Title: Proposed Public Service Commission Margin Reserve Rule
Full Citation
Permanent Link: http://ufdc.ufl.edu/WL00004853/00001
 Material Information
Title: Proposed Public Service Commission Margin Reserve Rule
Physical Description: Book
Language: English
Spatial Coverage: North America -- United States of America -- Florida
Abstract: Jake Varn Collection - Proposed Public Service Commission Margin Reserve Rule (JDV Box 39)
General Note: Box 29, Folder 5 ( Water Supply Issues Group (File 3 of 3) - 1996 ), Item 18
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: WL00004853
Volume ID: VID00001
Source Institution: Levin College of Law, University of Florida
Holding Location: Levin College of Law, University of Florida
Rights Management: All rights reserved by the source institution and holding location.

Full Text


* PAGE 1

South Florida Water Management District
3301 Gun Club Rtd, Wat Palm B ch, Florida 33406 (407) 66-800 FLWATS 1-800432-204


(407) 687-6200

Suncom Subscribers Dial Suncom: 229-6200



Number of pages to ransmit including this form:






Mike-- -- -- Slayt- -D u Dieo

Mike Slayton, Deputy Executive Director

nci+-rrcd ini ;a

n '- ml i il mill

Valeric I nYl. Clharman
Frink Williimson. Jr.. Vice Chainrunn
Witllium E. Urhin

William HIimmond
Benv Krant
Ricard A. Macwk

Eugene K. Peni'
Nathaniel P. Rcd
Mirism Singer

Samuel E. Poole III, Fgeeutive Direcw
Michual SlAyron. Deputy Execurive Director

M ailing ddArm: P.O. Box 24680 Wctr Pidm Seach, FL 33416-4,80

10/18 '96 10iQ:3

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10/18 '96 10:54


South Florida Water Management District
3101 Gun Clut Road, Ww Prlnm BaDach, lieda 33406 *(407) 686-S0* PL WAT 14-80032.204s
October 17, 1996

Chairman Susan P. Clark
Commisdionr J, Terry Deaon
Commissioner Joe Oarc
Commlssioner Julia L. Johnson
Commissioner Diane KelsloUA

Florida Public Service Commilsson
2540 Shumard Oak Blvd.
Tallahascc, Florida 23299-0850

Subjedt Popoed Public Serdie Comamllon Margin RItrv Rule

Dear Chairman Clark and Commissioners:

In an effort to coordinate with the Public Service Commlsion (PC) in providing fr the rafe,
rald a dl a rnd afdable water supply to the ciddea of Florida, this later is writma to provide
you with seven of the water management district' collective comment on your rule proposal.

Considerig Florida' burgeoomi population as well as Its ncrased focus on satifaction of
nvirornm tal water supply demands, the water management distri t have In reent year
expended oonsidel mount of wafif lme a~d mouroe on loWtpn-m water supply planni
and development. The Oovernor's recent sutliuve Order and the newly etablithed Water
Supply Development and Fundin Work Group re reflections of the now Intea interest in
water supply issue. Our various agencies effort ar geerally directed d towr qtfyin the
demands'of all usera, human and environmental. As you know, this task requires a delicate
balance to mtify tbhe ome tim e competing demands. A satlficant past of the solution of this
te-wid effot involves lovative ue of alternative water mpplis a ana incresd focus on
water eoon aon. Pture use of alteative supplies Is oupled with aon*olol requirement
placed on all pemited users to oonerve water. We think coordhiaton between our prounms'
cos rvaton goab and addtoalu er eli ance on alernave source must be matched with the
PSC's rate-etting authority in a manner which foster aempmlahment of the state-wide water
The PSC's proposed nrul may impact the dimtrics in the amas of loongtm planning, water
conservation and alternative supply development. Defning the margin rewrve period to be
eighteen months and the relationship of this component to the "used and useful. rate base
determin4ion seems to disuade utilities from implementing alternative water supply projects
deslnedito meet the utities' anticipated and even permitted demand. General, the districts
authorize public water supply uses on the basis of anticipated demand projected to occur over the
ensuing ten years. In this manner, the districts and utilities are better able to anticipate short-
CWoliwti PBI, s
Valaric Boyd, Chairman William HlanIIond ugene K. Pct8; Samuel E. PooP III, Executive Dircrur
Frank Wi limsnn, Jr., Vice Chaingan Betsy Krant Nathanid P. Reed Miclel Slayton, Deputy Ewcive. I)reitor
William If.. Oraham Richrd A, Mclirhck Miriam Singer
Maling Addres. P.O. aox 24680, West Palm Beach. FL33416-4680


ID: SFWRD F'^ OFFICE FAX:407-681-62~

Chairman Susan P. Clark
Commisitonr J. TIrry Deason
Commissioner Joe Garcia
Commission Julia L. Johnson
Commissioner Dian K. Kalsling
October 7, 1996
Page 2

fails n supply and, where appropia, develop alternative soutWe. FOr example, the typ~Ial
time period neoeM ry to plan, oonaruet and bekia supplylg ralmed water will fr exeed the
proposed eigtee month margin esere parod duy to the complexities uoclaed with timing
of improvements undertalkm by the supper ad enda-unr While 0ome reue projects may be
for the purpose of accommodating new outomers, many reuse prOjem are for dhe purpose of
allowingutilities o meet exdstinl uss with a lower quality soure, thus conserving higher quality
source for the benefit of both xistin and tre customers. As such, the "sed and usruhl
method of accounting (with the margin rweer period), whch aeem to be designed to address
apuunion of capacity, does not appear o be adequate in coiderig these fatdon which are
unique t reuse and t development of altereve upplie. If "used and msful is continued
to be applied to allow rseer y of costs frraus project, them the ar gin ww period needs
to be ilgu ty longer. Over te yne, uasu frt all ua aliase, iluding public water
upplier, have a~ampl~aed longer dundon water uie pewit to obtain ao asece capital
flnalat for he ft9hllidt which t y fbiM will be necessary to atisy demand during the
duraton of teh permit.

The matrgi reserve "used and uefunl" rul appears to be loonsuont with this publl water
supply utility trend. Innovative approaches such as marial cot ate structure might well be
an effective substtute for tbh proposed rle. Discussions during last week's meeting between
sveal oou respective taf seemed to Indcate an test onte part ofthe PSC to entertain
alternative to w maa seservo sule which would support the districts' and pub water supply
utilities' desre to implement alteratv water upply technology inlding reuse and
oosevatlon. We attrogly Ippotn contnFed disussiWon on this issue between ne PC and the
water ma agement ditriacs, &ad other interested pasties

To address these sooerns, we become that the published rule be amended to include a
specific recognition tht her alternative water supply p ects equrtid by a water
management district be allowed a sigat tly longer margn serve parod. Under the spirit
of our 'MOU on conorsvaon, we pla.to work with the PSC staff to prpewre a proposed
amadment to the draft laguap for your onsideraton during the le adoption hearg.

In mDakC thee comments and recommendations, the distriOs nweogu ie we are mot th only
agencies In Florlda charged with addressing water supply issues. The PSC leaily plays an
important role in this complex arena. Of particular impot in regard to the proposed rule is the
apparent intent to defer the cts of future facites away from misting customers. Achieving
equity btwben ex ng and futue water sn is etainly an Important goal. However, we hope
this gol can be accomplished in a manner which recognizes the districts' equally important


10/18 '6s 10:56


10/18 '98 10:i57 ID:SFWID :C. OFFICE FAX:407-681--6 PAGE A

Chairman Susan P. Clark
Commiuioaer J. Terry Deaon
Com mlsioner Joe Garca
Comm4aznoo Julia L Johnson
CommnisionMr Diar K. Keallr
October 17, 1996
Page 3

ar meiatod o ajodvW and tie dei to asuro aMn adeuat ad unable supply fr all water
uea. We do undersnd tdat the eavionmmtal protection mndatd by mt law uad tat wator
poley often lnaecrMes dio ned fr planning and klpos hlgbt o0a rr water ad asteatr
Mrvloe. wHowevr, we mainJl thte Oteo tive of maintanln g affbrdabm rato for essntil
water, wustewatr and rewse rvice c and should be bual u with the need to protect the
Stato's altr seo'urces.

We am hopeful that continue dialogue between our agnmrel as wll as joint partidiption in
Qcsh aosnae' nilmuldki prome wil Improve our ooUlltive manaMemsnt of wWtr related
issue. Thank you for td opportunity to ooauent.

Executive Director
Sou*h lorida Water ManagemeIt Diltrict


.:;.,:, 1, p.

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