Florida Public Service Commission native order document 01578-2023

Order No. PSC-2023-0101-PAA-WSFlapubserv

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FILED 2/28/2023
DOCUMENT NO. 01578-2023
FPSC - COMMISSION CLERK
BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
In re: Application for staff-assisted rate case in
Highlands County by LP Waterworks, Inc.
DOCKET NO. 20220099-WS
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ORDER NO. PSC-2023-0101-PAA-WS
ISSUED: February 28, 2023
The following Commissioners participated in the disposition of this matter:
ANDREW GILES FAY, Chairman
ARTGRAHAM
GARY F. CLARK
MIKE LAROSA
GABRIELLA P ASSIDOMO
NOTICE OF PROPOSED AGENCY ACTION
ORDER APPROVING RATE INCREASE FOR LP WATERWORKS AND ORDER ON
RECOVERY OF RATE CASE EXPENSES, AND TEMPORARY RA TES
BY THE COMMISSION:
NOTICE is hereby given by the Florida Public Service Commission (Commission) that
the actions discussed herein, except for (1) the reduction of rates after four years based upon the
recovery of rate case expense, (2) the granting of temporary rates in the event of protest, and (3)
the requirement for proof of adjustment of books and records, are preliminary in nature and will
become final unless a person whose interests are substantially affected files a petition for a
formal proceeding, pursuant to Rule 25-22.029, Florida Administrative Code (F .A.C.). The
reduction of rates after four years, the granting of temporary rates in the event of protest, and the
requirement for proof of adjustment of books and records are procedural agency actions a nd
subject to reconsideration and appeal as described below under the heading, "NOTICE OF
FURTHER PROCEEDINGS OR JUDICIAL REVIEW."
Case Background
LP Waterworks, Inc. (LP or utility) is a Class C water and wastewater utility located in
Highlands County. The utility is currently providing service to approximately 425 residential
customers, 21 general service customers, and 2 fire flow customers for its water system. The
utility is located in the water use caution area of the Southwest Florida Water Management
District (SWFWMD). According to the utility's 2021 Annual Report, the utility 's operating
revenues were $133,280 and operating expenses were $ 143 ,523 for water.
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On March 13, 2014, we approved the transfer of L.P. Utilities Corporation’s water and
wastewater systems and Certificate Nos. 620-W and 533-S to LP Waterworks, Inc.1 We last
established LP’s rates in a limited alternative rate increase proceeding in 2019.2
On May 17, 2022, the utility filed an application for a staff-assisted rate case (SARC)
requesting an increase for its water rates only. We selected the test year ended December 31,
2021. The official filing date was established as July 15, 2022. LP’s request for a SARC is based
upon a significant decrease in water consumption. A virtual customer meeting was held on
November 15, 2022. No customers spoke at the customer meeting.
We have jurisdiction pursuant to Sections 367.011, 367.081, 367.0812, 367.0814,
366.091, and 367.121, Florida Statutes (F.S.).
Review and Decision
1. Quality of Service
Pursuant to Section 367.081(2)(a)1, F.S., and Rule 25-30.433(1), Florida Administrative
Code (F.A.C.), in every rate case we make a determination of the quality of service provided by
the utility by evaluating the quality of the utility’s product (water) and the utility’s attempt to
address customer satisfaction (water and wastewater). The Rule requires that the most recent
chemical analyses, outstanding citations, violations, and consent orders on file with the DEP and
the county health department, along with any DEP and county health department officials’
testimony concerning quality of service shall be considered. In addition, any customer testimony,
comments, or complaints shall also be considered. The operating condition of the water system is
addressed below in Section 2.
A. 	Quality of Utility’s Product
In evaluation of LP’s product quality, we reviewed the utility’s compliance with the DEP
primary and secondary drinking water standards. Primary standards protect public health, while
secondary standards regulate contaminants that may impact the taste, odor, and color of drinking
water. The most recent comprehensive chemical analysis was performed on November 29, 2021.
All results were in compliance with the DEP’s standards.
B. 	The Utility’s Attempts to Address Customer Satisfaction
We reviewed the complaints filed in the Commission’s Consumer Activity Tracking
System (CATS), filed with the DEP, and received by the utility for the test year and four years
prior. During this time period, there were nine customer complaints filed in CATS, which were
1Order No. PSC-2014-0130-PAA-WS, issued March 17, 2014, in Docket No. 20130055, In re: Application for
approval of transfer of LP Utilities Corporation’s water and wastewater systems and Certificate Nos. 620-W and
533-S, to LP Waterworks, Inc., in Highlands County.
2Order No. PSC-2019-0141-PAA-WS, issued April 22, 2019, in Docket No. 20180215-WS, In re: Petition for
limited alternative rate increase in Highlands County by LP Waterworks, Inc.
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regarding billing and quality of service. These complaints addressed items such as poor water
taste and poor customer service. There was one complaint received by the DEP stating the water
was not properly chlorinated. However, DEP staff visited the facility and tested the chlorine
residual and found it to be within the appropriate range.
Over the past five years, the utility received 22 complaints associated with service
interruptions, 8 complaints regarding pressure issues, and 7 complaints addressing water quality.
Several of the service interruption complaints were due to outages the system experienced
following Hurricane Irma and the remaining complaints were related to issues such as water
main breaks or disconnections due to non-payment. Customer complaints regarding water quality
included reports of odor or cloudy water. All complaints were resolved by the utility. We note
that customer complaints have been decreasing over the past five years.
A virtual customer meeting was held on November 15, 2022. No customers spoke at the
customer meeting. A supplemental review of the complaints filed in CATS was conducted
following the customer meeting and we found no additional complaints. Four written comments
were submitted, three regarding billing and one regarding service quality.
C. Conclusion
LP has been responsive to customer complaints and is currently in compliance with the
DEP standards; therefore, the quality of service shall be considered satisfactory.
2. Infrastructure and Operating Conditions
Rule 25-30.225 F.A.C., requires that each water utility shall operate and maintain its
plant and facilities by employing qualified operators in accordance with the rules of the DEP in
order to provide safe and efficient service up to and including the point of delivery into the
piping owned by the customer. During a rate making proceeding, Rule 25-30.433(2), F.A.C.,
requires consideration of whether the infrastructure and operating conditions of the plant and
facilities are in compliance with Rule 25-30.225, F.A.C. In making this determination, we must
consider testimony of the DEP and county health department officials, sanitary surveys for water
systems and compliance evaluation inspections for wastewater systems, citations, violations, and
consent orders issued to the utility, customer testimony, comments, and complaints, and utility
testimony and responses to the aforementioned items.
A. 	Water System Operating Conditions
LP’s water system has two wells; one well is rated at 300 gallons per minute (gpm) and
the other well is rated at 280 gpm. We reviewed the November 19, 2020, sanitary survey
conducted by the DEP to determine the utility’s overall water facility compliance. The DEP
found no deficiencies or violations, and the system was determined to be in compliance.
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B. 	Conclusion
LP’s water system is currently in compliance with the DEP regulations.
3. Used and Useful Percentages
LP’s water treatment system has two wells. One well is rated at 300 gpm and the second
well is rated at 280 gpm. The utility’s water system has two hydropneumatic storage tanks
totaling 22,000 gallons in capacity. The distribution system is comprised of varying sizes of
polyvinyl chloride pipes.
A. 	Used and Useful Percentages
Rule 25-30.4325, F.A.C., addresses the method by which the U&U of a water system is
determined. LP’s U&U percentages were last determined in Docket No. 20160222-WS, and we
found the treatment facilities and distribution system were 100 percent U&U. The utility has not
increased the capacity of its facilities and the service area is built out. Therefore, consistent with
our previous decision, we find that the utility’s WTP and distribution system are 100 percent
U&U.
B. 	Excessive Unaccounted for Water
Rule 25-30.4325, F.A.C., additionally provides factors to be considered in determining
whether adjustments to operating expenses are necessary for EUW. EUW is defined as
"unaccounted for water in excess of 10 percent of the amount produced." Unaccounted for water
is all water produced that is not sold, metered, or accounted for in the records of the utility. A
review of the utility's Monthly Operating Reports, 2021 Annual Report, and audited billing data
indicate that LP treated 12,522,000 gallons and sold 6,929,000 gallons with 236,950 gallons used
for flushing and 2,580,000 gallons recorded for water main breaks during the test year. The
resulting 	calculation 	([12,522,000 	– 	6,929,000 	- 	236,950 	- 	2,580,000]/12,522,000) 	for
unaccounted for water is 22.2 percent; therefore, there is 12.2 percent EUW.
C. Conclusion
LP’s WTP and water distribution system shall be considered 100 percent U&U.
Additionally, there is 12.2 percent EUW; therefore, a 12.2 percent adjustment be made to
operating expenses for chemicals and purchased power.
4. Average Test Year Rate Base
The appropriate components of the utility’s rate base include utility plant in service
(UPIS), land and land rights, accumulated depreciation, contributions in aid of construction
(CIAC), accumulated amortization of CIAC, and working capital. The test year ended December
31, 2021, was selected for the instant case. Our audit determined that the utility’s books and
records are in compliance with the National Association of Regulatory Utility Commissioners’
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Uniform System of Accounts (NARUC USOA). A summary of each component and the
approved adjustments are discussed below.
A. 	Utility Plant in Service
The utility recorded UPIS of $664,237 for its water system. There were auditing
adjustments increasing UPIS by a net amount of $1,912 to reflect unrecorded retirements and to
capitalize an item that was expensed. In order to reflect the test year beginning and ending UPIS
average balance, we made an adjustment decreasing UPIS by $16,328.
The utility requested one pro forma item be included in rate base. The utility replaced the
generator controller at the water treatment plant due to a high voltage issue. The paid invoice for
this project shows a cost of $3,174. As shown in Table 1, we made a net adjustment increasing
UPIS by $794 for water pro forma plant additions.
In accordance with our standard practice, we requested that three bids be provided for the
pro forma project. However, due to the time-sensitive nature of this repair, the utility did not
obtain three bids. The new G series conversion on the transfer switch was replaced due to a high
voltage issue. This repair was necessary to ensure the generator remained functional in the event
of a power loss. The replacement of the generator controller at the water treatment plant was
necessary for the utility to provide safe and reliable service to its customers. We reviewed the
paid invoice provided by the utility and find that the cost for this project is appropriate.
Table 1
Pro Forma Plant Addition
Project
Acct.
No. 	Description
Amount
Water
Generator
Controller
310 	Installed and programed new G series
conversion. 	$3,174
Associated Retirement 	($2,381)
Net Adjustment 	$794
Source: Document No. 05055-2022.
Based on the above, we increased UPIS by $3,174 to reflect pro forma additions, offset
by a decrease of $2,381 for pro forma retirements.
As described above and summarized in Table 2 below, our adjustments to UPIS result in
a decrease of $13,622. We find an average UPIS balance of $650,615 ($664,237 - $13,622) for
the water system.
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Table 2
Adjustments to UPIS
Description 	Adjustment
To reflect auditing adjustments. 	$1,912
To reflect an averaging adjustment. 	(16,328)
To reflect pro forma additions. 	3,174
To reflect pro forma retirements. 	(2,381)
Total adjustment to UPIS. 	($13,622)
B. 	Land and Land Rights
The utility recorded a land and land rights balance of $27,412 for its water system. We
made no adjustments to this account, and therefore find a land and land rights balance of $27,412
for the water system.
C. Accumulated Depreciation
The utility recorded an accumulated depreciation balance of $460,542 for its water
system. We made auditing adjustments increasing accumulated depreciation by $21,358 to
reflect unrecorded retirements and to capitalize an item that was expensed. In order to reflect the
test year beginning and ending accumulated average balance, we decreased accumulated
depreciation by $19,329. We also made an adjustment decreasing accumulated depreciation by
$2,334 to reflect pro forma adjustments.
As described above and summarized in Table 3 below, our adjustments to accumulated
depreciation result in a decrease of $305. As such, we find an average accumulated depreciation
balance of $460,237 ($460,542 - $305) for the water system.
Table 3
Adjustments to Accumulated Depreciation
Description 	Adjustment
To reflect auditing adjustments. 	($21,358)
To reflect an averaging adjustment. 	19,329
To reflect pro forma adjustments. 	2,334
Total adjustment to accumulated depreciation. 	$305
D. Contributions in Aid of Construction
The utility recorded a CIAC balance of $268,967 for its water system. To reflect the test
year beginning and ending accumulated average balance, we decreased CIAC by $125. We find
an average CIAC balance of $268,842 ($268,967 - $125) for the water system.
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E. 	Accumulated Amortization of CIAC
The utility recorded an accumulated amortization of CIAC balance of $215,860 for its
water system. Using the correct composite rates to calculate amortization expense we made
auditing adjustments decreasing accumulated amortization of CIAC by $312. In order to reflect
the test year beginning and ending accumulated average balance, we decreased accumulated
amortization of CIAC by $3,954. Our adjustments to accumulated amortization of CIAC result in
a decrease of $4,266. As such, we find an average accumulated amortization of CIAC balance of
$211,595 ($215,860 - $4,266) for the water system.
F. 	Working Capital Allowance
The utility recorded a working capital balance of $15,221 for its water system. Working
capital is defined as the short-term investor-supplied funds that are necessary to meet operating
expenses. Consistent with Rule 25-30.433(3), F.A.C., we used the one-eighth operation and
maintenance (O&M) expense (less rate case expense) formula for calculating the working capital
allowance. Section 367.081(9), F.S., prohibits a utility from earning a return on the unamortized
balance of rate case expense. For this calculation, we removed the rate case expense balance of
$698. This resulted in an adjusted O&M expense balance of $123,669 ($124,367 - $698).
Applying this formula, we established a working capital allowance of $15,459 ($123,669/8) for
the water system. Thus, we find that the working capital allowance shall be increased by $238
($15,459 - $15,221).
G. Rate Base Summary
Based on the foregoing, we find that the appropriate average test year rate base is
$176,001 for the water system. Rate base is shown on Schedule No. 1-A. The related
adjustments are shown on Schedule No. 1-B.
5. Rate of Return
The utility’s reported capital structure consists of $200,588 in common equity and
$19,094 in customer deposits. The utility has no debt, and no test year adjustments are necessary.
The utility’s capital structure has been reconciled with our approved rate base. The appropriate
ROE is 7.84 percent based upon the approved leverage formula currently in effect.3 We find an
ROE of 7.84 percent, with a range of 6.84 percent to 8.84 percent, and an overall rate of return of
7.33 percent. The ROE and overall rate of return are shown on Schedule No. 2.
6. Test Year Revenues
LP recorded test year revenues of $133,280. The water revenues included $128,056 of
service revenues and $5,224 of miscellaneous revenues. We annualized service revenues by
3Order No. PSC-2022-0208-PAA-WS, issued June 15, 2022, in Docket No. 20220006-WS, In re: Water and
wastewater industry annual reestablishment of authorized range of return on common equity for water and
wastewater utilities pursuant to Section 367.081(4)(f), F.S.
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applying the number of billing determinants to the utility’s existing rates, which became
effective September 22, 2021. As a result, we determined that service revenues shall be
$117,062, which is a decrease of $10,994 ($128,056 - $117,062). Using the number of
occurrences and the approved miscellaneous service charges, we determined that miscellaneous
revenues are $5,281, which is an increase of $57 ($5,281 - 1,224). Based on the above, the
appropriate test year revenues for LP’s water system, including miscellaneous revenues are
$122,343 ($117,062 + $5,281).
7. Operating Expenses
The utility recorded operating expense of $149,439 for its water system. We have
reviewed the test year O&M expenses, including invoices and other supporting documentation.
We have made several adjustments to the utility’s operating expenses as described below.
A. Operation and Maintenance Expenses
Purchased Power (615)
The utility recorded a purchased power expense of $2,406 for its water system. We made
an auditing adjustment to increase purchased power expense by $132 based on the calculation of
actual power bills. Additionally, as discussed above, we established a 12.2 percent reduction to
purchased power expense to reflect EUW. As such, we made an adjustment to reduce purchased
power expense by $310. Our adjustments result in a net decrease of $178. Therefore, we find a
purchased power expense of $2,228 ($2,406 - $178) for the water system.
Chemicals (618)
The utility did not record any chemicals expense for its water system as it did not
purchase chemicals in the test year. To correct this error, LP requested a pro forma increase to
chemicals expense of $1,000. Additionally, as discussed above, we found a 12.2 percent
reduction to chemicals expense to reflect EUW. As such, we made an adjustment to reduce
chemicals expense by $122. Thus, we find a chemicals expense of $878 ($1,000 - $122) for the
water system.
Rental Expense (640)
The utility recorded a rental expense of $855 for its water system. We made an auditing
adjustment to reclassify the rental expense as a miscellaneous expense. As such, we find a rental
expense of $0 for the water system.
Insurance Expense (655)
The utility recorded an insurance expense of $878 for its water system. We made an
auditing adjustment to increase insurance expense by $75 based on the actual bill amount.
Therefore, we find an insurance expense of $953 ($878 + $75) for the water system.
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Rate Case Expense (665)
The utility recorded a rate case expense of $619. The utility is required by Rule 25-
22.0407, F.A.C., to mail notices of the rate case overview, final rates, and four-year rate
reduction. We calculated noticing costs to be $1,322 and the distance from the utility to
Tallahassee as 215 miles. Based on the 2022 IRS business mileage rate of $0.625, we calculated
a round-trip travel expense to the Commission Conference and back, as well as one night of
lodging to be $469. We calculated a total amount of noticing costs and travel expense of $1,790
($1,322 + $469). Additionally, the utility paid a filing fee of $1,000. We find a total rate case
expense of $2,790 ($1,790 + $1,000), which amortized over four years is $698 ($2,790 ÷ 4
years); and an increase to rate case expense of $79 and an annual rate case expense of $698
($619 + $79) for the water system.
Miscellaneous Expenses (675)
The utility recorded miscellaneous expenses of $863. As discussed above, we made an
auditing adjustment to reclassify $855 recorded in rental expense as a miscellaneous expense. LP
requested a pro forma increase of $1,127 to account for emergency monitoring system services.
As such, we find miscellaneous expenses of $2,845 ($863 + $1,127 + $855) for the water
system.
B. 	Operation and Maintenance Expense Summary
The utility recorded test year O&M expenses of $122,386 for its water system. Based on
the above adjustments, we find the O&M expense shall be increased by $1,981. This results in
total O&M expenses of $124,367 ($122,386 + $1,981) for the water system. Our findings
concerning adjustments to O&M expenses are shown on Schedule 3-C.
C. Depreciation Expense
The utility recorded net depreciation expense of $12,015 ($20,233 depreciation expense
less $8,218 CIAC amortization expense) for its water system. Using the depreciation rates
prescribed in Rule 25-30.140, F.A.C., we increased depreciation expense for water by $47 to
reflect the incremental depreciation expense associated with pro forma investments. LP recorded
CIAC amortization expense of $8,218. Using the correct composite rates, we made an auditing
adjustment to increase CIAC amortization expense by $1,626. As such, we find CIAC
amortization expense of $9,844 ($8,218 + $1,626) for the water system. Therefore, we find net
depreciation expense of $10,436 ($20,233 + $47 – 9,844) for the water system.
D. Amortization Expense
The utility recorded amortization expense of $4,299 for a non-recurring expense related
to sandblasting and painting of a hydro tank completed in January, 2019. LP provided an invoice
supporting the expense.4 According to the provided invoice, the total cost was $21,494. Rule 25-
4 DN 00218-2023
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30.433(9), F.A.C., requires that non-recurring expenses be amortized over a five-year period
unless a shorter or longer period of time can be justified. We verified one year of amortization
expense to be $4,299 ($21,494/5). Additionally, a five-year period will not expire until 2024.
Therefore, we find an amortization expense of $4,299 for the water system.
E. Taxes Other Than Income (TOTI)
The 	utility 	recorded 	TOTI 	of 	$10,739 	for 	its 	water 	system. 	We 	made 	auditing
adjustments to decrease TOTI by $222 to reflect the proper amount of property taxes, as well as
Regulatory Assessment Fees (RAFs) based on the auditor’s test year revenues. We further
decreased TOTI by $12 to reflect the RAFs based on corrected utility test year revenues. We also
increased TOTI by $10 to reflect property taxes associated with pro forma additions. We find an
increase in revenues by $42,071, in order to reflect the change in revenue required to cover
expenses and allow an opportunity to earn the approved rate of return. As a result, TOTI is
increased by $1,893 to reflect RAFs of 4.5 percent of the change in revenues. As such, we find a
TOTI of $12,408 ($10,739 - $222 - $12 + $10 + $1,893) for the water system.
F. Operating Expense Summary
The utility recorded operating expenses of $149,439 for its water system. The application
of our adjustments to the utility’s operating expenses results in a total operating expense of
$151,509. Operating expenses are shown on Schedule No. 3-A, and the related adjustments are
shown on Schedule No. 3-B.
8. Operating Ratio Methodology
Rule 25-30.4575(2), F.A.C., provides that, in rate cases processed under Rule 25-30.455,
F.A.C., we will use the operating ratio methodology to establish the utility’s revenue requirement
when its rate base is not greater than 125 percent of O&M expenses and the use of the Operating
Ratio Methodology does not change the utility’s qualification for a SARC.
Under the Operating Ratio Methodology, instead of calculating the utility’s revenue
requirement based on a rate of return on rate base, the revenue requirement is calculated using a
margin of 12 percent of O&M expenses, not to exceed $15,000. Purchased water and wastewater
expenses, if any, must be removed from O&M expense prior to calculating the margin of 12
percent.
With respect to LP, we find a rate base of $176,001 for the water system. We also
calculated an O&M expense of $124,367. Based upon our review, the utility’s rate base is 142
percent of its O&M expense for its water system. Based on the above, the utility does not qualify
for application of the Operating Ratio Methodology.
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9. Revenue Requirement
LP shall be allowed an annual increase of $42,071 (34.39 percent) for its water system.
This shall allow the utility the opportunity to recover its expenses and earn a 7.33 percent return
on rate base. The calculations for the water system are shown in Table 4.
Table 4
Water Revenue Requirement
Water Rate Base 	$176,001
Rate of Return 	7.33%
Return on Rate Base 	$12,905
Water O&M Expense 	$124,367
Depreciation Expense 	$10,436
Amortization Expense 	$4,299
Taxes Other Than Income 	$12,408
Revenue Requirement 	$164,414
Less Test Year Revenues 	$122,343
Annual Increase 	$42,071
Percent Increase 	34.39%
Source: our staff’s calculations.
10. Rate Structure
LP is located in Highlands County within the SWFWMD. The utility provides water
service to approximately 425 residential customers, 2 fire flow customers, and 21 general service
customers. Approximately 51 percent of the residential customer bills had zero gallons indicating
a very seasonal customer base. The average water demand is 1,100 gallons per month. The
average water demand excluding zero gallon bills is 2,266 gallons per month. Currently, the
utility’s residential water rate structure consists of a base facility charge (BFC) and a two-tier
inclining block rate structure. The rate blocks are: (1) 0-3,000 gallons and (2) all usage in excess
of 3,000 gallons per month. The general service rate consists of a BFC and uniform gallonage
charge. Moreover, the utility’s private fire protection service rates are based on one-twelfth of
the utility’s BFC for each meter size pursuant to Rule 25-30.465, F.A.C.
We analyzed the utility’s billing in order to evaluate the appropriate rate structure for the
residential water customers. The goal of the evaluation was to select the rate design parameters
that: (1) produce the approved revenue requirement; (2) equitably distribute cost recovery among
the utility’s customers; (3) establish the appropriate non-discretionary usage threshold for
restricting repression; and (4) implement, where appropriate, water conserving rate structures
consistent with our standard practice.
The customer base is very seasonal coupled with low average consumption. The utility’s
current BFC allocation is 52 percent, which is typical for a seasonal customer base. In this case,
the utility has experienced a significant decrease in consumption and we have determined it is
appropriate to have more of the cost recovery in the BFC. For this reason, we find that 60 percent
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of the revenue requirement be recovered through the BFC in an effort to provide revenue
stability for this utility. Furthermore, the average people per household served by the water
system is 2; therefore, based on the number of people per household, 50 gallons per day per
person, and the number of days per month the discretionary usage threshold shall be 3,000
gallons per month.5 Our review of the billing data indicate that discretionary usage above 3,000
gallons represents 7 percent of the bills, which accounts for approximately 37 percent of the
water demand. This is an indication that there is a significant amount of discretionary usage
above 3,000 gallons.
We find that it is appropriate to continue the utility’s current rate structure, which
includes separate gallonage charges for discretionary and non-discretionary usage for residential
water customers. The rate blocks are: (1) 0-3,000 gallons and (2) all usage in excess of 3,000
gallons per month. Due to the high usage above 3,000 gallons per month we find it is appropriate
in this case to approve a rate factor of 1.50 in the second tier because it will target those
customers with high consumption levels. General Service customers shall continue to be billed a
BFC and a gallonage charge.
Based on a revenue increase of 35.9 percent, which excludes miscellaneous revenues, the
residential consumption can be expected to decline by 105,000 gallons resulting in anticipated
average residential demand of 1,078 gallons per month. We also find a 2.1 percent reduction in
test year gallons for rate setting purposes. As a result, the corresponding reductions are $34 for
purchased power expense, $13 for chemical expense, and $2 for RAFs to reflect the anticipated
repression, which results in a post repression revenue requirement of $159,084.
11. Appropriate Miscellaneous Charges
Effective June 24, 2021, Rule 25-30.460, F.A.C., was amended to remove initial
connection and normal reconnection charges.6 The definitions for initial connection charges and
normal reconnection charges were subsumed in the definition of the premises visit charge.
LP’s current miscellaneous service charges consist of initial connection and normal
reconnection charges. Since the premises visit entails a broader range of tasks, the premises visit
shall reflect the amount of normal reconnection charges of $57.89 for normal hours and $65.50
for after hours. Although this proceeding is for the water system, in order to maintain uniformity
with the miscellaneous service charges, the wastewater miscellaneous service charges shall be
revised pursuant to the amended rule. Therefore, we find that the initial connection and normal
reconnection charges be removed for both water and wastewater, and the definition for the
premises visit charge be updated to comply with amended Rule 25-30.460, F.A.C. The premises
visit charge shall be revised from $31.53 for normal hours and $36.70 for after hours to $57.89
for normal hours and $65.60 for after hours for both water and wastewater. The violation
reconnection shall also remain at $57.89 for normal hours and $65.60 for after hours and at
actual 	cost 	for 	wastewater. 	The 	utility’s 	current 	miscellaneous 	service 	charges 	and 	our
5Average person per household was obtained from www.census.gov/quickfacts/polkcounty.
6Order No. PSC-2021-0201-FOF-WS, issued June 4, 2020, in Docket No. 20200240-WS, In re: Proposed
amendment of Rule 25-30.460, F.A.C., Application for Miscellaneous Service Charges.
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS
PAGE 13
determination of the appropriate miscellaneous service charges are shown below in Tables 5 and
6.
Table 5
Utility’s Current Miscellaneous Service Charges
Normal Hours 	After Hours
Initial Connection Charge 	$31.53 	$36.70
Normal Reconnection Charge 	$57.89 	$65.60
Violation Reconnection Charge – Water 	$57.89 	$65.60
Violation Reconnection Charge – Wastewater 	Actual Cost 	Actual Cost
Premises Visit Charge 	$31.53 	$36.70
Table 6
Approved Miscellaneous Service Charges
Normal Hours 	After Hours
Violation Reconnection Charge - Water 	$57.89 	$65.60
Violation Reconnection Charge -Wastewater 	Actual Cost 	Actual Cost
Premises Visit Charge 	$57.89 	$65.60
Based on the above, we find that the miscellaneous service charges for both water and
wastewater be revised to conform to the recent amendment to Rule 25-30.460, F.A.C. The tariff
shall be revised to reflect the removal of initial connection and normal reconnection charges. LP
is required to file a proposed customer notice to reflect our approved charges. The approved
charges shall 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 shall not be implemented until our
staff has approved the proposed customer notice and the notice has been received by customers.
The utility shall provide proof of the date notice was given no less than 10 days after the date of
the notice.
12. Appropriate Initial Customer Deposits
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, we have set
initial customer deposits equal to two times the average estimated bill.7 Currently, the utility’s
initial deposit for residential water is $45 for the 5/8 inch x 3/4 inch meter size and two times the
average estimated bill for all other meter sizes and all general service meter sizes. However, this
amount does not cover two months’ average bills based on our approved rates. The utility’s
average monthly residential water usage after repression is 1,078 gallons per customer.
7Order No. PSC-2015-0142-PAA-SU, issued March 26, 2015, in Docket No. 20130178-SU, In re: Application for
staff-assisted rate case in Polk County by Crooked Lake Park Sewerage Company.
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS
PAGE 14
Therefore, the average residential monthly bill based on our approved rates is approximately
$23.94.
We have determined the appropriate initial customer deposits shall be $48 for the
residential 5/8 inch x 3/4 inch meter size for water. The initial customer deposits for all other
residential meter sizes and all general service meter sizes shall be two times the average
estimated bill for water. The approved initial customer deposits shall 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 shall collect the approved deposits until authorized to
change them by us in a subsequent proceeding.
13. Four-Year Rate Reduction
Section 367.081(8), F.S., requires that the rates be reduced immediately following the
expiration of the recovery period by the amount of the rate case expense previously included in
rates. The reduction shall reflect the removal of revenue associated with the amortization of rate
case expense and the gross-up for RAFs. The total reduction for water is $730.
We have determined that the rates be reduced as shown on Schedule No 4, to remove rate
case expense grossed-up for RAFs and amortized over a four-year period. The decrease in rates
shall be effective immediately following the expiration of the rate case expense recovery period,
pursuant to Section 367.081(8), F.S. LP shall file revised tariffs and a proposed customer notice
setting forth the lower rates and the reason for the reduction no later than one month prior to the
actual date of the required rate reduction. If the utility files this reduction in conjunction with a
price index or pass-through rate adjustment, the utility shall file separate data for the price index
and/or pass-through increase or decrease and the reduction in the rates due to the amortized rate
case expense.
14. Recommended Rates on a Temporary Basis
We have determined that an increase in rates is appropriate. A timely protest might delay
a rate increase resulting in an unrecoverable loss of revenue to the utility. Therefore, pursuant to
Section 367.0814(7), F.S., in the event of a protest filed by a party other than the utility, our
approved rates are effective on a temporary basis. LP shall file revised tariff sheets and a
proposed customer notice reflecting our approved rates. The approved rates are effective for
service rendered on or after the stamped approval date on the tariff sheet, pursuant to Rule 25-
30.475(1), F.A.C. In addition, the temporary rates shall not be implemented until we have
approved the proposed notice, and it has been received by the customers. The additional revenue
produced by our approved rates and collected by the utility shall be subject to the refund
provisions discussed below.
LP is authorized to initiate the temporary rates upon our approval of an appropriate
security for the potential refund and cost of the proposed customer notice. Security shall be in the
form of either a bond or letter of credit in the amount of $28,816. Alternatively, the utility may
establish an escrow agreement with an independent financial institution.
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS
PAGE 15
If the utility chooses a bond for securing the potential refund, the bond shall contain
wording to the effect that it will be terminated only under the following conditions:
1. 	We approve the rate increase; or,
2. 	If we deny the increase, the utility shall refund the amount collected that is attributable to
the increase.
If the utility chooses a letter of credit for securing the potential refund, the letter of credit
shall contain the following conditions:
1. 	The letter of credit is irrevocable for the period it is in effect.
2. 	The letter of credit shall be in effect until our final order is rendered, either approving or
denying the rate increase.
If security is provided through an escrow agreement, the following conditions shall be
part of the agreement:
1. The Commission Clerk, or his or her designee, must be a signatory to the escrow
agreement.
2. No monies in the escrow account may be withdrawn by the Utility without the prior
written authorization of the Commission Clerk, or his or her designee.
3. The escrow account shall be an interest bearing account.
4. If a refund to the customers is required, all interest earned by the escrow account
shall be distributed to the customers.
5. If a refund to the customers is not required, the interest earned by the escrow account
shall revert to the Utility.
6. All information on the escrow account shall be available from the holder of the
escrow account to a Commission representative at all times.
7. The amount of revenue subject to refund shall be deposited in the escrow account
within seven days of receipt.
8. This escrow account is established by the direction of the Florida Public Service
Commission for the purpose(s) set forth in its order requiring such account.
Pursuant to Cosentino v. Elson, 263 So. 2d 253 (Fla. 3d DCA 1972), escrow
accounts are not subject to garnishments.
9. The account must specify by whom and on whose behalf such monies were paid.
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS
PAGE 16
In no instance shall the maintenance and administrative costs associated with the refund
be borne by the customers. These costs are the responsibility of, and shall be borne by, the
utility. Irrespective of the form of security chosen by the utility, an account of all monies
received as a result of the rate increase shall be maintained by the utility. If a refund is ultimately
required, it shall be paid with interest calculated pursuant to Rule 25-30.360(4), F.A.C.
The utility shall maintain a record of the amount of the bond, and the amount of revenues
that are subject to refund. In addition, after the increased rates are in effect, pursuant to Rule 25-
30.360(6), F.A.C., the utility shall file reports with the Commission Clerk’s office no later than
the 20th of every month indicating the monthly and total amount of money subject to refund at
the end of the preceding month. The report filed shall also indicate the status of the security
being used to guarantee repayment of any potential refund.
15. Adjustment to Books
LP shall notify us, in writing, that it has adjusted its books in accordance with our
decision. LP shall submit a letter within 90 days of the final order in this docket, confirming that
the adjustments to all the applicable NARUC USOA primary accounts as shown on Schedule
No. 5 have been made to the utility’s books and records. In the event the utility needs additional
time to complete the adjustments, notice providing good cause shall be filed not less than seven
days prior to the deadline. Upon providing good cause, our staff has administrative authority to
grant an extension of up to 60 days.
Based on the foregoing, it is
ORDERED by the Florida Public Service Commission that LP Waterworks, Inc. is
currently in compliance with the Department of Environmental Protection (DEP) standards;
therefore, the quality of service is considered satisfactory. It is further
ORDERED the infrastructure and operating conditions of the utility’s water system are in
compliance with DEP regulations. It is further
ORDERED that LP’s WTP and water distribution system is considered 100 percent
U&U. There is 12.2 percent EUW; therefore, a 12.2 percent adjustment shall be made to
operating expenses for chemicals and purchased power. It is further
ORDERED that the appropriate average test year rate base for LP is $176,001 for the
water system. It is further
ORDERED that the appropriate return on equity (ROE) is 7.84 percent with a range of
6.84 percent to 8.84 percent. The appropriate overall rate of return is 7.33 percent. It is further
ORDERED that the appropriate test year revenues for LP’s water system are $122,343. It
is further
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS
PAGE 17
ORDERED that the appropriate amount of operating expense for LP is $151,509 for its
water system. It is further
ORDERED that LP does not meet the requirement for application of the Operating Ratio
Methodology for calculating the revenue requirement. It is further
ORDERED that the appropriate revenue requirement for LP's water system is $164,414
for the water system, resulting in an annual increase of $42,071 (34.39 percent). It is further
ORDERED that the approved rate structure monthly water rates are shown on Schedule
No. 4. The utility shall file revised tariff sheets and a proposed customer notice to reflect our
approved rates. The approved rates are effective for service rendered on or after the stamped
approval date on the tariff sheets pursuant to Rule 25-30.475(1), F.A.C. In addition, the approved
rates shall not be implemented until we have approved the proposed customer notice and the
notice has been received by the customers. The utility shall provide proof of the date notice was
given within 10 days of the date of the notice. It is further
ORDERED that the miscellaneous service charges for both water and wastewater shall be
revised to conform to the recent amendment to Rule 25-30.460, F.A.C. The tariff shall reflect the
removal of initial connection and normal reconnection charges. LP shall file a proposed customer
notice to reflect our approved charges. The approved charges shall 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 shall not be implemented until we have approved the proposed customer notice
and the notice has been received by customers. The utility shall provide proof of the date notice
was given no less than 10 days after the date of the notice. It is further
ORDERED that the appropriate initial customer deposits shall be $48 for the residential
5/8 inch x 3/4 inch meter size for water. The initial customer deposits for all other residential
meter sizes and all general service meter sizes shall be two times the average estimated bill for
water. The approved initial customer deposits shall 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
shall be required to collect the approved deposits until authorized to change them by us in a
subsequent proceeding. It is further
ORDERED that the rates shall be reduced as shown on Schedule No. 4, to remove rate
case expense grossed-up for regulatory assessment fees (RAFs) and amortized over a four-year
period. Pursuant to Section 367.081(8), F.S., the decrease in rates shall become effective
immediately following the expiration of the rate case expense recovery period. LP shall file
revised tariffs and a proposed customer notice setting forth the lower rates and the reason for the
reduction no later than one month prior to the actual date of the required rate reduction. If the
utility files this reduction in conjunction with a price index or pass-through rate adjustment, the
utility shall file separate data for the price index and/or pass-through increase or decrease and the
reduction in the rates due to the amortized rate case expense. It is further
ORDERED that, pursuant to Section 367.0814(7), F.S., the approved rates for the utility
are temporary and subject to refund with interest in the event of a protest filed by a party other
ORDER NO. PS C-2023-0 10 1-P AA -W S
DOCKET NO. 20220099- WS
PA GE 18
than th e utilit y. LP sha ll fil e rev ise d tariff sheets a nd a p ro posed cus tom er not ice re fl ecting the
appro ve d rates. The appro ve d rates are effective fo r serv ices rendered on or after th e sta mp ed
approva l date on t he tariff shee t, pursua nt to 	Rule 25-30 .4 75( I), 	F.A.C. In a dd ition, the
te mporary rates sha ll not be im plemented un t il we have ap proved the proposed notice, a nd the
notice ha s been received by th e customer s. Further, prior to im plementing an y te mp orary ra tes,
th e util ity shall prov id e appro pri ate fin ancial sec uri ty. It is further
ORDERED that LP sha ll no tify us, in writing, that it has adju sted its books in accordance
w ith our decisio n. LP shall submit a letter within 90 da ys of the fin al o rd er in thi s docket,
confirming th at th e adju s tm e nt s to a ll ap pli cab le NA RUC US OA primary accounts as shown on
Sc hed ule No. 5 h av e been made to th e utilit y's books and records. In the event the utili ty needs
add itional time to co mpl ete the adjus tm e nt s, noti ce providing good cause sha ll be fi led not less
than 	seven days 	prior 	to 	the 	dead line. 	Upo n 	providing 	good 	cause, 	o ur 	staff has 	th e
admini strative authority to grant an extension of up to 60 days. It is further
ORD ERED that if no person whose s ub stantial int erests are affected by th e proposed
agency action tiles a p ro te st within 2 1 days of the issuance of th e Proposed Agency Action
Order, a Cons umm at in g O rd er sha ll be issued. Th e docket sha ll remain open for o ur ve rification
that th e revised tariff sheets and customer no ti ce have been fil ed by th e utility a nd approved by
our staff. Once th ese ac ti ons are co mpl e te , thi s docket sha ll be closed ad mini strati ve ly.
WLT
By ORDER of the Flor id a Pub li c Service Co mmi ss ion t hi s 28th day of Feb ru ary, 20 23 .
Co mmi ss ion Cle rk
Flor ida Publ ic Service Com mi ss ion
2540 Shuma rd Oak Bo ul eva rd
Ta ll ahassee, Florida 32399
(850) 413 -6770
www. fl o ri dapsc.com
Co pi es fu rni she d: A copy of t hi s docume nt is
prov id ed to th e pa rti es of record at the tim e of
iss uance a nd , if app licable, interested perso ns.
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS
PAGE 19
NOTICE OF FURTHER PROCEEDINGS OR JUDICIAL REVIEW
The Florida Public Service Commission is required by Section 120.569(1), Florida
Statutes, to notify parties of any administrative hearing or judicial review of Commission orders
that is available under Sections 120.57 or 120.68, Florida Statutes, as well as the procedures and
time limits that apply. 	This notice should not be construed to mean all requests for an
administrative hearing or judicial review will be granted or result in the relief sought.
As identified in the body of this order, our actions are preliminary in nature, except for
(1) the reduction of rates after four years based upon the recovery of rate case expense, (2) the
granting of temporary rates in the event of protest, and (3) the requirement for proof of
adjustment of books and records. 	Any person whose substantial interests are affected by the
action proposed by this order may file a petition for a formal proceeding, in the form provided by
Rule 28-106.201, Florida Administrative Code. This petition must be received by the Office of
Commission Clerk, at 2540 Shumard Oak Boulevard, Tallahassee, Florida 32399-0850, by the
close of business on March 21, 2023. If such a petition is filed, mediation may be available on a
case-by-case basis. 	If mediation is conducted, it does not affect a substantially interested
person's right to a hearing. 	In the absence of such a petition, this order shall become effective
and final upon the issuance of a Consummating Order.
Any objection or protest filed in this docket before the issuance date of this order is
considered abandoned unless it satisfies the foregoing conditions and is renewed within the
specified protest period.
Any party adversely affected by the Commission's procedural action in this matter may
request: (1) reconsideration of the decision by filing a motion for reconsideration with the Office
of Commission Clerk, within fifteen (15) days of the issuance of this order in the form prescribed
by Rule 25-22.060, Florida Administrative Code; or (2) judicial review by the Florida Supreme
Court in the case of an electric, gas or telephone utility or the First District Court of Appeal in
the case of a water or wastewater utility by filing a notice of appeal with the Office of
Commission Clerk and filing a copy of the notice of appeal and the filing fee with the
appropriate court. This filing must be completed within thirty (30) days after the issuance of this
order, pursuant to Rule 9.110, Florida Rules of Appellate Procedure. The notice of appeal must
be in the form specified in Rule 9.900(a), Florida Rules of Appellate Procedure.
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS 	Schedule 1-A
PAGE 20
LP WATERWORKS, INC. 	SCHEDULE NO. 1-A
TEST YEAR ENDED 12/31/2021 	DOCKET NO. 20220099-WS
SCHEDULE OF WATER RATE BASE
BALANCE
PER 	APPROVED 	APPROVED
DESCRIPTION 	UTILITY 	ADJUST. 	BALANCE
1. 	UTILITY PLANT IN SERVICE 	$664,237 	($13,622) 	$650,615
2. 	LAND & LAND RIGHTS 	27,412 	0 	27,412
3. 	ACCUMULATED DEPRECIATION 	(460,542) 	305 	(460,237)
4. 	CIAC 	(268,967) 	125 	(268,842)
5. 	ACCUMULATED AMORT. CIAC 	215,860 	(4,266) 	211,595
6. 	WORKING CAPITAL ALLOWANCE 	15,221 	238 	15,459
7. 	WATER RATE BASE 	$193,221 	($17,220) 	$176,001
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS 	Schedule 1-B
PAGE 21
LP WATERWORKS, INC. 	SCHEDULE NO. 1-B
TEST YEAR ENDED 12/31/2021 	DOCKET NO. 20220099-WS
ADJUSTMENTS TO RATE BASE
WATER
UTILITY PLANT IN SERVICE
1. 	To reflect unrecorded retirements and reclassify expense. 	$1,912
2. 	To reflect an averaging adjustment. 	(16,328)
3. 	To reflect pro forma additions. 	3,174
4. 	To reflect pro forma retirements. 	(2,381)
Total 	($13,622)
ACCUMULATED DEPRECIATION
1. 	To reflect corresponding adjustments made to plant. 	($21,358)
2. 	To reflect an averaging adjustment. 	19,329
3. 	To reflect pro forma adjustments. 	2,334
Total 	$305
CIAC
To reflect an averaging adjustment. 	$125
ACCUMULATED AMORTIZATION OF CIAC
1. 	To reflect calculations using correct composite rates. 	($312)
2. 	To reflect an averaging adjustment. 	(3,954)
Total 	($4,266)
WORKING CAPITAL ALLOWANCE
To reflect 1/8 of test year O&M expenses. 	$238
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS 	Schedule 2
PAGE 22
LP WATERWORKS, INC. 	SCHEDULE NO. 2
TEST YEAR ENDED 12/31/2021 	DOCKET NO. 20220099-WS
SCHEDULE OF CAPITAL STRUCTURE
BALANCE 	PRO RATA 	BALANCE 	PERCENT
PER 	ADJUST- 	PER 	OF 	WEIGHTED
COMPONENT 	UTILITY 	MENTS 	STAFF 	TOTAL 	COST 	COST
1. 	LONG-TERM DEBT 	$0 	$0 	$0 	0.00% 	0.00% 	0.00%
2. 	SHORT-TERM DEBT 	0 	0 	0 	0.00% 	0.00% 	0.00%
3. 	COMMON EQUITY 	200,588 	(39,885) 	160,703 	91.31% 	7.84% 	7.16%
4. 	CUSTOMER DEPOSITS 	19,094 	(3,797) 	15,297 	8.69% 	2.00% 	0.17%
5. 	DEFERRED INCOME TAXES 	0 	0 	0 	0.00% 	0.00% 	0.00%
6. 	TOTAL CAPITAL 	$219,682 	($43,681) 	$176,001 	100.00% 	7.33%
RANGE OF REASONABLENESS 	LOW 	HIGH
RETURN ON EQUITY 	6.84% 	8.84%
OVERALL RATE OF RETURN 	6.42% 	8.25%
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS 	Schedule 3-A
PAGE 23
LP WATERWORKS, INC. 	SCHEDULE NO. 3-A
TEST YEAR ENDED 12/31/2021 	DOCKET NO. 20220099-WS
SCHEDULE OF WATER OPERATING INCOME
TEST 	APPROVED 	APPROVED 	ADJUST
YEAR PER 	ADJUST- 	ADJUSTED 	FOR 	REVENUE
UTILITY 	MENTS 	TEST YEAR 	INCREASE 	REQUIREMENT
1. 	TOTAL OPERATING REVENUES 	$133,280 	($10,937) 	$122,343 	$42,071 	$164,414
34.39%
OPERATING EXPENSES
2. 	OPERATION & MAINTENANCE 	$122,386 	$1,981 	$124,367 	$0 	$124,367
3. 	NET DEPRECIATION 	12,015 	(1,579) 	10,436 	0 	10,436
4 	AMORTIZATION 	4,299 	0 	4,299 	0 	4,299
5. 	TAXES OTHER THAN INCOME 	10,739 	(224) 	10,515 	1,893 	12,408
6. 	INCOME TAXES 	0 	0 	0 	0 	0
TOTAL OPERATING EXPENSES 	$149,439 	$177 	$149,616 	$1,893 	$151,509
7. 	OPERATING INCOME / (LOSS) 	($16,159) 	($27,273) 	$12,905
8. 	WATER RATE BASE 	$193,221 	$176,001 	$176,001
9. 	RATE OF RETURN 	(8.36%) 	(15.50%) 	7.33%
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS 	Schedule 3-B
PAGE 24
LP WATERWORKS, INC. 	SCHEDULE NO. 3-B
TEST YEAR ENDED 12/31/2021 	DOCKET NO. 20220099-WS
ADJUSTMENTS TO OPERATING INCOME
WATER
OPERATING REVENUES
1. 	To reflect an auditing adjustment to service revenues. 	($10,994)
2. 	To reflect an auditing adjustment to miscellaneous revenues. 	57
Total 	($10,937)
OPERATION AND MAINTENANCE EXPENSE
1. 	Purchased Power (615)
a. To reflect actual amount from power bills. 	$132
b. To reflect EUW adjustment. 	(310)
Total 	($178)
2. 	Chemicals Expense (618)
a. To reflect pro forma for unrecorded chemical expense. 	$1,000
b. To reflect EUW adjustment. 	(122)
Total 	$894
3. 	Rental Expense (640)
To reclassify property owner’s association fees. 	($855)
4. 	Insurance Expense (655)
To reflect actual bill amounts. 	$75
5. 	Rate Case Expense (665)
To reflect 1/4 rate case expense. 	$79
6. 	Miscellaneous Expense (675)
a. To reclassify property owner’s association fees. 	$855
b. To reflect pro forma for emergency monitoring service. 	1,127
Total 	$1,982
TOTAL OPERATION AND MAINTENANCE EXPENSE 	$1,981
NET DEPRECIATION EXPENSE
1. 	To reflect corresponding adjustments of pro forma plant additions. 	$47
2. 	To reflect auditing adjustment to amortization of CIAC expense 	(1,626)
Total 	($1,579)
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS 	Schedule 3-B
PAGE 25
LP WATERWORKS, INC. 	SCHEDULE NO. 3-B
TEST YEAR ENDED 12/31/2021 	DOCKET NO. 20220099-WS
ADJUSTMENTS TO OPERATING INCOME
WATER
TAXES OTHER THAN INCOME
1. 	To reflect auditing calculation of RAFs and property tax. 	($222)
2. 	To reflect appropriate test year RAFs. 	(12)
3. 	To reflect property taxes associated with pro forma adjustment. 	10
Total 	($224)
TOTAL OPERATING EXPENSE ADJUSTMENTS 	$177
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS 	Schedule 3-C
PAGE 26
LP WATERWORKS, INC. 	SCHEDULE NO. 3-C
TEST YEAR ENDED 12/31/2021 	DOCKET NO. 20220099-WS
ANALYSIS OF WATER O&M EXPENSE
TOTAL 	APPROVED 	APPROVED
PER 	ADJUST- 	TOTAL
ACCT. 	DESCRIPTION 	UTILITY 	MENT
601 	Salaries and Wages – Employees 	$6,300 	$0 	$6,300
615 	Purchased Power 	2,406 	(178) 	2,228
618 	Chemicals 	0 	878 	878
632 	Contractual Services – Accounting 	425 	0 	425
633 	Contractual Services – Legal 	150 	0 	150
636 	Contractual Services – Other 	109,890 	0 	109,890
640 	Rental Expense 	855 	(855) 	0
655 	Insurance Expense 	878 	75 	953
665 	Rate Case Expense 	619 	79 	698
675 	Miscellaneous Expenses 	863 	1,982 	2,845
Total O&M Expense 	$122,386 	$1,981 	$124,367
Working Capital is 1/8 O&M less
RCE
$15,221 	$238 	$15,459
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS 	Schedule 4
PAGE 27
LP WATERWORKS, INC.
TEST YEAR ENDED 12/31/2021
MONTHLY WATER RATES
UTILITY'S 	COMMISSION 	4 YEAR
EXISTING 	APPROVED 	RATE
RATES 	RATES 	REDUCTION
Residential and General Service
Base Facility Charge by Meter Size
5/8" x 3/4" 	$11.78 	$14.51 	$0.07
3/4" 	$17.67 	$21.77 	$0.10
1" 	$29.45 	$36.28 	$0.17
1-1/2" 	$58.90 	$72.55 	$0.33
2" 	$94.24 	$116.08 	$0.53
3" 	$188.48 	$232.16 	$1.07
4" 	$294.50 	$362.75 	$1.67
6" 	$589.00 	$725.50 	$3.33
Charge per 1,000 gallons - Residential
0-3,000 gallons 	$6.77 	$8.57 	$0.04
Over 3,000 gallons 	$9.95 	$12.86 	$0.06
Charge per 1,000 gallons - General Service 	$8.15 	$9.33 	$0.04
Private Fire Protection Service
Base Facility Charge by Meter Size
5/8" x 3/4" 	$0.98 	$1.21 	$0.01
3/4" 	$1.47 	$1.81 	$0.01
1" 	$2.45 	$3.02 	$0.01
1-1/2" 	$4.91 	$6.05 	$0.03
2" 	$7.85 	$9.67 	$0.04
3" 	$15.71 	$19.35 	$0.09
4" 	$24.54 	$30.23 	$0.14
6" 	$49.08 	$60.46 	$0.28
Typical Residential 5/8" x 3/4" Meter Bill Comparison
2,000 Gallons 	$25.32 	$31.65
6,000 Gallons 	$61.94 	$78.80
10,000 Gallons 	$101.74 	$130.24
DOCKET NO. 20220099-WS
SCHEDULE NO. 4
ORDER NO. PSC-2023-0101-PAA-WS
DOCKET NO. 20220099-WS 	Schedule 5
PAGE 28
LP WATERWORKS, INC. 	SCHEDULE NO. 5
TEST YEAR ENDED 12/31/2021 	DOCKET NO. 20220099-WS
SCHEDULE OF WATER PLANT, DEPRECIATION, CIAC, & CIAC AMORTIZATION BALANCES
ACCUMULATED
ACCT. 	DESCRIPTION 	UPIS 	DEPRECIATION
301 	Organization 	$471 	($251)
304 	Structures and Improvements 	75,171 	(74,124)
307 	Wells and Springs 	41,707 	(38,091)
309 	Supply Mains 	1,040 	(732)
310 	Power Generation Equipment 	12,086 	(11,375)
311 	Pumping Equipment 	616 	(1,989)
320 	Water Treatment Equipment 	42,547 	(6,129)
330 	Dist. Reservoirs and Standpipes 	123,439 	(54,878)
331 	Trans. and Distribution Lines 	212,706 	(152,537)
333 	Services 	60,079 	(52,974)
334 	Meters and Meter Installations 	78,344 	(73,904)
335 	Hydrants 	5,364 	(4,258)
336 	Backflow Prevention Devices 	1,874 	(2,869)
340 	Office Furniture and Equipment 	698 	(710)
346 	Communication Equipment 	9,281 	(6,984)
347 	Miscellaneous Equipment 	726 	(95)
Total 	$666,149 	$481,900
Accum.
Amort.
CIAC 	CIAC
($268,967) 	$215,548

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