Recommendation

Issue 1:

Should Suwannee Valley Utilities, LLC’s application for a grandfather water certificate in Columbia County be acknowledged?

Recommendation:

Yes. Suwannee Valley’s application should be acknowledged and the Utility should be granted Certificate 696-W, effective May 16, 2024, to serve the territory described in Attachment A. The resultant order should serve as Suwannee Valley’s certificate and should be retained by the Utility. (Sanchez, Bardin, Dose)

Staff Analysis:

Legal Standard

Under Section 367.171(2)(b), F.S., on the day a county declares it is subject to the provisions of Chapter 367, any utility engaged in the operation or construction of a non-exempt water or wastewater system shall be entitled to receive a certificate for the area served by the utility. Within 90 days after the day this chapter becomes applicable to it, the utility shall file an application for a grandfather certificate. The filing requirements for a grandfather application are set forth in Rule 25-30.035, F.A.C.

Analysis

The Utility’s application for certificate under grandfather rights to provide water service in Columbia County is in compliance with Section 367.171(2)(b), F.S., and Rule 25-30.035, F.A.C. An adequate service territory description and system maps were provided. As the Utility has its own treatment facilities, Suwannee Valley filed warranty deeds as proof of ownership of the land on which the Utility’s facilities are located as required by Rule 25-30.035(11), F.A.C. A description of the Utility’s territory is described in Attachment A.

As stated in the case background, Suwannee Valley currently provides water service to approximately 320 customers with a potential customer base of approximately 348 customers. The Utility does not have any outstanding citations, violations, or consent orders on file with the Florida Department of Environmental Protection.

The Utility is aware of its obligation to submit its 2026 Annual Report pursuant to Rule 25-30.110, F.A.C, and is also aware of its obligation to pay regulatory assessment fees (RAFs) pursuant to Rule 25-30.120, F.A.C. During the pendency of this docket, the Utility filed a 2025 Annual Report and paid its 2024 RAFs. In addition, the Utility is aware that it must maintain its books and records according to the National Association of Regulatory Utility Commissioners’ Uniform System of Accounts.

Conclusion

Based on the above, staff recommends that Suwannee Valley’s application should be acknowledged and the Utility should be granted Certificate 696-W, effective May 16, 2024, to serve the territory described in Attachment A. The resultant order should serve as Suwannee Valley’s certificate and should be retained by the Utility.

Issue 2:

What rates, charges, and deposits should be approved for Suwannee Valley Utilities, LLC?

Recommendation:

Of the Utility’s rates and charges that were in effect when the County transferred jurisdiction to the Commission, only the rates and charges shown on Schedule No. 1 are appropriate and should be approved. The rates and charges should be effective for services rendered or connections made on or after the stamped approval date on the tariff sheets. Suwannee Valley should be required to charge the approved rates and charges until authorized to change them by the Commission in a subsequent proceeding. (Sibley)

Staff Analysis:

The Utility consists of several water systems. The County approved Suwannee Valley’s current monthly water rates and charges for Woodgate, Country Dale, College Manor, Suwannee Valley Estates, and Brandon Brent. Woodgate and Country Dale rates consist of a base facility charge (BFC), which includes a 3,000 gallonage allotment and a gallonage charge per 1,000 gallons over 3,000 gallons. College Manor and Suwanee Valley Estates rates consist of a BFC for all meter sizes and a charge per 1,000 gallons. The monthly rates for Brandon Brent consist of a BFC and a four-tier inclining block rate structure. With the exception of Suwannee Valley Estates, which serves only residential, all systems apply the same rate structure to both residential and general service customers. In addition, the Brandon Brent system has a billing charge of $4.50, which was inherited when the system was acquired from the City of Lake City. The Utility indicated that the billing charge is assessed for labor, paper, and postage cost for mailing customer’s bills. Based on this charge, it appears the operation and maintenance expense associated with billing is not embedded in rates. Therefore, staff believes the billing charge should be continued until a subsequent rate proceeding.

Suwannee Valley has separate miscellaneous service charges for each system. Since the charges vary across the systems, the Utility requested uniform miscellaneous service charges to reflect that the cost incurred is the same across all of the systems. Therefore, staff recommends that the miscellaneous service charges be modified in Issue 3. However, the late payment charge and non-sufficient funds (NSF) charge are uniform across all systems and should remain unchanged. In addition, Suwannee Valley’s initial customer deposits must be revised, as addressed in Issue 5, to be consistent with Commission practice. Finally, Suwannee Valley’s tariff included service availability charges at actual cost. After an inquiry from staff, the Utility indicated the service availability charges were for meter and line installations (tap-in) to connect new customers to the Utility facilities. Staff believes the tap-in charge is appropriate at actual cost. However, historically, the Commission has defined the dollar amount for the 5/8-inch x 3/4-inch meter size. Therefore, staff addresses the appropriate meter installation charge in Issue 4.

Staff recommends that of the Utility’s rates and charges that were in effect when the County transferred jurisdiction to the Commission, only the rates and charges shown on Schedule No. 1 are appropriate and should be approved. The rates and charges should be effective for services rendered or connections made on or after the stamped approval date on the tariff sheets. The Utility should be required to charge the approved rates and charges until authorized to change them by the Commission in a subsequent proceeding.

Issue 3:

What are the appropriate miscellaneous service charges for Suwannee Valley Utilities, LLC?

Recommendation:

The appropriate miscellaneous service charges shown on Table 3-4 should be approved. The Utility should be required to file a proposed customer notice to reflect the Commission-approved charges. The approved charges should be effective for service rendered or connections made on or after the stamped approval date on the tariff sheet pursuant to Rule 25-30.475(2), F.A.C. In addition, the tariff sheets should be approved upon staff’s verification that the tariffs are consistent with the Commission’s decision and that the proposed customer notice is adequate. (Sibley)

Staff Analysis:

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. As shown in Table 3-1, the miscellaneous service charges vary across systems. The existing miscellaneous service charges include charges that have become obsolete pursuant Rule 25-30.460, F.A.C. In order to achieve administrative efficiency and remove the disparities between the miscellaneous service charges, the Utility requested uniform miscellaneous charges. Suwannee Valley provided justification for its requested charges.

Table 3-1

Suwannee Valley’s Existing Miscellaneous Service Charges (All systems)

	Existing Charges
Initial Connection Charge (Suwannee Valley Est. and College Manor)	$25.00
Reconnection Charge (Suwannee Valley Est. and College Manor)	$25.00
Normal Reconnection Charge (Woodgate, Country Dale, and Brandon Brent)	$34.50
Violation Reconnection Charge (Woodgate, Country Dale, and Brandon Brent)	$34.50
Premises Visit Charge (Woodgate, Country Dale, and Brandon Brent)	$34.50
Late Payment Charge (All systems)	$10.00
Nonsufficient Funds Charge (All systems)	Per Florida Statute
Meter Tampering Charge (Woodgate, Country Dale, and Brandon Brent)	Actual Cost
Meter Tampering Charge (Suwannee Valley Est. and College Manor)	$75.00

Source: Document No. 08452-2024, filed on August 14, 2024, in Docket No. 20240123-WU.

Violation Reconnection and Premises Visit Charges

The existing miscellaneous service charges included initial connection and normal reconnection charges. Suwannee Valley’s request did not include the initial connection and normal reconnection charges, which is consistent with Rule 25-30.460, F.A.C. The Utility requested uniform violation reconnection and premises visit charges for its systems.

A 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 adjusted the cost breakdown for rounding and added the markup for RAFs. Based on labor and transportation to and from the service territory, staff recommends violation reconnection charges of $142.00 for normal hours and $153.00 for after hours. Staff’s calculations are shown in Table 3-2.

Table 3-2

Violation Reconnection Charge

Activity	Normal Hours Cost	Activity	After Hours Cost
Labor (Administrative) ($27.80/hr x 1/4 hr)	$6.95	Labor (Administrative) ($41.70/hr x 1/4 hr)	$10.42
Labor (Field) ($28.90/hr x 1/2 hr )	$14.45	Labor (Field) ($43.35/hr x 1/2 hr)	$21.68
Transportation ($0.725/mile x 79 miles-to/from x 2)	$114.55	Transportation ($0.725/mile x 79 miles-to/from x 2)	$114.55
Mark up for RAFs (4.5%)	$6.12	Mark up for RAFs (4.5%)	$6.60
Total	$142.07	Total	$153.25

Source: Utility Cost Justification with staff adjustments for rounding.

A premises visit charge is levied when a service representative visits a premises to discontinue service for nonpayment of a due and collectible bill and the customer pays the service representative or otherwise makes satisfactory arrangements to pay the bill and service is not discontinued. A premises visit is also levied when a service representative visits a premises at the customer’s request to (1) initiate service, (2) temporarily disconnect, (3) reconnect service after a temporary disconnection, or (4) assess a service issue and it is found to be the customer’s responsibility. Staff adjusted the cost breakdown for rounding and added the markup for RAFs. Based on labor and transportation to and from the service territory, staff recommends premises visit charges of $137.00 for normal hours and $146.00 for after hours. Staff’s calculations are shown in Table 3-3.

Table 3-3

Premises Visit Charge

Activity	Normal Hours Cost	Activity	After Hours Cost
Labor (Administrative) ($27.80/hr x 1/4 hr)	$6.95	Labor (Administrative) ($41.70/hr x 1/4 hr)	$10.42
Labor (Field) ($28.90/hr x 1/2 hr)	$9.62	Labor (Field) ($43.35/hr x 1/3hr)	$14.44
Transportation ($0.725/mile x 79 miles-to/from x 2)	$114.55	Transportation ($0.725/mile x 79 miles-to/from x 2)	$114.55
Mark up for RAFs (4.5%)	$5.90	Mark up for RAFs (4.5%)	$6.27
Total	$137.02	Total	$145.68

Source: Utility Cost Justification with staff adjustments for RAFs and rounding.

Tampering or Prohibited Connection or Use Charge

The Utility’s meter tampering charges consist of $75 for the College Manor and Suwannee Valley Estates subdivisions. The meter tampering charges for Woodgate, Country Dale, and Brandon Brent are at actual cost. Rule 25-30.320(2)(j), F.A.C., provides that a utility may refuse or discontinue service without notice in the event of unauthorized or fraudulent use of service. If service is discontinued due to fraudulent use, the Utility may, as a condition of restoration, require the customer to (i) make, at the customer’s expense, all necessary changes to piping or equipment to eliminate the illegal use, and (ii) pay an amount reasonably estimated to reflect the revenue deficiency resulting from the fraudulent use. Based on the above, staff recommends that the tampering charge of $75 for College Manor and Suwannee Valley Estates subdivisions be discontinued, and instead approved at actual cost.

Table 3-4

Staff Recommended Miscellaneous Service Charges

	Normal Hours	After Hours
Violation Reconnection	$142.00	$153.00
Premises Visit Charge	$137.00	$146.00
Meter Tampering Charge	Actual Cost
NSF Charge*	Pursuant to Section 68.065, F.S.
Late Payment Charge*	$10.00

Conclusion

Based on the above, the appropriate miscellaneous service charges shown on Table 3-4 should be approved. The Utility should be required to file a proposed customer notice to reflect the Commission-approved charges. The approved charges should be effective for service rendered or connections made on or after the stamped approval date on the tariff sheet pursuant to Rule 25-30.475(2), F.A.C. In addition, the tariff sheets should be approved upon staff’s verification that the tariffs are consistent with the Commission’s decision and that the proposed customer notice is adequate.

Issue 4:

What is the appropriate meter installation charge for Suwannee Valley Utilities, LLC?

Recommendation:

The appropriate meter installation charge is $219 and should be approved. The Utility should file a tariff sheet and a proposed customer notice. The Utility should provide notice to potential customers who have requested service within 12 calendar months prior to the month the application was filed and up until this Order becomes final. The approved charge should be effective for connections made on or after the stamped approval date on the tariff sheet. The Utility should provide proof of the date notice was given within 10 days of the date of notice. (Sibley)

Staff Analysis:

Currently, the Utility’s tariff has service availability charges as actual cost. As stated in Issue 2, after an inquiry from staff, the Utility indicated the service availability charges were for meter and line installations (tap-in) to connect new customers to the Utility facilities. In Issue 2, staff indicated the Utility’s tap-in charge is appropriate. However, the meter installation charge should be defined for the 5/8-inch by 3/4-inch meter size. The Utility’s cost justification for a meter installation charge includes the cost of materials and labor. Staff has reviewed Suwannee Valley’s cost justification and determined it to be reasonable. Staff recommends that the proposed meter installation charge of $219 for the 5/8-inch x 3/4-inch meter size should be approved.

Conclusion

Based on the above, the appropriate meter installation charge is $219 and should be approved. The Utility should file a tariff sheet and a proposed customer notice. The Utility should provide notice to potential customers who have requested service within 12 calendar months prior to the month the application was filed and up until this Order becomes final. The approved charge should be effective for connections made on or after the stamped approval date on the tariff sheet. The Utility should provide proof of the date notice was given within 10 days of the date of notice.

Issue 5:

What are the appropriate initial customer deposits for Suwannee Valley Utilities, LLC?

Recommendation:

The appropriate initial customer deposit amount should be $85 for the residential 5/8 inch x 3/4 inch meter sizes. The initial customer deposits for all other residential meter sizes and all general service meter sizes should be two times the average estimated bill. The approved initial customer deposits should be effective for services rendered or 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 deposits until authorized to change them by the Commission in a subsequent proceeding. (Sibley)

Staff Analysis:

Rule 25-30.311, F.A.C., provides the criteria for collecting, administering, and refunding customer deposits. Customer deposits are designed to minimize the exposure of bad debt expense for the Utility and, ultimately, the general body of ratepayers. An initial customer deposit ensures that the cost of providing service is recovered from the cost causer. Historically, the Commission has set initial customer deposits equal to two times the average estimated bill. The dollar amount for the residential 5/8-inch x 3/4-inch meter size is defined and all other residential and all general service meter sizes are reflected as two times the average bill. In the Utility’s tariff, the initial customer deposits for the residential and general service 5/8 inch x 3/4 inch meter size is $85. All other meter sizes are at actual cost.

To be consistent with Commission practice, staff recommends that the appropriate initial customer deposit should be $85 for the residential 5/8 inch x 3/4 inch meter sizes. The initial customer deposits for all other residential meter sizes and all general service meter sizes should be two times the average estimated bill. The approved initial customer deposits should be effective for services rendered or 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 deposits until authorized to change them by the Commission in a subsequent proceeding.

Issue 6:

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 this 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, and notice has been provided to customers. Once these actions are complete, this docket should be closed administratively if no timely protest has been filed. (Dose)

Staff Analysis:

DESCRIPTION OF TERRITORY SERVED

Suwannee Valley Utilities, LLC

Columbia County

DESCRIPTION: (WOODGATE VILLAGE)

A PARCEL OF LAND DESCRIBING A WATER UTILILTY SERVICE AREA AS LIES IN SECTION(S) 5 AND 8, TOWNSHIP 4 SOUTH, RANGE 16 EAST, COLUMBIA COUNTY, FLORIDA AND BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS:

COMMENCE AT THE NW CORNER OF THE SW 1/4 OF THE SE 1/4 OF SAID SECTION 5, TOWNSHIP 4 SOUTH, RANGE 16 EAST, COLUMBIA COUNTY, FLORIDA AND RUN N.88°25'26"E., ALONG THE NORTH LINE OF SAID SW 1/4 OF THE SE 1/4, 12.02 FEET TO THE POINT OF BEGINNING OF PARCELS BEING SUBJECT TO SAID WATER UTILITY SERVICE AREA; THENCE CONTINUE N.88°25'26"E„ 381.44 FEET; THENCE CONTINUE N.88°25'26"E., 500.00 FEET TO THE NORTHERLY RIGHT-OF-WAY LINE OF SW PINEMOUNT ROAD; THENCE CONTINUE N.88°25'26"E., 215.83 FEET TO THE SOUTHERLY RIGHT-OF-WAY LINE OF SAID SW PINEMOUNT ROAD; THENCE CONTINUE N.88°25'26"E., 221.40 FEET TO THE NE CORNER OF SAID SW 1/4 OF THE SE 1/4, ALSO BEING THE NE CORNER OF "WOODGATE VILLAGE UNIT 1" AS PER THE PLAT THEREOF RECORDED IN PLAT BOOK 5, PAGE 16; THENCE RUN S.02'°04'28"E., ALONG THE EAST LINE OF SAID "WOODGATE VILLAGE UNIT 1", 687.56 FEET TO THE SE CORNER OF SAID "WOODGATE VILLAGE UNIT 1", ALSO BEING THE NE CORNER OF "WOODGATE VILLAGE UNIT 2" AS PER THE PLAT THEREOF RECORDED IN PLAT BOOK 5, PAGE(S) 84 AND 84A, OF THE PUBLIC RECORDS OF COLUMBIA COUNTY, FLORIDA; THENCE CONTINUE S.02°04'28"E„ ALONG THE EAST LINE OF SAID "WOODGATE VILLAGE UNIT 2", 638.94 FEET TO THE SE CORNER OF THE SW 1/4 OF THE SE 1/4 OF SECTION 5, ALSO BEING THE NE CORNER OF THE NW 1/4 OF THE NE 1/4 OF SAID SECTION 8; THENCE S.02°07'50"E., STILL ALONG SAID EAST LINE OF "WOODGATE VILLAGE UNIT 2" 991.82 FEET; THENCE RUN S.88°23'00"W., ALONG THE SOUTH LINE OF SAID "WOODGATE VILLAGE UNIT 2", 529.39 FEET TO THE SW CORNER OF SAID "WOODGATE VILLAGE UNIT 2", ALSO BEING THE SE CORNER OF "WOODGATE VILLAGE UNIT 3" AS PER THE PLAT THEREOF RECORDED IN PLAT BOOK 6, PAGE 83 OF THE PUBLIC RECORDS OF COLUMBIA COUNTY, FLORIDA; THENCE CONTINUE S.88°23'00"W., ALONG THE SOUTH LINE OF SAID "WOODGATE VILLAGE UNIT 3", 783.44 FEET TO THE SW CORNER OF SAID "WOODGATE VILLAGE UNIT 3"; THENCE N.02°13'36"W., ALONG THE WEST LINE OF SAID "WOODGATE VILLAGE UNIT 3", 992.57 FEET TO THE NORTH LINE OF SAID SECTION 8, ALSO THE SOUTH LINE OF SAID SECTION 5; THENCE N.02°28'44"W., STILL ALONG SAID WEST LINE OF "WOODGATE VILLAGE UNIT 3", 225.18 FEET TO THE NW CORNER OF SAID "WOODGATE VILLAGE UNIT 3", ALSO BEING THE SW CORNER OF SAID "WOODGATE VILLAGE UNIT 1"; THENCE N.02°26'52"W., ALONG THE WEST LINE OF SAID "WOODGATE VILLAGE UNIT 1", 530.00 FEET TO THE SOUTHERLY RIGHT-OF-WAY LINE OF SAID SW PINEMOUNT ROAD; THENCE RUN N.00°00'50"W., 139.96 FEET TO THE NORTHERLY RIGHT-OF-WAY LINE OF SAID SW PINEMOUNT ROAD; THENCE N.02°37'33"W., 431.73 FEET TO THE POINT OF BEGINNING.