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19. Florida law does not authorize a municipality to provide extra-territorial electric <br /> utility service within another municipality's corporate limits without the other municipality's <br /> permission. The Franchise Agreement provides the permission under which the City is currently <br /> providing electric utility service in the Town, but the City will no longer have that permission <br /> after November 6, 2016. <br /> 20. The Town has elected to revoke its permission for the City to operate its electric <br /> utility in the Town because the City continues to mismanage its utility and charge the Town and <br /> its citizens unreasonable and excessive electric rates. <br /> The City's Failure to Charge Reasonable Rates <br /> 21. The City's electric rates have increased dramatically over the last 10 years. Today, <br /> the Plaintiffs and other Non-Resident Customers in the Town are forced to pay unreasonable <br /> electric rates that are approximately 30% higher than the electric rates paid by Town citizens <br /> receiving electric utility service from FPL. <br /> 22. Upon information and belief, Plaintiffs and other Non-Resident Customers in the <br /> Town receiving electric service from the City are collectively paying in excess of$2.0 million <br /> more per year than they otherwise would pay if electric service was provided by FPL. <br /> 23. Because FPL is an investor-owned utility, its electric rates are regulated by the <br /> Florida Public Service Commission ("PSC") under Chapter 366, Florida Statutes. <br /> 24. In contrast, as a municipal electric utility, the City and its electric utility rates are <br /> not regulated by the PSC. See §§ 366.04 and 366.02(1), Fla. Stat. (2014) (providing the PSC with <br /> the jurisdiction to regulate rates and services of a "public utility," but excluding municipalities <br /> from the definition of"public utility"). <br /> 5 <br /> CIA <br /> 0 v <br />