STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
GULFSTREAM UTILITY COMPANY, )
)
Petitioner, )
)
vs. ) DOAH CASE NO.: 81-1499
) FPSC DOCKET NO.: 800621-WS FLORIDA PUBLIC SERVICE COMMISSION )
)
Respondent. )
)
RECOMMENDED ORDER
Pursuant to notice, the Division of Administrative Hearings, by its duly designated Hearing Officer, R. L. Caleen, Jr., conducted a formal hearing in this case on June 25 and 26, 1981, in Fort Lauderdale, Florida.
APPEARANCES
For Petitioner: B. Kenneth Gatlin, Esquire
318 North Monroe Street Tallahassee, Florida 32302
For Respondent: Marta M. Suarez-Murias, Esquire
101 East Gaines Street Tallahassee, Florida 32301
ISSUE PRESENTED
Whether, and to what extent, petitioner should be authorized to increase the water and sewer rates it charges its customers.
BACKGROUND
On February 5, 1981, petitioner Gulfstream Utility Company ("Utility") filed an application with respondent Florida Public Service Commission ("Commission") seeking authorization to increase, on an interim and permanent basis, the water and sewer rates it charges its customers in Broward County, Florida. By order No. 9880 dated March 17, 1981, the Commission authorized, under bond, an interim increase of $37,130 in annual water operating revenues, an increase of $134,127 in annual sewer operating revenues and suspended the proposed rate schedules filed by the Utility. By letter dated October 7, 1980, the Commission Chairman approved, for purposes of this rate proceeding, use of a test year ending September 30, 1980.
On June 2, 1981, the Commission forwarded the Utility's application for a rate increase to the Division of Administrative Hearings for the conducting of a formal hearing. By notice dated June 9, 1981, final hearing was set for June 25 and 26, 1981.
At the outset of hearing, Motorola, Inc., a corporate customer of the Utility, presented a petition seeking leave to intervene as a party in this proceeding. Both the Utility and the Commission opposed the petition on grounds of surprise and untimeliness. The Commission cited Model Rule 28-5.207 which requires that petitions to intervene be filed at least five days prior to hearing. It was undisputed that Motorola, Inc., along with all other customers of the Utility, were sent written notices on April 1, 1981, and June 12, 1981, indicating that a rate increase application had been filed and a hearing would be held. After hearing arguments, the petition to intervene was denied for failure to file within the time prescribed by Rule 28-5.207, Florida Administrative Code. However, Motorola, Inc., and all other customers were allowed to present relevant oral and written testimony at an appropriate point in the hearing.
At final hearing, the Utility called as its witnesses, John A. Farina, John
Ring, and Barry K. Asmus; it offered into evidence Petitioner's Exhibit 1/ Nos. 1 through 9.
The Commission called as its witnesses Tom Walden, Barry Davis, and Joyce Fabelo; it offered into evidence Respondent's Exhibit 1/ Nos. 1 through 6.
Numerous customers attended the hearing and testified in opposition to the proposed rate increases. In connection with their testimony, Customers' Exhibit 1/ Nos. 1 and 2 were offered into evidence.
The parties' proposed findings of fact were timely submitted on July 30, 1981. It was agreed that the Recommended Order would be due on August 17, 1981.
Based upon the evidence submitted at hearing, the following findings of fact are determined:
FINDINGS OF FACT
I.
The Utility and its Application
The Utility, a wholly owned subsidiary of Gulfstream Land and Development Corporation, owns and operates water and sewer systems serving residents of "Jacaranda Community," a development located within the city limits of Plantation, Florida. The Utility's water treatment plant uses a lime- softening process; its sewage treatment plant uses a contact stabilization mode. During the test year ending September 30, 1980, the Utility supplied water service to an average of 3,162 residential, 662 general service, and 14 private fire-line customers; during the same period it supplied sewer service to an average of 3,162 residential and 276 general service customers.
By its February 5, 1981, application, the Utility alleged that it was authorized a rate of return of 9.87 percent, yet during the test year it earned only a 7.20 percent rate of return on its water rate base, and a 6.58 percent return on its sewer rate base. It proposed new rates which would generate
$1,271,841 in water operating revenues and $1,381,401 in sewer operating revenues--constituting a rate of return of not less than 12.42 percent. (Testimony of Fabelo; Petitioner's application dated January 30, 1981, R-4.)
II.
The Elements of Rate-Making
In setting utility rates, the Commission must determine: (1) rate base; 2/ (2) the cost of providing the service, including debt interest, working capital, maintenance, depreciation, tax, and operating expenses; (3) a fair return on the rate base; and (4) the quality of service provided. If the Utility is providing service of acceptable quality, it is entitled to rates which will produce revenues sufficient to cover its reasonable costs of operation and allow it an opportunity to earn a fair return on its rate base.
There are three major issues in this case: two involve the determination of rate base and the other involves whether several Utility expenditures should be expensed or capitalized. These issues are addressed below with the the appropriate rate-making element.
Rate Base
The two issues involving rate base are: (1) what portion of the Utility's sewer treatment plant is used and useful in the public service; and
what method should be used to calculate working capital allowance.
Used and Useful Plant
A public utility is entitled to a return only on Utility property which is "used and useful in the public service." 3/ At hearing, the Utility contended that 100 percent of its sewage treatment plant was used and useful; the Commission contended that the correct figure was 76 percent. 4/
The Utility's contention is accepted as more credible because it is based on a professional engineering analysis of actual wastewater flows through the sewage treatment plant during the test year and eight months thereafter. In contrast, the Commission's contention is based on application of a formula which relates total rated capacity of a plant to the number of Equivalent Residential Connections 5/ ("ERCs") it is capable of serving. Here, actual must prevail over theoretical fact.
The Utility's sewage treatment plant has a rated capacity of 2.5 million gallons per day ("MGD"). During the test year, average daily flows, calculated monthly, fluctuated between 63.6 percent and 75.2 percent of the rated capacity; the average three-day peak flow, calculated monthly, ranged from
73.2 percent to 86.4 percent of capacity; and one-day peak flows ranged from
74.4 percent to 87.2 percent of capacity.
During the eight months following the test year, sewage flow steadily increased. The greatest flow was during February, a relatively dry month; average daily flow was 2.20 MGD, 88 percent of rated capacity; the average three-day peak flow was 98.8 percent of capacity; and the peak flow day was
100.4 percent of capacity. If, on that peak flow day, the plant had only 76 percent of its present capacity, sewage would have overflowed the plant. The parties agree 6/ that a margin of reserve or allowance for growth of approximately 24 percent should be used in calculating the Utility's used and useful plant; they also agree that the Utility's future growth in ERCs is expected to range from 700 to 800 ERCs a year. The Commission argues that the
24 percent growth allowance should be added to average ERCs during the test year, and not to actual February, 1981, flows. This argument is unpersuasive. The test year period is a tool for predicting conditions which will exist during
the period in which the new rates will be effective; rates are set prospectively, for the future--not the past. Thus, rates must take into account known changes and conditions occurring subsequent to the test year in order to accurately reflect conditions expected for the future. Here, the Utility's actual sewage flows indicate that 100 percent of its existing plant is used and useful and necessary to satisfy the immediate and anticipated future needs of its customers.
In an attempt to rebut or overcome the effect of the sewage plant's actual flow conditions, the Commission contends that the sewage system is experiencing ground water infiltration of sufficient magnitude to cast doubt on the use of total flow figures. However, the infiltration does not exceed the amount which is ordinarily planned for in constructing sewage treatment plants. Infiltration which will continue to take place--despite the Utility's best efforts to ameliorate it--cannot be separated from the wastewater stream. Since the plant must be capable of handling the combined flow, including infiltration, total flow figures must be considered.
The Commission also contends that the system is not 100 percent used and useful because it can serve more connections. This contention is inconsistent with the acknowledged requirement that a sewage treatment plant must be capable of accepting increased sewage flows reasonably anticipated in the near future. That is the purpose of including an allowance for growth in the used and useful calculation.
Lastly, the Commission contends that the Utility's failure to consult with Department of Environmental Regulation officials about future plant expansion is inconsistent with its 100 percent used and useful claim. But the Utility, recognizing its present limits and future needs, has actively pursued an interlocal agreement which will allow it to pump approximately 700,000 GPD to Broward County's regional sewage facility. The agreement is in its final stages and approval is eminent. (Testimony of Ring, Farina, Walden; P-1, p-2, R-1.)
Cash Working Capital Allowance
Cash working capital is the amount of investors' supplied cash needed to operate a utility during the interval between rendition of service and receipt of payment from the customers. By including it in rate base, a utility is allowed to earn a return on this portion of its investment.
A utility's working capital requirements may be calculated by using:
a standardized formula; (2) the utility's balance sheet; or (3) a lead-lag study. Until June, 1981, the Commission routinely used the formula approach; working capital was calculated by multiplying 12.5 percent (equivalent to one- eighth of a year) times the utility's annual adjusted operations and maintenance expenses. This method is also facilitated by Commission Rule 25- 10.176(2)(a)2.g., Florida Administrative Code which requires that water and sewer rate adjustment applications include a schedule showing:
g. Allowance for working capital (1/8 of annual operations and maintenance expenses for the test year.) Id.
In this case--consistent with the Commission's rule and custom--the Utility seeks a working capital allowance derived by using the standard Commission formula. However, the Commission seeks to use, instead, the balance sheet approach--an approach which it contends is more precise than the standard
formula and results in a closer correlation between the Utility's rate base and its capital structure.
The Commission's contention is accepted as persuasive. Under the balance sheet method, working capital allowance is the difference between a utility's current assets and current liabilities. Thus, the working capital component of rate base is derived, by simple adjustments, from a utility's balance sheet; it originates in the balance sheet's capital structure, just as do the other components of rate base. In comparison, the formula approach originates from a utility's income statement, i.e., one-eighth of its annual operating and maintenance expenses. The one-eighth factor equates to a 45-day lag--a period of time assumed to cover the lapse between the rendering of service and payment by the customer. But this assumption, while generally useful, may not accurately depict the working capital requirement of a given utility. In this case, the balance sheet approach is a more precise method for determining the Utility's working capital requirements.
The Utility poses two objections to calculating working capital allowance by the balance sheet method: (1) it deviates from the Commission's prior practice in water and sewer rate cases, and (2) it may result in a negative allowance when a utility has insufficient cash to pay its current bills; thus a utility in greatest need of working capital would receive the least allowance.
As to the objection that the balance sheet method represents a departure from past practice, the Commission has flexibility to expand, refine, and alter its policy through individual case decisions provided its action is explained and justified by record evidence. 7/ The Commission has not, by rule, limited that flexibility. Rule 25-10.176(2)(a)2.g. only requires applicants for rate adjustments to show their working capital requirements by applying the formula method; it does not preclude the Commission or utilities from using an alternative method more suitable to the facts of a given case. For example, it is generally recognized that, if a lead-lag study is conducted, it will prevail over the formula method.
The Utility's second objection (that a cash-poor utility receives a lesser working capital allowance), is based on a hypothetical case and has no application to the facts here; the Utility has sufficient current assets and the balance sheet method results in a positive working capital allowance.
This finding in favor of the balance sheet method is based on the evidence presented; its effect is thus necessarily limited to this case. Should the Commission--in future cases--advocate the balance sheet method, as opposed to the formula method, it must again explain and justify its position, insofar as possible, by conventional proof. 8/ Unless its policy is adopted by rule, an agency must repeatedly establish and defend it. 9/
The other components of the Utility's rate base, as adjusted, are not in dispute. Water and sewer rate base are therefore $3,369,160 and $4,099,887, respectively, and are depicted below:
RATE BASE
Test Year Ending September 30, 1900
Water | Sewer |
Utility Plant in Service $5,919,833 | $9,210,212 |
Utility Plant Held for Future Use (145,384) | (644,429) |
Construction Work in Progress 265,300 | -0- |
Accumulated Depreciation (616,835) | (954,300) |
Contributions in Aid of Construction--Net (2,293,690) | (3,579,118) |
Working Capital Allowance 39,936 | 59,522 |
Materials and Supplies -0- | -0- |
TOTAL $3,369,160 | $4,099,887 |
(Testimony of Davis, Asmus; P-6, R-2, R-3.)
Net Operating Income
The Commission opposes several operation, maintenance, and depreciation expenses which the Utility proposes to include in the test year statement of operations.
The Hardy Gross Analysis
The Hardy Cross Analysis is a computer analysis of the entire water distribution system. It indicates loss of pressure, balances water flows, and determines residual pressure at the end points of the system. It is a useful and necessary informational tool in designing additions to water distribution systems: it allows the designer to properly size new pipes added to the system. Growth, such as that experienced by the Utility, requires that such an analysis be updated at least once a year.
The parties do not dispute the value of such an analysis, its cost, or the necessity for its actual updating. They dispute only who should bear the cost: the existing rate-payers or the developers which require and benefit from the continued expansion of the water system.
It is concluded that the recurring cost of updating the Hardy Cross Analysis should be borne by developers, and, indirectly, the future customers who are the primary beneficiaries of the annual updating; without the growth associated with new developments, the annual updating of the Hardy Gross Analysis would be unnecessary. It would be unfair to require existing customers to pay for services--through higher rates--which they do not require and from which they receive no significant benefit. (Testimony of Farina, Walden.)
Review of City of Plantation Utility Standards
In 1969, the City of Plantation, where the Utility's water and sewer systems are located, enacted an ordinance containing detailed technical standards governing the construction of water and sewer systems. Historical experience has indicated that the standards incorporated in the ordinance require annual review, and periodic revision; the Utility's participation in that process is reasonably necessary to its continued efficient operation. A necessary expense of $1,000 should be allowed and charged as an operation expense to each system--water and sewer. (Testimony of Farina.)
Diesel Fuel
On June 16, 1980--during the last quarter of the test year--the Utility installed two auxiliary power units which utilize diesel fuel. Since the two power units were not in service during the entire test year, the Utility seeks to annualize the cost of the diesel fuel consumed during the 3 1/2-month period and include it as a recurring operating expense. 10/
The Commission opposes annualizing the fuel costs on the ground that sufficient documentation was not presented by the Utility to justify the actual consumption of fuel by the power units and establish that such consumption represented normal operation of the Utility, i.e., that it is reasonably expected that such annual consumption will repeatedly occur in the future. The Commission's contention is accepted as persuasive. The Utility has the burden of supporting its claimed expenses with adequate documentation. 11/ Here, no evidence was presented to establish the actual periods of operation of the auxiliary generators or the conditions under which they were used; nor were rated consumption of fuel figures supplied. The alternate treatment suggested by the Commission--amortize initial diesel fuel fill-up cost over three years, placing one-third of it in expense and adding the other two-thirds to materials and supplies 12/ --is a reasonable method of treating the fuel expenditures. (Testimony of Davis, Walden, Asmus; R-2, R-3.)
Amortization of Legal Expense Relating to Proposed CIAC Rules
The Utility contends that the Commission is contemplating further CIAC 13/ rule making thus necessitating the expenditure of recurring legal expenses in the total amount of $778. However, although the Commission is now considering the adoption of CIAC rules, recurring revisions in the future are not reasonably expected. In the last ten years, the Commission has had one rule docket pertaining to CIAC rule making. Amortization of this expense is therefore unjustified. (Testimony of Davis.)
Adjustment for Increased Chemical Costs
Because of escalating costs of chemicals, the Utility proposes to adjust the water and sewer chemicals account by applying June, 1981, prices to the quantity of chemicals consumed during the test year. The Commission opposes the proposed adjustment, contending that the Utility's new lime-feeding equipment will result in lower lime costs. The Utility's adjustments 14/ are accepted as credible; since a new Zeolite treatment plant will soon be coming
on-line, it is reasonably expected that lime requirements, associated with the water-softening process, will--if anything--increase. (Testimony of Farina, Davis, Asmus; R-6.)
Maintenance Expenses: Amortization of Post Test-Year Gearbox Repairs
The Utility proposes to include in sewer maintenance expense amortization of the cost of a gearbox repair incurred subsequent to the test year. The Commission proposes to amortize--for three to five years--all major repairs incurred during the test year. The Utility has not amortized such extraordinary repairs during each of the last five years; it contends that such historical amortization is necessary to arrive at a representative figure for extraordinary repair on an on-going basis, that the Commission cannot begin--for the first time--to amortize such repairs during the test year. The Utility proposes to simply adjust sewer maintenance expense by $3,386--an admittedly rough estimate. The Utility's accountant admits:
It would be a lot more exact to go back five years and apply it [amortization of extraordinary repairs] down the line. . .but that's very time-consuming. (Tr. 192.)
It is undisputed that the Utility--to properly account for extraordinary maintenance repairs--should amortize such expenses through the expected life of the repairs. The Utility has not done so to repairs incurred during the last five years. The substitution of an "estimate" of expected future repair costs for a preferable and more exact accounting method is unacceptable and should be rejected. (Testimony of Davis, Asmus.)
Depreciation Expense
The finding, infra, paragraph A(1) that the Utility's sewer plant is
100 percent used and useful necessarily requires an adjustment to the Commission's proposed depreciation expense. The adjustment increases depreciation, for sewer operations, by $11,897. (Testimony of Asmus; R-6.)
The net operating income which a utility should be allowed the opportunity to earn is reached by multiplying rate base by a fair rate of return. 15/ Operating expense and taxes (income and gross receipts tax) are then added to net operating income to calculate gross revenue requirements.
In this case, the Utility's net operating income should be $414,743 from water operations and $504,696 from sewer operations. Before gross revenue requirements can be determined, operating expense and taxes should be recalculated consistent with the above findings; such recalculation should be conducted by the Commission, verified by the Utility, and included as part of the Commission's final order entered in this proceeding.
Rate Structure, Allocation, and Rate Design
The Utility's present rates are structured in accordance with what is commonly referred to as the base facility rate design. The purpose of this design is to require customers to pay their pro rata share of the Utility's cost of providing the service. It is objectively determined and results in an equitable and consistent distribution of the costs involved. Both parties agree that the new rates should also be structured in accordance with the base facility rate design. However, the new rates should eliminate the present 25 percent rate differential between commercial and residential rates--a differential that has not been justified and which the Utility no longer seeks to impose.
Motorola, Inc., a large industrial customer of the Utility, requested more favorable rate treatment because of the large volume of water it consumes. However, insufficient cost of service information was submitted to justify a "volume discount." A cost of service study is necessary to accurately allocate costs of service among customer classes. (Testimony of Fabulo, Asmus; R-4.)
Quality of Service
Several customers complained that the Utility's water had offensive color and taste. Eight complaints were filed with the Broward County Health Department during 1980. However, the preponderance of evidence establishes that the Utility's water and sewer systems are in compliance with local and state standards. Neither system is under any citation or enforcement action instituted by a regulatory agency. The quality of the water and sewer service provided is, therefore, determined to be satisfactory. (Testimony of Farina, Walden; P-11)
CONCLUSIONS OF LAW
The Division of Administrative Hearings has jurisdiction over the subject matter and parties to this proceeding. Section 120.57(1), Florida Statutes (1979).
The criteria for setting the rates of a regulated public utility are contained in Section 367.081(1), (2), and (3), Florida Statutes (Supp. 1980):
Except as provided in subsection (4), rates and charges being charged and collected by a utility shall be changed only by approval of the commission.
The commission shall, either upon request or upon its own motion, fix rates which are just, reasonable, compensatory, and not unfairly discriminatory. In all such proceedings, the commission shall consider the value and quality of the service and the cost of providing the service, which shall include, but not be limited to, debt interest; the utility's requirements for working capital; maintenance, depreciation, tax, and operating expenses incurred in the public service; and a fair return on the utility's investment in property used and useful in the public service. However, the commission shall not allow the inclusion of contributions-in-aid-of- construction in the rate base of any utility during a rate proceeding; and accumulated depreciation on such contributions-in-aid-of- construction shall not be used to reduce the rate base, nor shall depreciation on such contributed assets be considered a cost of providing utility service. Contributions-in- aid-of-construction shall include any amount
or item of money, services, or property received by a utility, from any person or governmental agency, any portion of which is provided at no cost to the utility, which
represents a donation or contribution to the capital of the utility, and which is utilized to offset the acquisition, improvement, or construction costs of the utility's property, facilities, or equipment used to provide utility services to the public. The commission shall also consider the utility's investment in property required by duly authorized governmental authority to be constructed in the public interest within a reasonable time in the future, not to exceed
24 months.
The commission, in fixing rates, may determine the prudent cost of providing service during the period of time the rates will be in effect following the entry of a final order relating to the utility's rate request and may use such costs to determine the revenue requirements that will allow the utility to earn a fair rate of return on its rate base.
Pursuant to Section 367.081(2), the Utility has established its entitlement to gross annual revenue--as recalculated in accordance with paragraph II B. above; the rate structure it proposes is just, reasonable, and not unjustly discriminatory. Id. It should be allowed to file rate tariffs designed to generate the recalculated gross revenues, infra, based on the average number of customers served during the test year.
Proposed findings of fact were submitted by both parties. To the extent the proposed findings have not been adopted herein, they are rejected as unnecessary to resolution of the issues presented or unsupported by the evidence.
Based on the foregoing findings of fact and conclusions of law, it is RECOMMENDED:
That the Utility be authorized to file rate tariffs consistent with the provisions of this Recommended Order.
DONE AND RECOMMENDED this 21st day of August, 1981, in Tallahassee, Florida.
R. L. CALEEN, JR. Hearing Officer
Division of Administrative Hearings The Oakland Building
2009 Apalachee Parkway
Tallahassee, Florida 32301
(904) 488-9675
Filed with the Clerk of the Division of Administrative Hearings this 21st day of August, 1981.
ENDNOTES
1/ Petitioner's, Respondent's, and Customers' Exhibits will be referred to as "P- ," "R- ," and "C- ," respectively.
2/ Rate base represents the total investment in Utility property which provides the service for which rates are charged. This figure is then multiplied by a percentage, called "rate of return" to arrive at the allowed return which the Utility is given an opportunity to earn.
3/ Section 367.081(2), Florida Statutes (1979).
4/ In its proposed findings of fact filed on July 30, 1981, the Commission recalculated and concluded that an 82 percent used and useful figure was correct.
5/ One ERC equates to a theoretical flow of 350 gallons of wastewater per day.
6/ While the Commission's witness testified that a 15 percent reserve allowance should he used, in its subsequently filed proposed findings of fact, the Commission supports a 24 percent reserve allowance. (Testimony of Walden, Petitioner's Proposed Findings, p. 5.)
7/ "[S]ection 120.57 requires proof of incipient agency policy not expressed in rules and subjects it to countervailing evidence and argument." McDonald v.
Department of Banking and Finance, 346 So.2d 569, 579 (Fla. 1st DCA 1977).
8/ This is the APA's "self enforcing incentives for rule- making--those requirements concerning orders by which agencies will be pressed toward rule- making by the necessity otherwise to explicate and defend policy repeatedly in Section 120.57 proceedings.'" Anheuser-Busch, Inc., v. Department of Business Regulation, 393 So.2d 1177, 1182 (Fla. 1st DCA 1981).
9/ Anheuser-Busch, supra.
10/ This amount to $10,713 of which $4,821 is allocated to water and $5,892 is allocated to operation of the sewer system.
11/ See, Section 25-10.175, Florida Administrative Code.
12/ Included in Commission calculation of working capital allowance. 13/ Contributions in Aid of Construction.
14/ A reduction of chemical expenses for water operations of $1,724, an increase in sewer chemical expenses of $1,855, and a reversal of $4,060 to the Commission's proposed adjustment.
15/ The parties agree that the cost of capital to the Utility and a fair rate of return is 12.31 percent. (Prehearing Statement.)
COPIES FURNISHED:
B. Kenneth Gatlin, Esquire
318 North Monroe Street Tallahassee, Florida 32302
Marta M. Suarez-Murias, Esquire Public Service Commission
101 East Gaines Street Tallahassee, Florida 32301
Steve Tribble, Commission Clerk Public Service Commission
101 East Gaines Street Tallahassee, Florida 32301
| Issue Date | Proceedings |
|---|---|
| Jun. 15, 1990 | Final Order filed. |
| Aug. 21, 1981 | Recommended Order sent out. CASE CLOSED. |
| Issue Date | Document | Summary |
|---|---|---|
| Oct. 15, 1981 | Agency Final Order | |
| Aug. 21, 1981 | Recommended Order | Proposed rate increases are just and compensatory. |
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