Florida Public Service Commission native order document 00755-2024

Order No. PSC-2024-0043-PAA-GUFlapubserv

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FILED 2/19/2024
DOCUMENT NO. 00755-2024
FPSC - COMMISSION CLERK
BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
In re: Joint petition for approval of amendment
to territorial agreement in Pasco County, by
Florida Public Utilities Company and Peoples
Gas S stem, Inc.
DOCKET NO. 20230125-GU
ORDER NO. PSC-2024-0043-PAA-GU
ISSUED: February 19 , 2024
The following Commissioners participated in the disposition of this matter:
MIKE LA ROSA, Chairman
ART GRAHAM
GARY F. CLARK
ANDREW GILES FAY
GABRIELLA PASSIDOMO
NOTICE OF PROPOSED AGENCY ACTION
ORDER APPROVING AMENDMENT OF TERRITORIAL AGREEMENT
BY THE COMMISSION:
NOTICE is hereby given by the Florida Public Service Commission that the action
discussed herein is preliminary in nature and will become final unless a person whose interests
are substantially affected fi les a petition for a formal proceeding, pursuant to Rule 25-22.029,
Florida Administrative Code (F.A.C.).
Background
On November 3, 2023, Florida Public Utilities Company (FPUC) and Peoples Gas
System, Inc. (Peoples), collectively the joint petitioners, filed a petition seeking our approval of a
first amendment (Amendment No. 1) to the Amended and Restated Territorial Agreement -
Pasco County (Pasco Agreement). In November 2007, we approved the Pa sco Agreement, along
with a Master Territorial Agreement (Master Agreement) and a gas transportation agreement
between the Florida Division of Chesapeake Uti lities Corporation I and Peoples.2 This Master
Agreement contains terms and conditions that govern all territorial agreements entered into by
1 By ORDER NO. PSC-2024-0043-PAA-GUPSC-2023-0103-FOF-GU, issued March 15, 2023, in Docket No.
20220067 -GU , the Florida Division of Chesapeake Utilities Corporation, as well as FPUC's Indiantown Division
and Fort Meade Division, were consolidated with Florida Public Utilities Corporation, under the name of Florida
Public Utilities Co mpan y. FPUC has assumed the rights and responsibilities und er a ll pertinent agreements entered
into by its predecessor, the Florida Division of Chesapeake Uti lities Corporation, also known as CFG.
2 ORDER NO. PSC-2024-0043-PAA-GUPSC-2007-0944-PAA-GU, issued November 28, 2007, in Docket No.
20070399-GU, In re: Joint Petition for approval of territorial agreement in Pasco County, master territorial
agreement, and gas transportation agreement, by Peoples Gas System and the Florida Division of Chesapeake
Utilities Corporation.
ORDER NO. PSC-2024-0043-PAA-GU
DOCKET NO. 20230125-GU
PAGE2
Peoples and Chesapeake. 3 The joint petitioners, through Amendment No. 1, seek our approval to
adjust the utilities' shared service boundary.
During the review of this joint petition, our staff issued a data request to the joint
petitioners on November 17, 2023, for which responses were received on December 13 , 2023.
On January 10, 2024, the parties filed a corrected version of Amendment No. I. The
cotTected version, initialed by counsel, contains the date that the amendment was entered into by
the parties (October 31, 2023), which was inadvertently omitted in the original version submitted
with the petition. 4 No other changes were made to the corrected version of Amendment No. 1.
Amendment No. 1 is shown as Attachment A to this order.
We have jurisdiction over this matter pursuant to Section 366.04, Florida Statutes (F.S.).
Decision
A. Proposed Amendment to Territorial Agreement
FPUC and Peoples began territorial agreement discussions after a developer announced
plans for a commercial complex in Service Area B. The previously undeveloped parcel of land in
FPUC 's service territory is located geographically a considerable distance from the company's
existing natural gas facilities, but very close to existing facilities operated by Peoples. The
proposed Amendment No. 1 will facilitate serving the new commercial development within the
geographic area described in Amendment No. l - Exhibit A as Service Area B (Attachment A).
Service Area B is about 12,212 acres in size, and the new commercial development is projected
to include a grocery store and other retail outparcels totaling about 60,000 square feet. The joint
petitioners assert that in the next 5 to l O years, further development within the Service Area B
could result in up to 1,000 new residential and commercial customers.5
FPUC determined that its nearest facilities to Service Area B are approximately 24 miles
away in Plant City. 6 The utility asserted that construction of new facilities from its existing
facilities in Plant City to Service Area B would cost several million dollars. Although a specific
estimate 	was 	not 	developed, 	FPUC 	determined 	it 	was 	unable 	to 	extend 	service 	to 	the
development economically and thus pursued the territorial modifications set forth in this petition.
Peoples, on the other hand, has natural gas facilities about 320 feet away from Service
Area B on County Road 577 (Curley Road). To provide natw-al gas services to Service Area B,
Peoples would need to construct 170 linear feet of main lines, 150 linear feet of service lines, and
a distinct regulator station, which Peoples estimate would cost $105,000. 7 Based on the
3 Id.
4 See Document No. 00141-2024.
5 Document No. 06579-2023, Staffs First Data Request, No. 5.
6 Document No. 06579-2023, Staffs First Data Request, No. I.
7 Id.
ORDER NO. PSC-2024-0043-PAA-GU
DOC KET NO. 20230125 -GU
PAGE3
comparative difference in the amount of required infrastructure, Peoples can more economically
serve the commercial development than FPUC and is willing to do so.
Pursuant to Paragraphs 3.D. and 3.E. of the Master Agreement, the joint petitioners have
entered into Amendment No. 1 which, if approved, would transfer Service Area B from FPUC to
Peoples.8 Pursuant to Paragraph 5 of Amendment No. 1, the terms and conditions of the Pasco
Agreement would remain unchanged going forward. Prior to the second anniversary of our
approval of Amendment No. 1, and no more frequently than every five years thereafter, Peoples
and FP UC will confer regarding the status of the amendment.
The joint petitioners state that the approval and implementation of Amendment No. I will
not cause a decrease in the availability or reliability of natural gas service provided by either
entity, or to the existing or future ratepayers of either entity, consistent with the standards set
forth in Section 366.04, F.S., and Rule 25-7.0471(2)(c), F.A.C.9 As stated in paragraph 6 of the
petition, approval of Amendment No. 1 will enable as many residential and business customers
in Pasco County as possible to receive economical and reliable natural gas service and will not
necessitate the transfer of any existing customers or facilities between the joint petitioners.
Moreover, as stated in paragraph 6, absent the subject amendment, certain customers in Pasco
County would be unable to obtain natural gas service; thus, the approval of Amendment No . I
would be in the public interest.
B. Rule Considerations
Rule 25-7.0471(2), F.A.C., addresses the standards we must consider when approving
territorial agreements for natural gas utilities. The Rule states:
(2) 	Standards 	for 	Approval. 	In 	approving 	te1Titorial 	agreements, 	the
Commission shall consider:
(a) 	The 	reasonableness 	of the 	purchase 	price 	of any 	facilities 	be in g
transferred;
(b) The reasonable likelihood that the agreement, in and of itself, will not
cause a decrease in the reliability of natural gas service to the existing or
future ratepayers of any utility party to the agreement, and
(c) The reasonable likelihood that the agreement will eliminate existing or
potential uneconomic duplication of facilities.
(d) Other relevant factors that may arise from the circumstances of a particular
case.
In our review, we considered each component of Rule 25-7.0471(2), F.A.C. Regarding
paragraph (2)(a), we note that FP UC agreed to transfer the pertinent area to Peoples without
8 Se e Footnote 2, citing the Master Agreement approved by ORDER NO. PSC-2024-0043-PAA-GUPSC-2007-
0944-PAA-GU.
9 Document No. 06579-2023, Staff's First Data Request, No. 4.
ORDER NO. PSC-2024-0043-PAA-GU
DOCKET NO. 20230125-GU
PAGE4
compensation, which is reasonable because no facilities are being transferred. 10 Regarding
paragraph (2)(b), the joint petitioners' have confirmed that the availability and reliability of
service to existing or future customers wilJ not be decreased for either petitioner. The joint
petitioners verified that there are no natural gas facilities in Service Area B and that construction
would be necessary to service that geographic area. 11 Paragraph (2)(c) has been appropriately
considered 	because, under the 	proposed 	territorial 	agreement, 	uneconomic duplication 	of
facilities 	will not occur because Peoples facili ties are better positioned to serve the area
economically and efficiently. 12 We find that paragraph(2)(d) gives us the flexibi lity to address
any other relevant concerns that are case-specific. The joint petitioners assert that there are
none.13
Under Rule 25-7.047 l (l)(e) , F.A.C., a proposed territorial agreement must provide
information regarding the degree of acceptance by affected customers. We note, however, that in
the instant case, there are no current customers and under this proposed territorial agreement, no
facility transfers are contemplated. In addition, representatives from FPUC and Peoples have
noti tied us that the developer is aware of, and has no objection to, the proposed territorial
agreement.
C. 	Conclusion
We approve the proposed Amendment No. 	1, which transfers a portion of FPUC' s
service territory to Peoples. The proposed Amendment No. 	I will faci litate the provision of
economical and reliable natural gas service by Peoples to residential and business customers in
the proposed transfer area identified as Service Area B in Amendment No. I - Exhibit A, thereby
avoiding duplication of facilities and services.
Based on the foregoing, it is
ORDERED by the Florida Public Service Commission that the proposed Amendment No.
l to the Amended and Restated Territorial Agreement - 	Pasco County between Florida Public
UtiUties Company and Peoples Gas System, lnc., shall be approved. It is further
ORDERED that the provisions of this Order, issued as proposed agency action, shall
become final and effective upon the issuance of a Consummating Order unless an appropriate
petition, in the form provided by Rule 28-106.20 l , Florida Administrative Code, is received by
the Commission Clerk, 2540 Shumard Oak Boulevard, Tallahassee, Florida 32399-0850, by the
close of business on the date set forth in the '·Notice of Further Proceedings" attached hereto. 	It
is further
ORDERED that in the event this Order becomes final, this docket shall be closed.
10 Document No. 06579-2023, Staff's First Data Request, No . 3.
11 Document No. 06579-2023, Staff's First Data Request, No. 4.
12 Id.
13 Id.
ORDER NO. PSC-2024-0043-P AA-GU
DOCKET NO. 20230 125-GU
PAGES
By ORDER of the Florida Public Service Commission this 19th day of February. 2024.
DD
Commission
Florida Public Service Commission
2540 Shumard Oak Boulevard
Tallahassee, Florida 32399
(850) 413-6770
www.floridapsc.com
Copies furnished: 	A copy of this document is
provided to the parties of record at the time of
issuance and, if applicable, interested persons.
NOTICE OF FURTHER PROCEEDINGS OR JUDICIAL REVIEW
The Florida Public Service Commission is required by Section 120.569(1), Florida
Statutes, to notify parties of any administrative hearing that is available under Section 120.57,
Florida Statutes, as well as the procedures and time limits that apply. 	This notice should not be
construed to mean all requests for an administrative hearing will be granted or result in the relief
sought.
Mediation may be available on a case-by-case basis. 	If mediation is conducted, it does
not affect a substantiaJly interested person's right to a hearing.
The action proposed herein is preliminary in nature. Any person whose substantial
interests are affected by the action proposed by this order may file a petition for a formal
proceeding, in the form provided by Rule 28-106.201 , Florida Administrative Code. 	This
petition must be received by the Office of Commission Clerk, 2540 Shumard Oak Boulevard,
Tallahassee, Florida 32399-0850, by the close of business on March 11, 2024.
In the absence of such a petition, this order shaJI become final and effective upon the
issuance of a Consummating Order.
ORDER NO. PSC-2024-0043-PAA-GU
DOCKET NO. 20230125-GU
PAGE6
Any objection or protest filed in this/these docket(s) before the issuance date of this order
is considered abandoned unless it satisfies the foregoing conditions and is renewed within the
specified protest period.
ORDER NO . PSC-2024-0043-PAA-GU
DOCKET NO . 20230125-GU 	Attachment A
Page 1 of 10	PAGE?
MCOIDOCl!.'r HO, l 10 'TIIWTORJAL Mlll8£NIHT - PASCO COW'l'Y
AMENDMENT NO, t
:tQ
AMRN ORO ,_NQ llll.'>TATIID ·mnruTORlAL AQJU~EM&lfi-PA§CO COVNJ.:X
THIS PLRST AMBNOMBNT TO THE AMBNDBO AND RPSl'ATBD TBRRtTORIAL 	q,.ti<
A~BEM BNT~PASCO COUNT'Y (thla "/uncodmant No. l ") Is nu1dund enteleld Into thb ~day : lf\¥ \<\
ofOotobor, 2023 , by and between Pforlda Public Utllltlos Company , a oc11poratlon of tho Stlto or
Florida, ho.rolnaftet rdarre<I to as (''FPUC,'' and Pooplea OuSylUICJl,ltl(.. ('POS"), aeo1por1tlon of
tho Stele of Florida, each bcl119 M lnveatol'-<>wn.ed ntt\lral gu local dlllrlbutlon ut!Uly III de.tlncd lo
Section 366.02(1 ~ Florlda StCIW!ea. PPUC and POS arc hClOinanct aometlmes rc!'med toalngularfy
as a "pe.4ty0 an<I collectlvcty as !he "partlu."
wrrrm.ssirra,
WHFllBAS,PPUCa11dPOSan,nabnlg11.1udlltlc,aubjoettothoreg\1lato:yJuriadlcdonof
tho Florida Pub! lo Sorvloo Commission ("Comrnl.uton") t1ndor Ol 1plct 366, Jlkxlda Slntutu; and
WRP.RBAS, u parll.ucat to thls Amondn\cnt No , I, POS and tho Florida Dlvls!ori of
ChoS11poako Utllltlos Corporatlon rcPO"), PPlJC'a ~ In lnlbre$1, cnteftd Into tl-.o
Amonde.d and Rostatod Tc.u1t.odal Agtocn,cx11-Pu:o Couu~ In luty 2007 ("Orlglr.al Agrcomc.nt");
and
WHBRBAS,CFO and POS aubtnltled d,o Onglnel Agrumontto tho Florida Pub Uc Seti/loo
c.omuilsslon ror IPf)tOval on J uly 6, 2007, oonalstonl with Seouon 4(1) oft h& ~/.ttter Territorial
A.grecmcnt bctweM UIO pa1tlos; and
WHRB.BAS, tho Florida Publ!o Set-vlco Comnlluton approved the Orlglr., I Agrconlffll by
Order No. PSC-07,0944,PM-OU 1 Issued N0Yon1\w28, 2007, In DocJcctNo , 200'/0399-0U, and
uscolalCd C<iu.sununt.tlng Order No. PSC',2007-1028-CO-OU; &bd
WHBRl?AS, U\o pM.io., havo 001:duoted U~lvco in aoeotd111ice ~ill tho Otlgfr.al
Ag1wncnt il1100 !ta approval by the Comnl.isslollj and
WHRRBAB, by Order No. PSC-2023-0103-POF-OU, l=acd}l..atch IS, 2023 1 in Pocl(o1 No.
20220067-0U, CPO, along with the other nature! giu utility holcilnga of CM..sapow UtWtlc.s
Corporation In Plorlda, were e<>t\SOlld.a!.od Into ono1-c.gul1tod natwil gu utility busiucsa u11!1und11t
tho namo of PlorldaPubtlo Utlllt!os Company: end
WHBRRAS,PPU½ ucho logi1l 1uoecuora1ul a~gtl otCPO, 1-.u a,sumedtnd ls bound by
d101.ctt\l40ftho Orfgl11alAgrecmw1, oon1!stCC1I with tho tcma ofd10Mapr Agrco1ncn t ~\ lhe
pa1tl°'; and
W1IBIU!A8, PPUC la utablo to oeonomlcally 11'le0t a l"tquest for aorvlco from • n~w
cu,tomcrlooated In an treuulgncd to It undct d\C Origlna_l Ai,~cmci,t; 11.1d
ORDER NO. PSC-2024-0043-PAA-GU
DOCKET NO. 20230125-GU
PAGE8
I
l\kl!~:ot-1tA-t NO . l TO \'t!UUTOI\IAL AGtttr<ftl.r
WHHREAS, PGS ls willing and 11ble to oconomieruly serve tho customer in que.<ition; 11nd
WI JERE.AS, PPUC nnd PGS desire thul this Amendment No. l ,upe:slidu ond n:p!ncc the
portions of the Original Agreement ns specified hereh,; end
WHEREAS, iu Ol'der to enable ns many pet30ns llftd businesses as possible with.in Pasco
County to ~i ve econom ical end reliable 1111tunll gas service, PGS 11nd PPUC have entered into rhis
Amendment No. I to mOTC rapid ly nnd ce-0nomiclllly expand the avnlh1billty of nnturnl gu aorvice to
poh:ntinl C11.~tomt.1-s in PilSOO County ; sod
WHERBAS, the Co1T1JniS$I011 is empowered by the legislature of U10 Stato of Florida,
pursuruu to Section 366 .04(3)(ft), Florula St«turu, to npprove nttl supervise :c.rri torial ag,.~nents
betv.'CCn and among Olltuml gr.s utilities;
NOW, ·numRFO!U.:, in fulfillrnc.nt of the purpos,e,afores:iid, and inooMidcmtion of the
mutual covenant, !Ind 11g1ccmcnts herein cootalrtcd, which shall be oonstrued a., beins
interdependent, Uie parties, subject to and upon the term, and condltlons herein set forth, ugrcc a.,
follows :
I. 	For pu~ ofclarity, 1111 refc:.Nnoes to Che$8peclcC in the Original Agn,cmcn t shnll
bo deemed to Include and incorporate Ji.kc refermco to 11PUC.
2. 	Paragraph 3 of the Origlnal Agreement shall be deleted and replaced with tho
following paragraph :
Ju between tho Parties. Che3npcakc's sccvico t1Ico in Posco Couuty, ttlorldn (the
"Cbc.sapcako Service An:a") shall be a, sot forth on Exhibit A, which is
incorporated herein by reference ar,d made a pt1t1 h<:rcof. TJtt; Chcsnpc:Akc Service
Arca is also depicted on tho torrltory map attached hereto and rmdc n pnrt hcceof as
Hxhibit C as tbosearcM shaded end designated rcspcetivcly us "Chesapeake Service
Arca A", which aro.i L, more fully described lo tho legnl dc.,cription act forth in
Bxhlbit A.
3. 	Exhibi t A to the Original Agreement shall be roviscd to delote tho section entitled
"J .cgo l description of Chcsapeako Service A1ca 'B "'.
4. 	E.xhibit C to the Origi nal Agreement shall be deleted wd replACCd with I.ho mnp
at.Itched hereto as Amendment l!.'<hibit A.
5. 	Exco1>t as modll1ed by tltls Amendmoul No . I, the Origlnnl Agr~mcnt shall
rcf1lJl.ln unchanged r.nd continue In fu ll fo1'CC nud effect. 'l his AtUcn<lment No. I sluill
have llO effect on the bounda.rics of tho respective service areas of the 11artic$ hCt'Ol o M
the 11ome may DOW or herenfter exist except as :,pocificolly provided h ere in .
lN WJTNBSS WHHilliOI', th e parties hereto havo cnUSCll th!$ Amendment No. I to the
2
Attachment A
Page 2 of IO
ORDER NO. PSC-2024-0043-PAA-GU
DOCKET NO. 20230 125-GU
PAGE9
,\~UlNOkt:H1' NO. 1 TO TY-RR1TORI1\L 1\GI\BBMIWT 	PA.SCO COOt-'7'/
Attachment A
Page 3 of 10
Amended und Resmted Ten·itorial Ae.i-eemenl to be cxecutcd by their d\1 ly mllhnrizcd officeJ-s as of
the dnto nnd yoar first abovo staled.
P~OPLES GAS SYSTJ" 	C.
?
Dy: 	/
---
3
ORDER NO. PSC -2024-0043-PAA -GU
DOCKET NO. 20230125-GU
PAGE 10
l'JCF.JIOH~»T WO. l TO TBRRl'l'ORIA I, lt\CIUJ:EHl!NT 	PASCO ooumY
F1,01u AP un1.. 1c u 1 1w1 11\S Co:.t r ANV
'
By:
Chfl; ~'½!.~ -~
l' nnt Name
4
Attachment A
Page 4 of 10
ORDER NO. PSC-2024-0043-PAA-GU
DOCKET NO. 20230125-GU
PAGE 11
AMt.HOC~mT llO. J TO Tf.RRl'tORIAL ACR£P,.M£i,.'T 	PASCO COUNTY
AMENDMENT EXTl llll 'f A
Chesapeake (PPUC) and Peoples Gas System, In c.
Pasco Co unty, Florida Service Area Map
s
Attachment A
Page 5 of 10
ORDER NO. P SC-2024-0043-P AA-GU
DOCKET N O. 20230 125 -GU
PAGE 12
R19E 	R20E
~ 	~
Q: 	Q:
T24S
T25S
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- -	Q: 	Q:
-	s
R19E 	R20f=
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$=].=.;ti::;~...------- ·-. -
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T24S
T25S
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R20E 	R21f=
Attachment A
Page 6 of 10
T25S
I J
~ -
ORDER NO. PSC-2024-0043-PAA-GU
DOCKET NO. 20230125-GU
PAG E 13
Attachment A
Page 7 of 10
FPUC Area 	Map - 	Exhibit 	l.F
M iles
0 	1 	2
t 	I 	As of 12/12/2023
D Service Area B
Distribution Main:
- 	Piped Natural Gas system
FPUC Plant City Natural
Gas System
I
ORDER NO. PSC-2024-0043-P AA-GU
DOCKET NO. 20230125-GU
PAGE14
Attachment A
Page 8 of 10
--------,---,,--,---,-------,-----.----------- iR20E 	R21E 	i
Ex1st1 g Peoples Gas 6" .,.,_.., 	!
Main 	==--~- 	J
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R19E 	R20E
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ORDER NO. PSC-2024-0043-PAA-GU
DOCKET NO. 20230125-GU
PAGE 15
Attachment A
Page 9 of 10
~
t
--------------------------------- !
-. ;,cxcct ot ,,,,,d (O<otcd m Po,co CO<Jnty. flor,ao t-c "<J mo,r pnrflc v1011y d,:scr b~d 0$ (t:,Jlf'I•$:
1n 1o-,n,;ni() 25 Souttt. Rart9t 20 £a1t. Posco COCJnt 1• /lo,,do.•
that Por1 of s«tf'OI': 21 Jyit,9 South Qlld [o!lt ol 111~ t19"t -01- ..ay fo., f)'"dolt Rood or,d '"'"" ~t11 ona Cost
,, thr 1l9ht • of- •ay for w l(efldfac Hood.
r,,a, Po,, of SO(;trt>II 22 1y,t,9 So.:Jttt«ty ol t1to r,crit-of-•cy tor ly,:t~ RtXJ3.
So-(."r,o,, ~J LLSS art/ po,t tf,c,NI ty,ng Nortl'e,11 of l'·c ri.Jr t-of - •\li !Of' :,~,Jolf ~0-10. ly'n9 ,\ortnrrly ct
~ (Jlc,- Hood one1 1y,,g to11cr1T ol ti•!! ri*'}ht-ol ,,..o, lo, CurJcr ,o,od
ri,ot Porf of SO'CIIO,t 24 ly,'ng 5<:tiwthqrl;, o/ rm, tiQ'("l1-01-way to, ;.;refer P0i1a: AL!. of Sc:ct•()('I 7~;
~LL of St,t,c,> 2/i; AU of St><I""' Ji;
fhat Port ol $,x.t,o., 28 1rn9 Sout!Hufy of thr 1,·ry,1-of -,oy ,,., \I, ;<onu,t·r. Rocu,
,~at PtJ,t "' s«t,on 2? 1.,.n9 Ca,terly of ,~. rtq1tt-ol- Ai,/)' (()I' v.s mt«.:f'Sf.c.,t,· H, J'l•(J~ 7~. :rss Ol'1/ ""''
·~,.,-c-oJ •>'"'I ,"io,thcr-1}' of thtJ right .. of """Y l(ltl 1.;,t,.l<t!""ld"<!IJ Rood ,,. tt ru11s la,t ~d "1:st l'IC:.Jr •t,u NO"th
1>a.ndcxy of Sqc::on 19.
rllot Port of St•etkYt J7 1_..;,u; Cu~u.,,y of Ila• ,;,q,., of ~Dy ,~ US. tntvrst1Jlt1 ,1:,1-"~'.J/ 75: AU of ~·<:1'1)1'
!J;
~:t 01 St<:I ·on J4, ,t,t of S,xti<,,, J5: "11 of SM;11ott J6:
1n to~ns,! t 25 Soc,M, Rong• 11 lost Posco Covn•r r,o,}tfo
lrtot rJotl -:,I Soct,on to 1ytn9 Sovtf'.cr1y 01 tnc- n9nt-of-,.oy '<H X.ieler Hood and '·1lr9 Wo.ttffly of fh<t
,i'ghl .. ol-1roy tor ltCfldC<Yt Hood,
tnol Porr of S<-ct'°" JO l'jfng ,\'esttv1y ol tht:f "9ht of .. oy lor Hondco,t Hood, Ttu,t Po,t ol s«tiott JI ,~"9
~\t'Jte,,ty of ,,.,o ..,.Ql1t - ol •ay for ,,a,,acort Roaa;
In lo•n•~·z; 16 So.1111. Rongo 10 t:ost, Posco CO<Jflty flo,,<10:
ALL of 5t-<llon ,. ALL Of !,,~.ctiOn i.- ALL ol !>t-etion ,,~ AU or 5tct,on I:!
lhol Port ol Soclian IJ 1:jng NorthOlly "'"' t·o,1or1,- 01 tho ,~t-ot•woy lo, 5rote RoorJ ~•. 11101 Port of
s~,tion ,., lyinq No,thcrtf 011r1 Costctrfy al tho riqt,t ol • at lor Stolt: Rood .54 ·
,~ ro..,s.~;i, 26 Sou1n. Range 21 tost Posco Counr, nor~a·
/hot /ltyt of Se-ctJo,, 6 fy,"1,9 W~stcrly o' the rlgM-of w ay lor Handcart !tooa Cl'1d ,~rH; K'tttterl)' of lht1
,i9nt-llf-woy 10,, £"ilcna Bou ovofd,
Th,t "°"' of SttNon I tr·"9 W6Jt~1y of tm: r.7ftl-ol wo1 for £#crta 8~1~vr,rd;
That porl of Stt:Uon 18 IY''n9 Northerly of thr rlql'tr-ot-•ay Iv Stat~ Rood 5,4 and Wc:,f~t., of u,,
rkz;,t-ol-11101 lo, £'ifo,td BouictrlJfd,
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Attachment A
Page 10 of 10

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