The standards are set forth in Wis. Admin. Code § PSC 185.52(2)(b) Single Connections, and in Schedule X-1,Water Utility Operating Rules.

Wis. Admin. Code § PSC 185.52(2)(b) Single Connections states: "A customer's line shall be directly connected to utility-owned facilities, and there shall be no other customer connection downstream from the utility's shut-off valve."

This means that normally there should be just one utility billing customer per shut-off valve and/or each billing customer shall connect directly to facilities (shut-off valve) owned by the utility.

Schedule X-1, Water Utility Operating Rules Establishment of Service, states: "No division of the water service lateral to any lot or parcel of land shall be made for the extension and independent metering of the supply to an adjoining lot or parcel of land. Except for duplexes, no division of a water service lateral shall be made at the curb for separate supplies for two or more separate premises having frontage on any street or public service strip, whether owned by the same or different parties."

The first sentence would not permit service to the second building (Property 2 in drawing) should the property ever be divided. The second sentence prohibits division of the water supply at the curb to separate premises (picture violates second sentence).

Schedule X-1, Water Utility Operating Rules, Replacement and Repair of Service Laterals, states: "The service lateral from the main to and through the curb stop will be maintained and kept in repair and, when worn out, replaced at the expense of the water utility. The property owner shall maintain the service lateral from the curb stop to the point of use."

This identifies ownership and responsibility for portions of the service lateral. The utility is responsible from the main through the shut off valve, and the customer is responsible from the valve to the point of use of the water. The water meter is the responsibility of the utility.

Where there is a pre-existing situation that does not comply with the above requirements, the utility should seek to reconcile the problem. Often, Commission staff recommends that if the situation provides adequate service and the parties are in agreement it can be corrected when the property that is being served from the other property's lateral (Property 2) is sold or when a leaky lateral needs replacement. At that time, the customer (Owner of Property 2) that does not have its own lateral and curb stop from the main in the street should be required to install a new lateral. This obligation to improve the service lateral should be recorded on the deed so any party interested in purchasing the property (Property 2) can be alerted to this cost.

In situations where it is apparent that the utility knew or recommended the improper connection, we require the utility pay for the street portion of the lateral. Often there is no record of this, and it is assumed that the original owner of the property with the non-complying lateral made the connection and, thus, the current owner of this property is held responsible for the cost to correct.

Occasionally, there are situations where waiting for change of ownership of the property is not workable, such as when the property owners involved are in dispute over the situation. Here we have directed the utility to give written notice to the property owner needing to install the new lateral (Property 2) that it shall be accomplished in a reasonable period of time. Often this period is one to two years.

In all the above scenarios, the property owner that is keeping the old lateral (Property 1) normally is held responsible for the cost to excavate and abandon the non-complying lateral at the point where the two laterals connect.

The best way to avoid these problems is to enforce at the time of initial construction the requirement of one lateral to each property. Where non-complying situations already exist, it is good to explain the problem to the property owners and reach an agreement to resolve over time. Sometimes it is necessary to ask Commission staff for assistance in resolving difficult situations and we encourage you to take advantage of that option as needed.

The two sides of a duplex can be served by a shared service line; however, if the property is subdivided and the units converted to condominiums, service through a shared service line is no longer allowed. The standards set forth in Wis. Admin. Code § PSC 185.52(2)(b), Single Connections, and in Schedule X-1,Water Utility Operating Rules prohibit this arrangement.

Wis. Admin. Code § PSC 185.52(2)(b) Single Connections states: "A customer's lateral shall be directly connected to utility-owned facilities, and there shall be no other customer connection downstream from the utility's shut-off valve."

Normally there must be just one utility billing customer per service line and each individual lot must be served by a separate line from the main to the dwelling. There is an exception for duplexes on a single lot, but this exception does not apply if the lot is subdivided and the duplex is converted to condominiums.

Schedule X-1, Water Utility Operating Rules Establishment of Service, states: "No division of the water service lateral to any lot or parcel of land shall be made for the extension and independent metering of the supply to an adjoining lot or parcel of land. Except for duplexes, no division of a water service lateral shall be made at the curb for separate supplies for two or more separate premises having frontage on any street or public service strip, whether owned by the same or different parties."

In the example below, the “side by side” duplex has been subdivided into two individual lots and living units. The above rule prohibits service to the second living unit (Condo 2 in drawing) through the shared lateral. Each unit must be served by an independent lateral from the main to the point of use.

When a “side by side” duplex with one lateral is converted to a condominium and the property is subdivided , each property must be independently served by an individual lateral from the main to the point of use. At the time of subdivision the utility must require the developer or owner to install a second water lateral from the main to the living unit of Condo 2 in the drawing.

Where the utility has not required a separate lateral at the time of subdivision, it should seek to reconcile the problem at the earliest opportunity. Commission staff recommends that, if the situation provides adequate service and the parties are agreeable, the necessary improvements be deferred until the property without its own lateral (Condo 2) is sold or when a leaky lateral needs replacement. At that time, the owner of Condo 2 is required to install a new lateral. This obligation to improve the service lateral should be recorded on the deed so any party interested in purchasing the property is aware of cost.

Where it is apparent that the utility recommended or allowed the improper connection, the utility is required to pay for the street portion of the new lateral and the property owner (Condo 2) must pay for the lateral from the shut off into the dwelling. If there is no record of how the noncompliant situation developed, PSC staff argues that the utility either was or should have been aware of it at one point and chose to allow it. Therefore the utility is responsible for its portion of the lateral in this case.

Occasionally, waiting for the sale of the property is not workable, such as when the property owners are involved in dispute over the situation. In this case the PSC will direct the utility to give written notice to the owner of the property without its own lateral (Condo 2) requiring him or her to install the new lateral within a reasonable period of time. The time allowed to correct the situation is up to the utility, but it often is one to two years.

In all the above scenarios, the property owner keeping the old lateral (Condo 1) normally is responsible for the cost to excavate and abandon the portion of the non-complying lateral on his or her property.

The best way to avoid these problems is to enforce the one lateral per property rule at the time of initial construction and at the time of subdivision. For a “side by side” duplex property it is wise to inform the owner or developer that individual laterals will be required for each parcel if the lot is ever subdivided. If the utility delays requiring compliance, the utility may be required to share the cost to bring the lateral(s) into compliance. Where noncompliant situations already exist, it is good to explain the problem to the property owners and agree to resolve the situation at the earliest opportunity. If the case is particularly complex or contentious, we encourage you to contact Commission staff for guidance.

Water laterals providing service to customers generally consist of two parts. In the vast majority of Wisconsin communities, the utility-owned portion of the service line is located in the public right-of-way and includes the section of the service line from the main to the curb stop box. The customer-owned portion extends from the curb stop box to the property provided with service.

Wisconsin Admin. Code § PSC 185.52 requires that mains and service lines be placed at such depth or otherwise protected as will prevent freezing. If a freeze-up occurs in the main or utility-owned portion of the service line, the utility is responsible for the expense of thawing its facilities. Individual customers may not be held responsible for the expense of thawing utility-owned service lines or mains.

If a freeze-up occurs in the customer-owned portion of a service line, Wis. Admin. Code § PSC 185.88 specifies the situations when the utility is responsible for the expense of thawing the customer's portion of the lateral, and when the customer is responsible for the expense.

A utility may use a magnetic or an ultrasonic meter under one of the following conditions:

1. The utility obtains Commission approval; or

2. The meter operates by battery and the utility tests the meter at the prescribed intervals; or

3. The meter operates by battery and the utility replaces the ⅝, ¾, and 1-inch meters on a 20 year basis.

Wisconsin Admin. Code §§ 185.61 and 185.76 address this question in greater detail.

Wisconsin Admin. Code § 185.61 Meters.

(1) All meters used for measuring the quantity of water delivered to a customer shall be in good working condition. They shall be adequate in size and design for the type of service measured and shall be accurate to the standard specified in Wis. Admin. Code § 185.65. Cold water meters of the turbine type shall be used for metered service only where the actual flow rates fall entirely within the normal test flow limits of the meter. Flow meters, including magnetic and ultrasonic meters, may be used for customer metering only with the specific approval of the commission.

Under Wis. Admin. Code § 185.61, the PSC should be notified if the utility uses magnetic or ultrasonic meters for customer metering. The PSC allows utilities to use these technologies when the meter does not require the use of the customer’s power. Some small magnetic and ultrasonic meters can operate on battery power and can be used for customer metering. A utility does not need PSC permission to use battery-powered magnetic and ultrasonic meters for measuring water usage by its customers.

Wisconsin Admin. Code § 185.76 Periodic tests.

(1) Customer meters ("in-use" meters) shall be tested as frequently as is necessary to maintain their accuracies within requirements set forth in Wis. Admin. Code § 185.65. Unless otherwise authorized by the commission, each utility shall observe a test schedule such that the intervals between tests do not exceed the following:

METER TEST INTERVALS

Meter size = Test Interval

⅝" , ¾", 1" = 10 years

1½" and 2" = 4 years

3" and 4" = 2 years

6" and over = 1 year

(2) Where local water conditions are such that meters shall not retain the required accuracy for the periods indicated, appropriate shorter test intervals shall be observed and may be specifically required by the commission.

(3) Where local water conditions permit and with specific commission approval, the test interval for ⅝-, ¾, and 1-inch meters may be extended. This contemplates that the utility shall demonstrate that the accuracy of its meters shall be retained for such period.

(4) For 3- and 4-inch meters, the above test interval may be extended to 4 years where the utility shall demonstrate that the accuracy of its meters shall be retained for this period.

(5) In lieu of testing every meter as required under sub. (1), a utility may satisfy the requirements of this section by testing meters according to Wis. Admin. Code § 185.761.

(6) When system losses are less than the prescribed percentages under Wis. Admin. Code § 185.85 (4), a utility in lieu of testing every meter as required under sub. (1), may satisfy the requirements of this section for ⅝, ¾, and 1-inch meters by adopting a new meter replacement program that results in each meter being replaced within 20 years of the original date of installation.

Under Wis. Admin. Code § 185.76, the utility should do volume flow tests of the magnetic and ultrasonic meters at the periodic intervals stated in the above table. For most residential customers, the utility should test the meter every 10 years.

Alternatively, a utility may replace the meters after 20 years of use instead of testing meters on a 10-year basis. Wis. Admin. Code § 185.76(6). This assumes that the utility’s water system losses are less than the prescribed percentage set in Wis. Admin. Code § 185.85(4). This alternative does not allow the utility to repair and reinstall these meters at the end of 20 years. If the utility would like to be able to repair and replace these meters on a 20-year interval, then the utility must request a variance to the administrative code and submit data to support its request.

No, the calibration of magnetic and ultrasonic meters is not a substitute for a volumetric meter test. The accuracy of these electronic water meters can vary over time, because electrodes become covered with material, water quality varies from the initial calibration, and meters deteriorate with usage. As an alternative to using a meter test bench, a utility may fulfill the periodic meter test requirements by using a reference meter. Wisconsin Admin. Code § 185.72(2) provides:

A reference meter used for testing domestic or larger meters may be used only if the referenced meter has been tested and calibrated during the preceding 6 months. A record shall be kept of the 2 latest tests of any reference meter. See also Wis. Admin. Code § 185.73 (1).

A wholesale meter should be treated as a customer meter that requires periodic testing according to Wis. Admin. Code § 185.76. Station meters are not used for billing purposes; therefore, they are not considered to be customer meters. Testing every two years is adequate for station meters larger than 6-inch.

No. All meters, regardless of type, must be tested in accordance with the periodic testing requirements included in Wis. Admin Code PSC 185.76. Unless a utility meets requirements included in Wis. Admin Code PSC 185.85(4), small customer meters (those 1 inch or smaller) must be tested every 10 years.

Many utilities allow customers to install additional meters on their service line for the purpose of measuring the volume of water that does not enter the sanitary sewer systems. In order to be considered an additional meter, there must be a primary meter installed on the same service line, and it must be billed on the same account as the primary meter. These meters may also referred to as deduct meters, irrigation meters, sewer meters, or secondary meters.

The configuration and applicable charges for additional meters depends on the plumbing configuration at the customer’s location, the ownership of the meter, the method for recovering public fire protection costs, and the customer classification system established by the utility in its PSC-approved tariff provisions. In general, all primary meters are subject to general service rates (Schedule Mg-1) and public fire protection charges (Schedule F-1 or Fd-1 if the municipality has elected to charge utility customers directly for public fire protection). Additional meters are subject to additional meter charges (Schedule Am-1) and are generally exempt from public fire protection charges. In some instances, a utility may classify additional meters as irrigation meters that are subject to irrigation class rates.

Additional meters owned by the water utility, regardless of configuration, should be reported by the utility in their PSC annual report as “in-stock deduct meters.” Meters that are owned by the customer or by the sewer utility should not be included in the PSC annual report. A customer may own meters for their own internal monitoring purposes as long as those meters are not used by the utility to compute that customer’s water bill. Examples include factories and mobile home parks where the water bill is computed using a master meter. These internal use meters should not be reported in the PSC annual report. A customer who provides their own water supply, such as a private well, may own the meter used to measure water discharged into the sanitary sewer system if the sewer utility is not regulated by the PSC.

The PSC generally recognizes three different metering configurations: the Deduct Method, the Direct Read Method, and the Addition Method.

FIGURE 1 – DEDUCT METHOD

Water Billing - No Irrigation Class

General water service is billed according to Schedule Mg-1 based on the M1 meter size and the M1 reading. If M2 is owned by the water utility, the water utility may charge a meter rental charge under Schedule Am-1 based on the M2 meter size.

Water Billing - Irrigation Class

If the utility has established an irrigation class, M2 is classified as an irrigation meter. Each meter is treated as a separate account. General water service is billed according to Schedule Mg-1 based on the M1 meter size and the difference between the M1 reading and the M2 reading. Irrigation water service is billed according to the irrigation class rates based on the M2 meter size and the M2 reading.

Direct Fire Protection

If the water utility bills its customers directly for public fire protection, the charges under Schedule F-1 (Fd-1) apply only to the M1 account. Typically, these charges are based on the size of service lateral or the M1 meter. No public fire protection charges apply to the M2 meter.

Sewer Billing

Sewer service is billed according to Schedule Smg-1 based on the M1 meter size and the billable sewer volume, which is calculated by subtracting the M2 reading from the M1 reading (for a regulated sewer utility).

Notes

The M1 meter must be owned by the water utility. The M2 meter can be owned by either the water utility or the sewer utility, unless it is used as an irrigation meter.

FIGURE 2 – DIRECT READ METHOD

Water Billing - No Irrigation Class

General water service is billed according to Schedule Mg-1 based on the M1 meter size and the M1 reading. If M2 is owned by the water utility, the water utility may charge a meter rental charge under Schedule Am-1 based on the M2 meter size.

Water Billing - Irrigation Class

If the utility has established an irrigation class, M2 is classified as an irrigation meter. Each meter is treated as a separate account. General water service is billed according to Schedule Mg-1 based on the M1 meter size and the M2 reading. Irrigation water service is billed according to the irrigation class rates based on the M2 meter size and the difference between the M1 reading and the M2 reading.

Direct Fire Protection

If the water utility bills its customers directly for public fire protection, the charges under Schedule F-1 ( Fd-1) apply only to the M1 account. Typically, these charges are based on the size of service lateral or the M1 meter. No public fire protection charges apply to the M2 meter.

Sewer Billing

Sewer service is billed according to Schedule Smg-1 based on the M2 meter size and the M2 reading (for a regulated sewer utility).

Notes

The M1 meter must be owned by the water utility. The M2 meter can be owned by either the water utility or the sewer utility, unless it is used as an irrigation meter.

FIGURE 3 – ADDITION METHOD

Water Billing - No Irrigation Class

General water service is billed according to Schedule Mg-1 based on the M1 meter size and the combined M1 and M2 readings. An additional meter rental charge under Schedule Am-1 may apply, depending on the M2 meter size (see Notes).

Water Billing - Irrigation Class

If the utility has established an irrigation class, M2 is classified as an irrigation meter. Each meter is treated as a separate account. General water service is billed according to Schedule Mg-1 based on the M1 meter size and the M1 reading. Irrigation water service is billed according to the irrigation class rates based on the M2 meter size and the M2 reading.

Direct Fire Protection

If the water utility bills its customers directly for public fire protection, the charges under Schedule F-1 ( Fd-1) apply to the M1 account. If M2 is larger than ¾–inch, public fire protection charges also apply to the M2 account.

Sewer Billing

Sewer service is billed according to Schedule Smg-1 based on the M1 meter size and the M1 reading (for a regulated sewer utility).

Notes

Both the M1 and M2 meters must be owned by the water utility. The Addition Method applies only if M2 is ¾-inch or smaller. If M2 is larger than ¾-inch, Schedule Mg-1 rates apply to both M1 and M2 as separate accounts.

The following examples demonstrate how these charges should be applied to various meter configurations for multi-tenant units. The units could represent multi-family rental units, condo units, or commercial properties.

Example 1: Each M1 meter is treated as a separate general service customer subject to Mg-1 and direct public fire protection charges, if applicable. If the M2 meter is billed on the same account as one of the M1 meters (Unit 1, 2 or 3), it could be considered an additional meter (Am‑1). Under this scenario, public fire protection charges do not apply to the M2 meter. Alternatively, the M2 meter could be billed as a separate account under Mg-1. Unless the M2 meter is billed as an irrigation only customer, public fire protection charges would apply under this scenario. Typically, the owner or association is responsible for charges on the M2 meter.

Example 2: Each M1 meter is treated as a separate general service customer subject to Mg-1 and direct public fire protection charges, if applicable. Because it is served by its own lateral, the M2 meter is treated as a separate general service customer subject both Mg-1 and direct public fire protection charges. The property owner or association would be responsible for charges on the M2 meter.

Example 3: Each M1 meter is treated as a separate general service customer subject to Mg-1 and direct public fire protection charges, if applicable. If the M2 meter is billed on the same account as one of the M1 meters (Unit 1, 2 or 3), it could be considered an additional meter (Am‑1). Under this scenario, public fire protection charges do not apply to the M2 meter. Alternatively, the M2 meter could be billed as a separate account under Mg-1. Unless the M2 meter is billed as an irrigation only customer, public fire protection charges would apply under this scenario. Typically, the owner or association is responsible for charges on the M2 meter (not necessarily Unit 3).

Example 4: The M1 meter is a master meter and is subject to Mg-1 and direct public fire protection charges, if applicable. The M2 meter could be considered an additional meter (Am-1) or a separate irrigation customer under Mg-1. No public fire protection charges should be applied to the M2 meter. The property owner or association would be responsible for charges on the M2 meter.

Example 5: The M1 meter is a master meter and is subject to Mg-1 and direct public fire protection charges, if applicable. The M2 meter could be considered an additional meter (Am-1) or a separate irrigation customer under Mg-1. No public fire protection charges should be applied to the M2 meter. The property owner or association would be responsible for charges on the M2 meter.

Example 6: The M1 meter is a master meter and is subject to Mg-1 and direct public fire protection charges, if applicable. Because it is served by its own lateral, the M2 meter is treated as a separate general service customer subject both Mg-1 and direct public fire protection charges. The property owner or association would be responsible for charges on the M2 meter.

Example 7: Each M1 meter is treated as a separate general service customer subject to Mg-1 and direct public fire protection charges, if applicable. The M2 meter could be considered an additional meter (Am-1) if both M1 and M2 are billed on the same account. Alternatively, M2 could be billed as a separate irrigation customer under Mg-1. If M2 is billed as an additional meter or an irrigation customer, no public fire protection charges should be applied to the M2 meter.

Example 8: No charges would apply if the meter is owned by the sewer utility or the customer. If the meter is owned by the water utility, then Am-1 charges would apply. Direct public fire protection charges would not apply unless the utility has opted to bill non-customers.

It is not appropriate to charge mass property expenditures to operating expenses. The minimum capitalization limit only applies to “items of general plant and other minor units of property.” This does not include mains, services, meters, and hydrants. The Uniform System of Accounts (USOA) specifies meters as the minimum unit of property for plant Account 346. Utilities normally are not routinely replacing a set amount like 10% of their meters each year. Frequently meters are replaced in mass to take advantage of new technology such as remote registers or, today, Automatic Meter Reading (AMR) opportunities. Capitalizing these assets continues to be the best mechanism for regulation and rate setting. Expensing meters could result in too many swings in the rate setting process. In addition, since the utility must track the customer and meter accuracy history associated with each meter, it is appropriate to maintain each meter as a property unit. To date, the Commission has not allowed expensing of meters in any of the utility services.

At present, there are no rules or regulations that prohibit sub-metering. Some municipalities have policies on the metering requirements for new multi-unit construction. Where a master meter is allowed, it is the developer’s choice whether the building is submetered. The PSC approved utility rules provide for either master metering or individual meters to each unit. These two options are identified under Schedule X-1, "Establishment of Service".

While the utility rules and the Administrative Code would allow for the master meter and condo submetering option, a municipal ordinance may further limit these options to individual meters owned and accounts managed by the water utility for new construction. Such requirements could be part of a building permit process.

The utility is responsible for the meter and required to own and maintain it. A customer cannot purchase and install his own meter, and a utility cannot sell its water meter to the customer. Wisconsin Admin. Code § 185.61(2) requires that utilities own all meters used for billing. The customer meter charge incorporates the utility's cost of owning and maintaining its meters, as well as some fixed costs, including capital costs associated with the service line, customer billing costs, and others.

The private fire protection charge, assessed under a utlity's Upf-1 tariff, applies only to unmetered connections. Private fire protection is based on the size of the service line connection to the utility water main. If the situation is one service line with a meter measuring all the water flowing through that connection, then the customer is not charged a private fire protection charge, provided the sprinkler system is connected downstream of the meter.

If a customer has a second service line that is used strictly for fire protection, and the customer sets up the piping so the utility can drop in an eight-inch meter, then again the customer is not assessed a charge under the utility's private fire protection tariff. However, the customer incurs a second bill and is responsible for the eight-inch meter charge and any volume charge that might occur under the utility's Mg-1 tariff. The customer is also responsible for the cost of the connection piping for the meter and for its repair if it is damaged.

Customers are responsible for damage to meters that result from carelessness, negligence or failure to protect the meter. Schedule X-1 of the utility’s rules defines this to include damage resulting from the meter freezing or the presence of hot water or steam in the meter. The utility should charge the customer for the full cost of repairs or replacement, including labor.

What if the property is sold, and the frozen meter is discovered by the new owner?

If the prior customer asked the utility to be disconnected and to stop service, and the utility elects to leave its meter installed, the utility must bear the cost of a damaged meter. If service is later re-established in the name of the prior customer, the utility could charge the owner for the damage. This practice prevents a new customer from being charged for something that he or she had no control over and gives the utility fair warning that it should pull its meter when valving-off a property that has potential to be vacant and unheated over the winter.

The financing of water main construction falls under two general categories -- extending new mains and service lines, or replacing existing mains and service lines. The customer (or developer) typically pays for the cost of a new main and service lines. The utility typically owns the mains and the portion of the service line from the main to the curb stop and is thus responsible for its replacement. The customer typically owns the service line from the curb stop to the point of service and is responsible for its replacement.

New Water Mains

New water mains are financed by one of the methods allowed under Schedules X-2 or X-3 of the utility's PSC approved tariff. Typically, the customer requesting the main extension contributes to the cost of the new main. However, Schedule X-2 does allow the utility or municipality to fund part or all of new extensions. This approach is typically used in situations involving limited overall system improvements such as looping of a dead-end main to improve pressure, flow or water quality.

Replacing Existing Water Mains and Service Lines

As discussed above, the customer typically pays for the initial cost of the water main and service line. In the vast majority of Wisconsin communities, the water utility owns the main and the portion of the service line from the main to and including the curb stop. At the end of their useful life, it is typically the utility's obligation to replace these facilities. In these typical arrangements, the portion of the service line from the curb stop to the point of use shall be maintained and kept in repair and, when worn out, replaced at the expense of the property owner. A small number of water utilities have adopted rules in their tariffs which differ from the PSC's standard rules with regard to replacement and repair of service lines. Please verify the rules for your particular water utility by reviewing its tariff. Water main replacement is generally not discussed in Schedule X-1 of a utility's tariff because it has traditionally been recognized as the responsibility of the utility to repair, replace or expand as necessary.

Several municipalities have used special assessments to finance replacements of the main and the portion of the service line for which the utility is responsible. Neither the PSC nor any state agency has specific regulatory authority over special assessments. That is a power granted directly by the legislature to the municipal governing body. Wisconsin Stat. § 66.0701(12) allows challenges to special assessments to be litigated in state court.

Whether the cost of road repair associated with water main repair should be paid by the water utility or by the street department needs to be determined on a case-by-case basis. In general, the cost-causer should pay for road repair. In water main repair situations, the general practice is that the road repair is paid for by the water utility as a maintenance expense, not a capital addition. If the water utility bears an unreasonably large portion of these types of expenses, it is important to note that the PSC could disallow these costs in future rate cases. For these reasons, it is important to coordinate water and sewer main replacement with planned road replacement.

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