Discussion

1. Tariff Rule 16

Garrapata's Tariff Rule 16, entitled "Service Connections, Meters, and Customer's Facilities" governs the respective responsibilities of utility and customer for installation and maintenance of portions of the water system. The rule has been a part of Garrapata's tariff since first filed in 1963. Utility and customer responsibilities differ depending upon whether the customer's property is inside the service area or beyond its boundaries; if within the service area, whether the location is urban or rural, as in this case; and whether the service expansion falls within the main extension requirements of Tariff Rule 15. We reproduce Tariff Rule 16, in relevant part, in Appendix B.

2. The Service Area Boundary

We begin by considering whether or not Fisch's property is within Garrapata's service area. The current service area map is included in Garrapata's tariff book as Revised Cal. P.U.C. Sheet No. 96-W (Sheet 96-W). This map, submitted as Advice Letter 10 under Mrs. Layne's signature, became effective on April 6, 1986. A hand drawn, red pencil line delineates the service area border on the map; the Fisch property is entirely within that red line, in the northwest corner of the service area.

Garrapata argues that the red boundary line on Sheet 96-W was drawn erroneously and that the map should not have been filed, since the correct northern boundary lies to the south, as described in the CPCN decision.⁸ However, Grover Meyrose, a local surveyor whom Fisch called as an expert witness, surveyed and plotted the acknowledged 1962 boundary--undisputedly, as illustrated in Ex. 17, the 1962 boundary passes through her house.

Garrapata contends, nonetheless, that the original house was built north of the 1962 service area boundary and that the portion which straddles that boundary is a subsequent addition. Both of the Laynes testified the Fisch property always has been an extra-service territory accommodation. Layne pointed out that the tract of land in the northwest corner on Sheet 96-W (i.e., located inside the red line but north of the 1962 boundary) bears a unique cross-hatching, which also appears in Ex. 107 (the map marked "Service Area, drawn by J.L.B. 7/71"). While Sheet 96-W does not explain this cross-hatching, Ex. 107 indicates that it represents an "area being served, but not filed."

Review of the cancelled tariff sheets archived at the Commission does not reveal that Ex. 107 was ever on file as a service area map. Sheet 96-W cancelled and replaced the prior service area map, Cal. P.U.C. Sheet No. 94-W (Sheet 94-W). Sheet 94-W was filed as Advice Letter 9 in compliance with the 1983 main extension decision and bears Mrs. Layne's signature. It became effective on April 13, 1983, and is the first service area map to show service of any kind beyond the northern border described in the CPCN decision. The northwestern portions of Sheet 94-W and Sheet 96-W are identical--the same unique cross-hatching appears inside a hand-drawn line. The legend on Sheet 94-W describes this hand-drawn line as representing the "total area served" while the Sheet 96-W legend identifies the line as representing the "boundary of the service area." Other portions of the two service area maps differ in ways immaterial to the issues raised in this case.

We draw several conclusions. First, at least a portion of the Fisch property has been part of Garrapata's filed service area since the utility's formation. Second, while there is some evidence to support the Laynes' testimony that service to the Fisch property began as an extra-service territory accommodation, it is circumstantial and cannot substitute for the lack of any documentary proof. Garrapata has produced no written agreement to establish the existence of an extra-service territory service arrangement, nor is such an arrangement noted anywhere in the utility's tariff, in any advice letter, or in any Commission decisions concerning Garrapata. No former tariff schedule established a metered rate for customers outside the service area, nor is there a flat rate for such customers now. Garrapata's Tariff Rule 4, filed as part of Advice Letter 1 in 1963, requires a contract for service under non-standard rates or conditions. For all of these reasons and particularly in the face of Fisch's reliance, Garrapata may not disavow, for the purpose of assigning greater responsibility to Fisch under Tariff Rule 16, the 1986 service area map filed as Sheet 96-W.

3. Point of Delivery of Service

Since we have determined that Fisch's property is within Garrapata's service area, and since the area is rural, Tariff Rule 16.A.1.a.(2) governs utility responsibilities with respect to establishment of a service connection, and 16.A.2.a. and 16.A.2.b. govern customer responsibilities. (See Appendix B.) Under the tariff, the location of a service connection determines "the point of delivery of water service to the customer." (Tariff Rule 16.A.1.b.)

3.1 Fisch's Showing

Fisch contends that the point of delivery of service is the meter box near the south side of her house. Ex. 5 is a photograph of the meter box and appears to show a concrete box resting entirely above ground on a downward slope. Though Fisch testified that she observed the meter box when she walked the property with the caretakers who had been managing it for at least 12 years prior, she did not inquire if the meter was functioning since she knew that Garrapata provided water to the property on a flat rate basis. She testified that she did not inquire which piping belonged to the property or make any other inquiries about the water distribution system serving the property. Fisch also testified that she had no discussions with other customers of Garrapata, other than her realtor, and was "not really" aware of the small size of the utility at the time she purchased the property. (Tr. 86.) Fisch does not live on the property full time but uses it as a "1031 exchange investment income property." (Tr. 87.)

Though the utility now has a flat rate structure, Fisch's brief notes that Garrapata's 1962 CPCN application proposed metered rates and points to three Advice Letter (AL) filings in Garrapata's tariff book which transmitted the original Schedule No. 1A for "Annual General Metered Service" (AL 1, dated March 22, 1963) and two subsequent updates (AL 4, dated September 15, 1970; AL 7, dated June 23, 1975). Fisch then argues: "It is logical to assume that the meter shown in Complainant's Exhibits 4 and 5 was placed at its location to meter service to Complainant's parcel and to fulfill the mandate of [Tariff] Rule 16.A.1.a.(2)." (Fisch opening brief at 8.) In her view, this location provides a "convenient" service connection in accordance with Tariff Rule 16.A.1.a.(2); more particularly, no other location is convenient to her. Fisch does not address the Tariff Rule 16.A.2.b. requirement that a customer's piping provide the utility with easy access from its existing distribution system and require minimal extension of the existing distribution main.

3.2 Garrapata's Defense

Garrapata counters that the existence of a meter on Fisch's property fails to establish that site as the original point of delivery of service or prove that the water line crossing Garrapata Creek is a utility main. Arguing that the utility was in financial and operational disarray at the time Morris acquired it in 1974, Garrapata appears to suggest those facts limit its ability to prove, undisputedly, who installed either the meter box or the water line, and under what terms. Mrs. Layne testified that Morely Baer, who built the original house on what is now Fisch's property and owned it at the time Morris acquired the utility, acknowledged the water line to be his private service line and spoke with her about its frailty. Layne stated that he made repairs on the water line in the late 1980s for Mrs. Bloom, who owned the property then and paid for the parts. Layne contends that considering the extreme geography of Garrapata Creek, the only reasonable interpretation is that the water line is a private service line.

The Garrapata system never actually was operated as a metered system during the 1960s and 1970s, according to the testimony of both of the Laynes. Mrs. Layne stated that though some meters had been installed before Morris acquired the utility, as far as she knew they were never read; subsequently, those that malfunctioned were eliminated. Layne testified that he installed a number of meters on the system in the 1980s, including one at the southern end of the water line, not to meter water usage for rate calculation but to serve as leak detection devices. Layne stated he had no knowledge of the meter near Fisch's house until after Fisch purchased the property and never read it or used it for any purpose.

3.3 An Equitable Resolution

With one exception (Meyrose), the witness testimony in this proceeding tends to yield more heat than light. As is readily apparent from the two preceding sections, some of the testimony is hearsay, some of it is speculation, and much of it is self-serving. We consider next Ex. 200, the report the ALJ requested from the Water Division's staff engineer after hearing was adjourned. Ex. 200 supplements the factual information provided at hearing about the meter on Fisch's property. The meter box is not sited in the ground but rests over the top of a 1½-inch galvanized water pipe leading to Fisch's house. The location of the meter box is approximately 200 feet east of the house and about 50 feet west of the point where the 1½-inch galvanized water pipe intersects with the 1½-inch water line that comes up from Garrapata Creek. Lifting the meter box up and setting it aside, the staff engineer found a ¾-inch, nonfunctioning, brass water meter which he estimated to be 25 years old, perhaps older, and which appeared to have been in its present position for a considerable period of time. There are no valves at or in the vicinity of the meter.

Thus, Ex. 200 establishes that someone, at some time in the past, installed a water meter in the piping that carries water to Fisch's house. As noted previously, Garrapata admits to serving the Fisch property since 1964; Fisch's complaint states the original house was built in 1965. Considering the small size of the utility system, its capacity and the limited number of service connections in 1962, the water service to Fisch's property some two years later could not have occurred without the utility's knowledge. Presuming then that the meter and meter box represent the service connection and therefore, the point of delivery of service, it does not appear that their placement complies with the requirements of Tariff Rule 16 in at least two respects.

First, the meter and meter box are not located at the point where the 1½-inch galvanized customer piping and the water line at issue connect (which would seem a more standard placement), but 50 feet to the west, nearer Fisch's house. Second, a much more major concern is the nonstandard siting of the water line that spans Garrapata Creek.

From the place it connects with the 1½-inch galvanized pipe, the water line runs easterly across Fisch's property to Highway 1. Garrapata's Highway 1 water main does not reach that far north--it ends south of Garrapata Creek. Thus, the water line continues along Highway 1 a short distance, and in the vicinity of the north end of the Highway 1 bridge, drops some 200 hundred feet down the canyon wall on the north side of Garrapata Creek. The water line spans the creek bed, continues up the south bank, and now leads to one of four new meters where it taps into a new, 4-inch main in the utility easement along Highway 1 south of Garrapata Creek. The total distance on the ground between the two metered points is approximately 900 feet, though Garrapata acknowledges responsibility for the southern-most 200 feet.⁹ The water line does not serve any other property.

Clearly, as Fisch argues, at least half of the water line (all the pipe located in Garrapata Creek canyon) is not readily accessible to her. Nor is it readily accessible to anyone else. This reality, however, and the parties' arguments about it, masks the greater problem--a mutually convenient interconnection does not exist because, in 1964, when Fisch's property was connected to Garrapata's distribution system, the customer and utility failed to build a main extension across the Highway 1 bridge. The water line that scales the canyon and runs above the creek bed is sub-standard. The pipe is routinely damaged during floods and, as noted above, its location is precarious and difficult to reach.¹⁰ Layne testified that leaks in the water line drain quickly enough to risk the water system's integrity and the imposition of State Water Control Board penalties for overdraft.

Fisch apparently misconstrues Tariff Rule 16 to require the utility to extend its water main, at its sole cost, to serve all customers within the service area. The provision that governs the utility's responsibilities to install service connections in rural areas (Tariff Rule 16.A.1.a.(2)) does not stand alone, however. It expressly refers back to the previous, more complete description of the utility's responsibilities to install service connections in urban areas, a responsibility which excludes "temporary services and as otherwise provided in Rule No 15, Main Extensions" (Tariff Rule 16.A.1.a.(1)). Neither can these provisions defining utility responsibilities be read without considering the customer's responsibilities. Tariff Rule 16.A.2.b. expressly provides that the customer shall install its own piping so as to require the least extension of the main.

Main extensions can be expensive, and no less so in rural areas than in urban ones. We have no evidence on what the cost of a main extension would have been in 1964, a cost that the customer avoided.¹¹ However, in the 1983 main extension decision, the Commission determined that in light of the constrained finances of very small water companies like Garrapata, customer funds which had been advanced under two defective main extension contracts in the mid-1970s should not be refunded. The Commission rebuked the utility for its role in signing the defective contracts but declined to order refunds to the customer. Rather, the Commission held that the funds advanced should be accounted for as nonrefundable contributions of the plant facilities necessary to serve the customers' properties, reasoning:

"Otherwise, an excessive burden would result for defendant's [other] customers. Very small water companies are by their nature uneconomical. Any return on rate base is problematical and sufficient cash flow to make refunds on main extension contracts is seldom present. Defendant is no exception. Clearly, the extension itself, serving only a few customers, would not develop nearly enough revenue to be self-supporting." (1983 main extension decision, mimeo. at 7.)

The record in this case does reflect that Layne and Fisch had preliminary communications, at different times, with the California Department of Transportation (CalTrans) about installation of a main underneath the Highway 1 bridge that spans Garrapata Creek. Their anecdotal testimony indicates that CalTrans most recently estimated the cost at several hundred thousand dollars, though it is not evident that a formal estimate has ever been requested.

The parties' testimony and briefs focus extensively upon the locations of the various meters, and their accessibility or inaccessibility to one party or the other. We do not discuss this opposing testimony in further detail because we conclude it misses the mark. Noncompliance with the main extension limitations in Tariff Rule 16 (and the requirements of Tariff Rule 15) does not convert this nonstandard water line into either a water main or a private service line.

We are troubled that Garrapata has taken no steps to formalize responsibility for ownership and repair of the water line over nearly four decades. Garrapata itself produced Ex. 103, a 1970 letter from the Commission's Executive Director to Garrapata's former, absentee ownership which lists 15 separate problems identified by Commission staff in the course of a water system field trip in June of that year. The problems range from questionable service connections (several are noted as being unmetered) to leaks and other plant repair concerns. Item number 10 explicitly notes the existence of what was then a ¾-inch line crossing Garrapata Creek to serve the property Fisch now owns. We need not rely on Garrapata's attempt to introduce circumstantial evidence that the water system was in some disarray before Morris acquired it--Ex. 103 establishes that fact directly. But that fact does not avoid, let alone answer, the question before us: who should pay for repairs to the nonstandard water line that presently crosses Garrapata Creek?

Generally, operations and maintenance expenses incurred by a utility in making repairs to its plant are factored into the annual revenue requirement recovered from all customers in rates. We see neither legal grounds nor equitable ones for deeming the entirety of this nonstandard water line to be utility plant and thereby imposing the full, annual cost of repairs on Garrapata's customers through the rates they pay. Approximately half of the water line (to the midpoint of Garrapata Creek) is on Fisch's property; thereafter it crosses land she does not own. The record does not reflect whether anyone holds an easement for the water line route between the southern border of Fisch's property and the point, further south, where it enters the utility easement that parallels Highway 1.

On balance, we conclude the evidence presented in this case warrants assigning responsibility for the outstanding bill of $396.39 and for the costs of future repairs equally between Fisch and Garrapata. As a public utility, Garrapata is charged to provide reasonable service within its service area and therefore, we conclude that Garrapata should perform any needed repairs to the water line, or contract for their performance. Repairs should be made as quickly as reasonably can be arranged, considering the location of the water line, in order to limit the time Fisch is left without water when damage to the water line necessitates shutting off water to her property. Fisch shall provide Garrapata or its agent reasonable access to her property for the purposes of locating damage and making repairs. Once the repairs have been completed, Garrapata shall bill Fisch for one half of the cost of the repairs. The remainder shall be a utility liability, which Garrapata shall not recover from its ratepayers in rates or separate assessments. In subsequent GRC applications, Garrapata shall separately itemize the costs of any repairs to the water line and shall exclude them from the annual utility expense calculations required to support a request for a rate adjustment.

In addition, we direct Garrapata to prepare a preliminary study of the feasibility of extending its Highway 1 main across Garrapata Creek and to submit the study to the Commission's Water Division within six months of the effective date of this decision. The study shall report the number of potential service connections, in addition to the Fisch property, and the status of existing fire protection north of Garrapata Creek as well as any other information which the Director of the Water Division shall require. In an effort to reduce speculation, we direct Garrapata to request, in writing, from CalTrans a formal cost estimate for all work on the Highway 1 bridge associated with such a main extension. Garrapata shall provide a copy of its request to the Director of the Water Division and shall include CalTrans' response in its preliminary study.

Nothing in this decision assigns any responsibility for funding the costs of any future main extension to Garrapata or to any of its present or future customers.

Findings of Fact

1. Garrapata was permitted to present its defense at evidentiary hearing in the manner it chose within the timeframe it requested.

2. By its own admission, Garrapata has provided water to the Fisch property since 1964; the original house on Fisch's property was built in 1965.

3. Garrapata's acknowledged 1962 service area boundary undisputedly passes through Fisch's house.

4. A hand drawn, red pencil line delineates the service area border on Garrapata's current service area map, filed in 1986 as Sheet 96-W. The Fisch property is entirely within that red line, in the northwest corner of the service area.

5. On Sheet 96-W and on the prior service area map (filed in 1983 as Sheet 94-W) the tract of land in the northwest bears a unique cross-hatching which also appears in Ex. 107. The Ex. 107 legend describes this cross-hatching as representing an "area being served, but not filed."

6. Review of the cancelled tariff sheets archived at the Commission does not reveal that Ex. 107 ever was filed as a service area map.

7. Garrapata has produced no written agreement to establish the existence of an extra-service territory service arrangement nor is such an arrangement noted anywhere in the utility's tariff, in any advice letter, or in any Commission decisions concerning Garrapata. No former tariff schedule established a metered rate for customers outside the service area, nor is there a flat rate for such customers now. Garrapata's Tariff Rule 4 requires a contract for service under non-standard rates or conditions.

8. The photograph in Ex. 5 shows a cement meter box which appears to be resting above ground on a downward slope on Fisch's property.

9. The Commission staff engineer's report of his inspection (Ex. 200) establishes that the meter box is not sited in the ground but rests over the top of a 1½-inch galvanized water pipe leading to Fisch's house. The location of the meter box is approximately 200 feet east of the house and about 50 feet west of the point where the 1½-inch galvanized water pipe intersects with the 1½-inch water line that comes up from Garrapata Creek. The meter box rests over a ¾-inch, nonfunctioning, brass, water meter which appears to be at least 25 years old and which has been in its present position for a considerable period of time. There are no valves at or in the vicinity of the meter.

10. The meter and meter box are not located at the point where the 1½-inch galvanized customer piping and the water line interconnect but 50 feet to the west, nearer Fisch's house.

11. The water line that drops down into the Garrapata Creek canyon and spans the creek bed is nonstandard.

12. The water line serves only Fisch's property.

13. Approximately one half of the water line is located on Fisch's property (to the mid-point of Garrapata Creek); the rest is located on property Fisch does not own.

14. Because of the terrain of the Garrapata Creek area, at least half of the water line (all the pipe located in Garrapata Creek canyon) is not readily accessible to anyone.

15. Flooding through Garrapata Creek routinely damages the water line.

16. The nonstandard water line is neither a water main nor a private service line.

17. Garrapata has taken no steps to formalize responsibility for ownership and repair of the water line over nearly four decades.

18. Approximately half of the water line (to the midpoint of Garrapata Creek) is on Fisch's property; thereafter it crosses land she does not own. The record does not reflect whether anyone holds an easement for the water line route between the southern border of Fisch's property and the point, further south, where it enters the utility easement along Highway 1.

Conclusions of Law

1. Garrapata's rights were not abridged when the ALJ adjourned the evidentiary hearing at 3 p.m.

2. For the reasons discussed in this decision, Garrapata's Ex. 102, Ex. 104, and Ex. 106 should not be received in evidence.

3. Garrapata's Ex. 105 should be received in evidence solely as corroboration of other evidence that Garrapata's Highway 1 main ends south of the Garrapata Creek bridge on Highway 1.

4. Garrapata's Ex. 107 should be received in evidence solely for its circumstantial, explanatory value with respect to certain aspects of Garrapata's present and former filed service area maps, as discussed in this decision.

5. Admitting Ex. 105 and Ex. 107 does not require us to set aside submission of this case and request another round of briefs, since as we discuss in this decision, other, adequate means exist to protect the rights of the parties.

6. At least a portion of the Fisch property has been part of Garrapata's filed service area since the utility's formation.

7. The circumstantial evidence which supports the Laynes' testimony that service to the Fisch property began as an extra-service territory accommodation cannot substitute for the lack of any documentary proof.

8. Garrapata may not disavow, for the purpose of assigning greater responsibility to Fisch under Tariff Rule 16, the service area map filed in 1986 as Sheet 96-W.

9. The provisions of Tariff Rule 16 must be read together. The provisions that govern the utility's responsibilities to install service connections in rural areas refer back to the previous, more complete description of the utility's responsibilities to install service connections in urban areas, a responsibility which excludes "temporary services and as otherwise provided in Rule No 15, Main Extensions." The customer's responsibilities include installing piping so as to require the least extension of the existing main.

10. Tariff Rule 16 does not require the utility to extend its water main, at its sole cost, to serve all customers within the service area.

11. The water line does not comply with the Tariff Rule 15 main extension requirements incorporated in Tariff Rule 16.

12. The evidence presented in this case warrants assigning responsibility for the outstanding bill of $396.39 and for the costs of future repairs equally between Fisch and Garrapata.

13. Garrapata should perform any needed repairs to the water line, or contract for their performance, and then bill Fisch for one half of the cost.

14. Neither legal grounds nor equitable ones warrant deeming the entirety of the nonstandard water line to be utility plant and thereby imposing the full, annual cost of repairs on Garrapata's customers through the rates they pay.

15. Garrapata, or its agent, should make repairs to the water line as quickly as reasonably can be arranged, considering the location of the water line, in order to limit the time Fisch is left without water when damage to the water line necessitates shutting off water to her property. Fisch must provide Garrapata or its agent reasonable access to her property for the purposes of locating damage to the water line and making repairs.

16. Garrapata should prepare a preliminary study of the feasibility of extending its Highway 1 main across Garrapata Creek, as further discussed in this decision.

17. Nothing in this decision assigns any responsibility for funding the costs of any future main extension to Garrapata or to any of its present or future customers.

18. In order to provide certainty to the parties regarding the status of service to Fisch's property and responsibility for repair of the water line, this decision should be effective immediately.

ORDER

IT IS ORDERED that:

1. Ex. 102, Ex. 104, and Ex. 106 offered by Garrapata Water Co., Inc. (Garrapata) are not received as evidence in this proceeding. Garrapata's Ex. 105 and Ex. 107 are received for the limited evidentiary purposes discussed in this decision.

2. The property now owned by Carol Fisch (Fisch) is within Garrapata's service area but the nonstandard water line is neither a water main nor a private service line.

3. Garrapata shall perform any repairs to the water line needed in future, or contract for their performance, and then bill Fisch for one half of the cost of such repairs. Repairs shall be made as quickly as reasonably can be arranged, considering the location of the water line, in order to limit the time Fisch is left without water when damage to the water line necessitates shutting off water to her property. Fisch shall provide Garrapata or its agent reasonable access to her property for the purposes of locating damage and making repairs. Once the repairs have been completed, Garrapata shall bill Fisch for one half of the cost of the repairs. The remainder shall be a utility liability, which Garrapata shall not recover from its ratepayers in rates or separate assessments.

4. Fisch shall pay Garrapata one half of the outstanding water line repair bill of $396.39 and one half of any future repairs.

5. In subsequent GRC applications, Garrapata shall separately itemize the costs of any repairs to the water line and shall exclude them from the annual utility expense calculations required to support a request for a rate adjustment.

6. Garrapata shall prepare a preliminary study of the feasibility of extending its Highway 1 main across Garrapata Creek and shall submit the study to the Commission's Water Division within six months of the effective date of this decision. The study shall report the number of potential service connections, in addition to the Fisch property, and the status of existing fire protection north of Garrapata Creek as well as any other information which the Director of the Water Division shall require. Garrapata shall request in writing from the California Department of Transportation (CalTrans), a formal cost estimate for all work on the Highway 1 bridge associated with such a main extension. Garrapata shall provide a copy of its request to the Director of the Water Division and shall include CalTrans' response in its preliminary study.

7. This proceeding is closed.

This order is effective today.

Dated , at San Francisco, California.

Appendix A

Exhibit 9

(See CPUC Formal Files for Appendix A: Exhibit 9.)

Appendix B

Tariff Rule No. 16 (Excerpt)

SERVICE CONNECTIONS, METERS, AND CUSTOMER'S FACILITIES

A. General

1. Utility's Responsibility

a.

(1) In urban areas with dedicated front streets, rear service roads, or public utility easements the utility will furnish and install the service pipe, curb stop, meter and meter box at its own expense for the purpose of connecting its distribution system to the customer's piping, except for temporary services and as otherwise provided in Rule No. 15, Main Extensions. The service connection, curb stop, meter and meter box will be installed at a convenient place between the property line and the curb, or inside the customer's property line where necessary.

(2) In areas which do not have dedicated front streets, rear service roads, or public utility easements the utility will furnish and install the service pipe, curb stop, meter and meter box as above provided but at a convenient point on or near the customer's property except for service beyond the service area.

b. The service connection will determine the point of delivery of water service to the customer.

2. Customer's responsibility

a. Condition Precedent to Receiving Service

The customer as a condition precedent to receiving service shall:

(1) Furnish and lay the necessary piping to make the connection from the service connection to the place of consumption and shall keep such piping in good repair in accordance with such reasonable requirements of the utility as may be incorporated in its rules herein.

(2) Provide a main valve on the piping between the service connection and the point of customer use.

(3) Where service is rendered at or near the service area boundary for use beyond the service area, install, operate and maintain the facilities necessary to provide service.

b. The customer's piping shall extend to that point on the curb line or property line of easiest access to the utility from its existing distribution system or requiring the least extension of the existing distribution main. The utility shall be consulted before installation thereof and its approval of location secured.

* * *

(END OF APPENDIX B)