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® facilities, and certain transitional issues. • • The City responded by filing both a motion to dismiss and a response in opposition to the requested statements; Florida Power & Light Company ("FPL"), Duke Energy Florida ("Duke"), Tampa Electric Company ("Tampa Electric"), the Florida Electric Cooperatives Association, the Florida Municipal Electric Association ("FMEA"), and the Orlando Utilities Commission ("OUC") also filed responsive pleadings in opposition to the County's requested statements. On November 13, 2014, the PSC Staff issued its recommendation to deny the County's Petition, which the PSC was scheduled to consider at its agenda conference on November 25, 2014. On the morning of November 25, however, the County requested and was granted a deferral of its Petition from the PSC's scheduled agenda. The PSC is now expected to hear the matter at its agenda conference on February 3, 2014. Historical Background The City of Vero Beach was initially incorporated in 1919 as the City of Vero, and reincorporated as the City of Vero Beach in 1925. (Coincidentally, Indian River County was also created in 1925.) The City has operated a municipal electric utility system since 1920, when it purchased the original small power plant, poles, and lines from the Vero Utilities Company. Naturally, the City's service area has grown since 1920, and during the intervening 94 years, the City has served customers inside and outside the City limits, pursuant to its own ordinances, pursuant to requests by customers living outside the City limits, pursuant to its powers under Florida Statutes, and, since at least 1972, pursuant to orders of the Commission approving the City's service area in territorial agreements with ("FPL"). Today, the City serves within the service area described in its territorial agreement with FPL, which agreement has been approved, with amendments over. time, by the following Commission orders: In re: Application of. Florida Power and Light Company for approval of a territorial agreement with the City of Vero Beach, Docket No. 72045 -EU, Order No. 5520 (August 29, 1972); In re: Application of Florida Power & Light Company for approval of a modification of territorial agreement and contract for interchange service with the City of Vero Beach, Florida, Docket No. 73605 -EU, Order No. 6010 (January 18, 1974); In re: Application of FPL and the City of Vero Beach for approval of an agreement relative to service areas, Docket No. 800596 -EU, Order No. 10382 (November 3, 1981); In re: Application of FPL and the City of Vero Beach for approval of an agreement relative to service areas, Docket No. 800596 -EU, Order No. 11580 (February 2, 1983); and In re: Petition of Florida Power & Light Company and the City of Vero Beach for Approval of Amendment of a Territorial Agreement, Docket No:, 3 Is