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• <br />• <br />• <br />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 management 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 />