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32. Under Florida law, customers of an electric utility are not required to bear the cost <br /> of imprudent utility management decisions. Gulf Power Company v. Florida Public Service <br /> Commission, 487 So. 2d 1036 (Fla. 1986). <br /> 33. Prudent electric utility managernent requires the implementation of proper risk <br /> management policies in order to manage fuel price volatility and keep power costs as low as <br /> reasonably possible. <br /> 34. The City has failed to prudently manage its utility system. For example: <br /> a. Upon information and belief, the City has abdicated its operational and <br /> managerial responsibilities to others without appropriate oversight and due <br /> diligence; <br /> b. Upon information and belief, the City has operated its electric utility system <br /> without implementing appropriate risk management protocols to mitigate fuel <br /> price volatility and keep electric power costs as low as reasonably possible; and <br /> c. The City has conceded in filings with the PSC that it did not have the "required <br /> knowledge, capabilities, or expertise" to perform basic utility managerial <br /> functions such as determining how customers were counted prior to 2008. <br /> These and other instances of managerial imprudence have caused the City's electric power costs <br /> to rise to excessive levels. <br /> 35. The City's elected officials have decided to pass the City's excessive power costs <br /> on to Plaintiffs by charging them unreasonable electric rates. As a result, Plaintiffs are being <br /> forced to pay unreasonable electric rates that are approximately 30% higher than the electric <br /> rates paid by other Town citizens receiving the same unit of electric service from FPL. All that <br /> 8 <br /> OJ <br />