60
|
|
Initial Customer Deposits
|
|
|
Residential and General Service – 5/8" X 3/4"
|
|
$50.00
|
|
|
All other meter
sizes
|
|
2x average estimated
bill
|
|
|
|
|
|
Miscellaneous
Service Charges
|
|
|
|
|
|
Initial Connection Charge
|
|
$25.00
|
|
Normal Reconnection Charge
|
|
$25.00
|
|
Violation Reconnection Charge
|
|
Actual Cost
|
|
Premises Visit Charge (in lieu of disconnection)
|
|
$25.00
|
