TAP (Tellico Action Plan) is the result of more than three years of research and analysis. Over 1000 hours have been invested in learning, reviewing, and planning for our community’s necessary water and sewer infrastructure upgrades. We engaged Jacob’s Engineering, a top-tier national firm, to produce both a Water and Sewer masterplan. They identified five critical infrastructure projects that have been reviewed and are supported by POA Staff, the Public Services and Finance Advisory Committees, and the TVPOA Board of Directors.

View Legal Opinion Regarding Water & Sewer Asset Fee HERE
Click here to view the current 2024 Water Rates.
Board of Directors Response: Addressing the Water & Sewer Asset Fee
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Q & A's

Why are irrigation restrictions not put in place to reduce the peak hourly summer demand?

Irrigation restrictions require considerable thought and consideration about the common reasons for irrigation restrictions, the goal for consumption reduction, the financial implications, and whether to use a voluntary or mandatory approach.

The most common reason utilities institute irrigation restrictions is to preserve limited raw water sources of supply (ground wells, lakes, rivers, etc.).   In Tellico Village, there is an adequate supply of water (see below Question No. 19 for more details on supply and demand).  In that light, think of water as a commodity.  When you have available water, and there are customers, you sell it.  Implementing restrictions on irrigation (your commodity) to avoid a sizable capital investment is very unusual. Instead, it is far more common to make the capital investment and ensure the revenue generated from the commodity.

To be clear, simply shifting the irrigation load to the nighttime doesn’t appear to solve anything.  There will still be peaks in demand, and operational personnel will have to work night shifts to manage the operational elements required to address peaks.

Building on that point, it would be essential to identify the goal for irrigation restrictions.  Given the context of this question, it seems like the goal would be to limit consumption to the point where the proposed Elevated Water Storage Tank isn’t needed.  To identify a possible target, consider Tellico Village consumes approximately 189,200,000 more gallons of water in the irrigation months than in non-irrigation months.  While not all that consumption would need to be eliminated to forgo the construction of an Elevated Water Storage Tank, let’s say (for the sake of explanation) the target is a 50% reduction or approximately 95 million gallons.  To accomplish that, it is realistic to assume that irrigation restrictions would not only be reduced to not less than two days per week (perhaps even one day per week).  Further, it would be prudent to institute irrigation during limited periods (for instance, only 5 a.m. to 7 a.m. on a per-neighborhood basis).  Regardless of how the irrigation restrictions are structured, reducing over 95 million gallons of consumption is an ambitious goal.

Additionally, the reduction of 95 million gallons is based upon the estimated 5,600 single-family residences in the Main Village.  As additional homes are built, restrictions must be adjusted to recognize the extra demand with more homes to be constructed.  Today’s irrigation restrictions would likely need to be reviewed to ensure further development does not warrant discussions about an Elevated Water Storage Tank.

Consider the estimated goal of reducing 95 million gallons, which means less water revenue.  It would be wise to assume that since the restrictions are aimed at less watering, the revenue loss will be realized primarily in the 2nd and 3rd tiers of usage (priced in 2024 at $9 and $15 per 1,000 gallons, respectively).  Between the lost revenue resulting from decreased water consumption, it is estimated (based on 2024 rates) that the loss in revenue will be $745,876.  Unfortunately, most operating costs associated with operating a utility are fixed.  Employment costs, insurance, electricity, water quality testing, materials and supplies to repair leaks, etc., are generally the same regardless of whether TVPOA sells everything available.  As a result, water restrictions typically bring rate increases.  Consider if you will the “sting” of using less and being charged more.  This is among the primary reasons that irrigation restrictions are generally employed only when a utility is afraid of running out of water.

The current even/odd restrictions are voluntary.  However, mandatory restrictions would be required to achieve an ambitious goal of reducing 95 million gallons (at least in the short term).  Enforcing irrigation restrictions requires driving (generally) slower than the speed limit to observe both sides of the road.  Observed violations require stopping and documenting.  Keep in mind that Tellico Village has over 110 miles of roadway.  One person cannot adequately enforce.  An enforcement team will likely be needed.  That also can bring additional costs that will be covered on top of rate increases to cover lost revenue.

Keep in mind the existing 500,000-gallon water ground storage tank is leaking.  It is not tall enough to adequately ensure pressure in the higher elevations.  Aside from household pressure issues, lower pressure diminishes fire protection for those residents, and the existing ground storage tank is not operationally equipped to address aged water efficiently.  Irrigation restrictions will not solve any of those problems.

What is the status of upgrading/replacing the water line to the Wellness Center?

As envisioned, this project’s design is estimated to be completed at the end of the third quarter of 2024, with a procurement process and recommendations for contract award in the fourth quarter of 2024The project is estimated to be completed in the first quarter of 2025. 

Did TVPOA ever send a letter to TDEC stating that storage requirements are being met by LUB, with a copy of the agreement?

There is no evidence that the letter was or was not sentRegardless, no evidence supports that LUB’s construction of the ground storage tank (resulting from the 2020 contract with LUB) meets the Main Village’s storage requirementSee the answer to Question No. 19 below on why water storage is needed.   

Does the TVPOA have a similar agreement for water storage for Kahite with TASS? If so, has it been submitted to TDEC?

The format for the TASS agreements is “take or pay,” with a 3 million gallon per month minimum and 10 million gallons per maximum for the Loudon County supply and a 1 million gallon minimum and 10 million gallons per month maximum for Monroe County. 

TVPOA is required to report every quarter to TDEC on monthly flows. Did Jacobs cross-check the calculated flows to the reported flows as a verification?

YesHowever, since there is no internal metering of the Tellico Village wastewater system, the TVPOA’s means of reporting wastewater flows to TDEC is based on metering owned by our wholesale suppliers and monthly invoices paid to LUB and TASSMeters malfunction, so the more accurate and industry-standard means of measuring wastewater flows is to use pump draw-down tests and assess wastewater flows based on pump run timesFor the studies Jacobs has completed for Tellico Village, they have used pump draw-down tests.   

Is there an inventory/report showing the work completed on the collection tanks? This report should show the tanks that needed additional work concerning locations, but it should not show that all the tanks need to be replaced.

There are hand-written notes from PSAC members and some TVPOA correspondence sent to Kahite residents. However, nothing could be located documenting the work completed concerning locations or residences that still need additional work. 

Does TVPOA have an emergency contract in place with a vendor for the supply of vacuum trucks within a certain time to transport effluent to LUB via trucks?

NoThe nearest Roto-Rooter is in Athens, TN (actually 6 miles south of Athens)They have four large trucks (3,500 gallons capacity) and one small truck (2,000 gallons capacity)In a wet weather event, they’ll be called by Tellico Village, LUB, and LCUB (Lenoir City Utility Board)Everyone will need them, and they will not have adequate capacity to solve everyone’s problems.  Even if Tellico Village is the only utility that needs them, a truck pumping (generously) 350 gallons per minute will fill in 10 minutesSometimes, they must haul the waste to Cleveland, TN.  If they’re lucky enough to go no further than a round trip to Loudon, their assistance is limited to approximately 3,500 gallons per hourThe difference (for instance) between what the Main Pumping Station can pump and what it receives is 150 gallons per minuteEquating Roto-Rooter with a solution to excess wastewater flows is putting a band-aid on a bullet hole.   

What is TVPOA's plan to start inspecting the individual collection tanks, generating an action plan, starting with the oldest in Toqua?

As discussed in the Public Services Advisory Committee, Finance Advisory Committee, and public Board meetings, inspections on individual collection tanks require time and laborPerhaps volunteers can be a force multiplier, but there are limitations with availability and other time commitments with volunteersThe decision to inspect and/or commence any meaningful remediation at the individual collection tanks is a topic of Advisory Committees, and the Board of Directors is awareTo undertake that task, it would procedurally start with recommendations from the TVPOA staff to the board or board direction to the committees in the inverseRealistically, the earliest this process could commence would be budget considerations for Fiscal Year 2025

When will TVPOA correct the statement that the work to replace the collection tanks and all the extra costs related to items around the tanks?

The only statement the TVPOA has made is that no decision has been made regarding whose expense repairs to the collection tanks would fall on.  That is not an incorrect statement.  Given the possible magnitude of expense and the inconvenience property owners would experience, the decision to place the expense on property owners would require Board approval. 

It is essential to provide further consideration to the implications of this inquiry.  As it stands, the Board of Directors has approved an $80/month Water/Sewer Infrastructure Fee to, in part, address Inflow and Infiltration.  That is the Board of Director’s direction.  Consider the implication of burdening property owners with remediating Inflow and Infiltration on their property along with the Water/Wastewater Infrastructure fee.     

When will TVPOA correct the videos and handouts stating “Risk if ignored, potential sewer backups into home”?

The videos do not make that statementThere are instances where property owners have had wastewater back up into their homes.  No correction seems required.   

Did the final Jacobs report review replacing the controls to make the existing pumps into variable speed pumps?

The impetus behind this question is the assumption that if wastewater is pumped more consistently, odor control measures are unnecessary.  To contrive this assumption, one must ignore that wastewater arrives in pumping station wet wells in a septic state because it has sat in household tanks for several days (in the case of liquids) and perhaps weeks in the case of solids.  Hydrogen sulfide and other gases exist long before the wastewater arrives at a neighborhood pumping station.   

Furthermore, the industry standard for designing wastewater odor control systems is 12 air changes per hour in the wet well.  Variable frequency drive pumps do not affect air changes at that frequency.  Hence, there is a need for vapor phase odor control systems that remove and filter hydrogen sulfide and other gases in the air.   

This proposed solution of installing variable frequency drive pumps has been vetted by two specific Public Services Advisory Committee members with a combined 80 years of civil water and wastewater experience.  It has also been vetted with Jacobs Engineering.  No one believes installing variable frequency drive pumps will solve odor control by themselves.  It simply doesn’t resonate with others with considerable field experience.   

When will the final PE-stamped Jacobs Engineering reports be available on the TVPOA website?

Jacobs Engineering is not required to affix an engineering stamp on reports (unless in some instances when they are being submitted to a State or Federal agency).  Formal and final design documents will be stamped for procurement and construction engineering purposes.   

What’s the status of roof drain testing?

To date, TVPOA Public Works staff has completed roof drain testing on 5.5 homesA typical house has seven drains, so approximately 38 drains have been testedNo drains have been identified, either connected to the tank, the sewer lateral from the house, or the hole in which the tank is installedThe total time invested in roof drain testing is approximately 12 hours (2 people for 6 hours)TVPOA Public Works staff has continued to ask residential contractors if they have seen (or even heard) of roof drains being connected to the tank, the sewer lateral, or the whole in which the tank is installed. There continues to be a resounding response along the lines of “Never done it, never seen it done, never even heard of it! 

How will the Inflow and Infiltration problem be addressed?

The issue of labor and expense (amount and who bears the expense), the time required, and the targeted outcomes will be considered during the 2025 Budget process.   

Is there a way to assess Inflow and infiltration by metering the electrical panel connected to the pump and tank to determine which homes may be contributing more I&I than others?

This is being doneBig thanks to resident Bob Bilodeau for manufacturing a homemade electrical meter at his own expense and working with Public Works to install it on the electrical panel that services the pump and tankMr. Bilodeau has gathered about three months of data and shared the outcomeIn short, the goal is to attempt to reconcile pump run times with how much wastewater is leaving the tankPreliminarily, there are some indications that this reveals some helpful dataHowever, when the data is most critical (during a wet weather event) is also when the data is most unreliable because if the wastewater main is full, the pump may be working, but no wastewater is leaving the tankBut rest assured, no ideas or volunteer efforts by residents are being ignored. 

Are tank alarms a method of identifying which homes may be contributing more I&I than others?

PerhapsSewer tank alarms can indicate a lot of thingsThey could be a result of significant I&I in the tankOr, they could be indicative of a malfunctioning pump, float switch, or electrical componentsIsolating I&I as the culprit for an alarm isn’t simpleIt’s a clue, but it isn’t as definitive as one might hope. 

John Oldsen’s question about water/wastewater conversion usage from the June Town Hall meeting.

Some may recall that resident John Oldsen asked a question at the May Town Hall meeting regarding estimated wastewater flows in Kahite, which are equated to excessive water usageTo his credit, Mr. Oldsen identified a shortcoming in the TAP video presentations that deserve correctionIn short, Mr. Oldsen articulated a dry-weather inflow of 118 gallons per minute on one of the slidesThat specific row should have been noted as “projected future build-out” dry-weather inflowIn that light, as a projected future build-out estimate, the water consumption equates with something more reasonable and along the lines of an industry standard of 100 gallons per person in the household. 

Who is PSAC and what is their involvement with these issues?

This question stems from a comment offered by a resident who is an engineer.  The comment is as follows: 

“As a closing to the comments and questions, one should understand not only the role of representing a public agency but also the “Engineering Consultant.”  TVPOA has hired Jacobs Engineering to be the engineering consultant for both the water and sewer issues.  Their scope is to present solutions to complex issues in TV.  During the May 30th Town Hall meeting, it was stated that problems are solved by a step-by-step process.  Some of the early Jacob’s reports did state the problems on both the sewer and water issues, with solutions.  However, during this process, it is apparent that Jacobs was instructed with the solution/s to the problems.  One example is the requirement of a water tank on the north end of the village, then switched to booster pumps, that switched again to an elevated tank near the existing ground storage tank. 

POA Public Works Staff and PSAC members must understand their role in the process.  They should not have a consultant mindset when reviewing reports or drawings.  I understand some of the PSAC members are spending hours and hours reviewing Jacobs reports, i.e. performing QA/QC.  If I had a consultant send me a report in my previous position with a public agency that required such review, it would be sent back to the consultant with no payment as the work was not completed per requirements of the contract.” 

There are some apparent gaps in congruity within the Jacobs reports that could leave something to the imagination.  However, to conclude that those gaps result from PSAC giving direction is perhaps the wildest of leaps.  To come to that conclusion, one must disregard that in five years, Board seats have changed, Executive Directors/CEOs have changed, and three Directors of Public Works have transitioned.  Different ideas have been explored (for which there are studies and documentation from Jacobs).  Some ideas have been abandoned (for valid reasons), and new opportunities have been researched.  Exploring new/different ideas didn’t occur over months or years.  It has taken at least five years to get where we are.  While the reports may not close the gaps and document the decisions and reasons that brought a change in direction, the assertion that resident volunteers somehow “seized the reigns” or “hijacked” the process requires dismissing several other valid possibilities. There’s no problem with disagreeing.  Expressing disagreement with conspiracy theories and disregarding the efforts of experienced, qualified professionals who happen to be resident volunteers is reckless and irresponsible. Most importantly, as Director of Public Works, I have never witnessed a member of PSAC instruct Jacobs to do or not do anything.  If I witnessed it, I would put a stop to it.  

I do believe PSAC members understand their role very clearly.  I have never witnessed any review of Jacob’s work with a “consultant mindset.”  To the contrary, PSAC members challenge Jacobs.  As Director of Public Works, I’m confident I understand my role very clearly.  I have fired consultants and withheld payment numerous times.  My sole interest is that of Tellico Village.   

From my perspective, it is apparent that a great deal of time and effort has been invested in reviewing the available information on the TVPOA website.  I don’t think these perspectives lack an unwillingness to read and investigate.  However, the assertions made do lack for not having asked questions (of PSAC and TVPOA staff) to confirm or deny preconceived notions.   

Is LUB compliant with their contractual requirements to supply water to the main portion of Tellico Village?

Yes.  Perhaps the most pivotal element of the contract is included in Section 5 from the TVPOA/LUB contract:  

  

That section precludes two things.  First and foremost, the main portion of Tellico Village has a daily maximum of 3.2 million gallons.  However, the hourly flows (almost 4.6 million gallons daily) address the peaking demands.  So, for interval periods in every 24 hours, we can draw at a rate of nearly 4.6 million gallons.  However, the daily limit is still 3.2 million gallons from LUB.  In addition to the LUB supply, TASS can supply approximately 500,000 gallons of water to the main Village, bringing the total daily availability to 3.7 million gallons.   

To be clear, there is no evidence that LUB is not meeting its contractual obligations.  On a heavy irrigation day, the main Village uses between 2.2 million and 2.5 million gallons daily.   

The question that seems to be brought up is, why is there a need for an elevated water storage tank if we are not using what is available?  The simple answer addresses the peaking factor resulting from irrigation demand.  It is widely understood that water usage isn’t linear.  If one were to attempt to ration our water supply, we would have just over 154,000 gallons per hour to use in a 24-hour period.  But, there are peaks that need to be supplied with water.  So, to address the peaking demand, consider the model below that attempts to realistically distribute water usage over 24 hours based on a significant irrigation load: 

  • Between 12 a.m. and 4 a.m., we use 2% of daily total water use.
  • Between 4 a.m. and 11 a.m., we use 68% of daily total water use.
  • Between 11 a.m. and 7 p.m., we use 20% of daily total water use.
  • Between 7 p.m. and 12 a.m., we use 10% of daily total water use

The model above equates with Public Works staff’s operational experience wherein we can see how much the level in the existing 500,000 gallon ground storage tank drops between 4 a.m. and 11 a.m.  It may not be a perfect model, but it is verifiable.  Now, let’s apply that theoretical distribution of consumption to a known heavy consumption day:  June 25, 2024 (2,293,532 gallons consumed combined from LUB and TASS in 24 hours, our 2nd highest day of consumption in the month). 

Supplying the demand between 5 a.m. and 11 a.m. requires storage because it exceeds an hourly availability of the 3.2 million gallon daily total.  Absent storage, pressure will begin to suffer significantly at higher elevations.   

Now, let’s apply that same distribution model with the addition of 750 more homes in the main Village with a daily irrigation demand of 750 gallons per day (a typical irrigation cycle results in 1,920 gallons divided by 3 for the number of days irrigating).  The peak demand then grows from 2,293,532 gallons to 2,856,032 gallons per day.   

Again, supplying the demand between 5 a.m. and 11 a.m. requires storage at an estimated amount in excess of 860,000.   

So, to conclude, the 2020 LUB contract likely secured a source and quantity of water through buildout.  That is a comfortable conclusion.  However, the requirement to store water to meet peak demand was not addressed with the 2020 LUB contract.

Are the unimproved lots in Tellico Village being assessed the $80 per month water and sewer infrastructure fee.

No, only utility users will be responsible for paying the $80 water and sewer infrastructure fee. Lot owners will be required to pay this fee when they obtain a permit to build a house. The fee will be applied retroactively, so if a lot owner obtains a permit two years from now, they will owe 24 months’ worth of fees at $80 per month, totaling $1,920 for the water and sewer infrastructure.

Our sewer and water systems should be managed on a risk basis. What are the risks and what plans are in place to mitigate those risks?

The videos produced by Public Works and available at TAP—Video Library—Tellico Village Property Owners Association (tellicovillagepoa.org) clearly outline the risks and alternatives that have been identified and studied, as well as the solutions to be delivered with the proposed projects. If you have not already watched those videos, I suspect the answers to your questions are included within.

There needs to be a communications plan, including an emergency response system that ensures all residents are contacted in the case of an emergency.

TVPOA Public Works staff responds to emergencies (water and sewer line breaks and pumping station outages) on a routine basis. Residents affected by the emergency are typically notified in person and with door hangers. For wider-scale emergencies, Public Works staff communicates with Beth Kuberka’s Communications team, which employs wider-scale communication strategies.

An emergency response plan to address known risks and a casualty control plan for possible casualties need to be developed. The needed equipment needs to be procured and prepositioned, and responders need to be trained.

TVPOA Public Works staff is well-trained with experienced operators.  The Supervisor and his assistant carry the highest water and wastewater certifications available for the water distribution and wastewater collection systems operated by Tellico Village.  The heavy equipment and operators are contracted with Tellico Dirt Works. 

We need an I&I condition-based maintenance program that methodically works to identify and resolve all I&I issues. All residents should receive regular progress reports.

A proposed plan and alternatives have been prepared for the CEO and Board of Directors.  It is under consideration. 

The freshwater system needs to be able to measure pressure in all neighborhoods. Currently, it can only measure pressure at the main tank, which prevents any diagnostic of individual neighborhood concerns or resolution of those issues.

The proposed Elevated Water Storage Tank project includes these improvements. However, with increased demand, pressure isn’t static. In any case, Public Works staff can assess where pressure is likely suffering based on ground storage tank water levels. 

The fire hydrants need to be added and extended to ensure that all homes are within range of the pumper truck. A map with the location of every fire hydrant and the water pressure at the last test needs to be published. Per state requirements, as the “Water Department,” the POA should be testing and reporting results to the applicable Fire Departments. The POA should request that the Tellico Village Volunteer Fire Department evaluate the adequacy and risks of Tellico Village’s water supply system to fight fires.

Tellico Village complies with the standard in place when fire hydrants were installed (which is 1,000’ radius).  Public Works maintains an inventory of hydrant locations, testing, and pressures.  It would not be an industry practice to publish such information.  State law does not allow the installation of fire hydrants on anything less than a 6” waterline.  Presently, areas that would be candidates for hydrant installation are on waterlines less than 6”.  Tellico Village, Public Works staff, stays in regular communication with the Volunteer Fire Department, and they have access to the same inventory of hydrants and pressure. 

Where possible, water line dead ends need to be eliminated. Those that cannot be eliminated should be identified. Routine testing and flushing need to be part of a planned maintenance program, and the results must be regularly published to the community.

Ideally, dead ends should be eliminated to ensure chlorine residuals.  However, every water system has them.  Waterline installation is estimated at approximately $150 to $300/linear foot and is generally not cost-effective unless achieved with new customers.  That’s why testing and flushing is the typical practice.  Tellico Village Public Works ensures testing to TDEC and flushing maintenance practices.

Regarding the main sewer line to Loudon: a) LUB needs to be engaged to reopen the contract and resolve the capacity limit they currently enforce on us. At the same time, we need to ensure we have sufficient pumping capacity on the village end to take advantage of any additional capacity that LUB allows.

My advice on that topic would be “be careful what you wish for.” Assuming LUB could be convinced to undertake a wastewater capacity improvement program (while also engaged in a $80 million water treatment project), expect those improvements to alleviate their capacity to be proportionately passed on to Tellico Village through higher wholesale distribution rates. 

Regarding the main sewer line to Loudon: Ensure that the main sewer line can handle additional loads (e.g., are we doing any testing to ensure minimal line breakage?).

The line is pressurized. Cameras and “pigging” (typical assessment techniques) cannot be used.

While the TAP program addressed several specific issues, it did not address the existing piping within the village. What is the plan for maintaining/replacing the piping? What is the plan to evaluate the condition and risk of failure of these assets?

Tellico Village has no water distribution or sewer collection line capacity issues.  Most of the water distribution and wastewater collection systems use PVC pipes.  It can last 100 years.  Most water and wastewater leaks in Tellico Village result from substandard installation, not pipe deterioration. 

What is the policy regarding new commercial builds? The CCI land purchase resulted in several large plots of land that are now being marketed. If someone wanted to build on one of these parcels, would it automatically grant them access to our sewer/water systems?

No.

The Reserve Study identified that 2/3 of POA assets are dedicated to water/sewer, so why are we not using 2/3 of the available reserve funding (a total of nearly $20m) for TAP projects?

At the same link provided above, go to the video of the June 25, 2024, Town Hall meeting.  At about the 36:41-minute mark, slides 11 and 12 answer this question. 

Encourage homeowners to understand their impact on the I&I problem by installing a usage meter on their wastewater controller and measuring their usage over time.

It has shortcomings (particularly during wet weather events when the pump may be operating, but the wastewater may not be leaving the tank). 

Develop an incentive plan to reduce water used for irrigation, such as providing homeowners with clear guidelines for installing a separate, optional irrigation water meter. Offer reduced water rates to enable payback if the homeowner agrees to not water between 5 am and 8 am on any day. If the new WIFI meters allow it, establish controls to prevent usage during peak hours.

Tellico Village water meters are not capable of inhibiting or throttling consumption.  Public Works cost of installing a separate irrigation meter is approximately $1,000.  The resident would then have to pay to have their irrigation system and backflow preventer attached to the new irrigation meter (unknown cost).  Also, go to https://www.tellicovillagepoa.org/tap/ and review question #1, “Why are irrigation restrictions not put in place to reduce the peak hourly summer demand?” for an explanation of the difficulties associated with irrigation restrictions. 

What happens if I don't pay the $80 Water & Sewer Asset Fee?

The $80 Water & Sewer Asset Fee is part of your water and sewer utility bill. If it is not paid by the due date, as per our policy, your water service runs the risk of being shut off and a $75 reconnection fee will be required. This notice is on every water & sewer bill. You can view a sample here. 

Can the $ 80 Water and Sewer Asset Fee be prorated by the POA at home closings?

No. The $80 TAP fee is a fixed monthly charge included in the utility bill and billed based on the property’s billing cycle. The POA cannot prorate this fee in the event of a home sale during the billing cycle. Any proration of the TAP fee must be arranged between the buyer and seller as part of the sales agreement and addressed at closing.

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