Resolución 0024 — Reform of Information Requirements on Quality for Services Regulated by the Water Superintendency

in the entirety of the text - Full Text of Norm 0024 Reform of Information Requirements Regarding Quality for the Services Regulated by the Water Superintendency WATER SUPERINTENDENCY RE-0024-IA-2021 of October 18, 2021 REQUEST FOR ADDITION AND CLARIFICATION, APPEAL FOR REVOCATION WITH SUBSIDIARY APPEAL AGAINST RESOLUTION RE-0018-IA-2021 OF AUGUST 30, 2021, FILED BY THE INSTITUTO COSTARRICENSE DE ACUEDUCTOS Y ALCANTARILLADOS (AYA).

I.On August 30, 2021, the Water Superintendency issued resolution RE-0018-IA-2021 regarding "Information Requirements Regarding Quality for the Services Regulated by the Water Superintendency." (Folios 63 through 72 and 74 through 83).

1. On August 30, 2021, the Instituto Costarricense de Acueductos y Alcantarillados (AyA) was notified of resolution RE-0018-IA-2021, published in Supplement 173 to Gazette 169, of September 2, 2021. (Folio 89).

II.On September 2, 2021, via official letter GG-2021-03238, Ms. Vanessa Castro López, identity card number one-zero seven hundred twenty-one-zero eight hundred forty-nine, in her capacity as Deputy General Manager with powers of an unlimited general attorney-in-fact of AyA, filed a request for addition and clarification and an appeal for revocation with a subsidiary appeal against resolution RE-0018-IA-2021. (Integrated Document System 010983-2021, folio 98).

III.On October 18, 2021, via official letter OF-0626-IA-2021, the Water Superintendency issued its opinion on the challenge filed by AyA. (incorporated into the record).

I.From official letter OF-0626-IA-2021 of October 18, 2021, which serves as the basis for this resolution, it is pertinent to extract the following:

Regarding the request for clarification and addition, this constitutes a figure of ordinary procedural law, which is not expressly regulated in the LGAP.

Pursuant to article 229 of the LGAP, the rules of the Civil Procedure Code (CPC) are applied supplementarily, in which it is indicated that such a motion applies only against the operative part of judgments, for the exclusive purpose of clarifying any obscure or contradictory pronouncement or supplementing any omission on some point discussed, without the possibility of varying, revoking, or in any way modifying what was ordered or decided (article 63 of the CPC).

In other words, by means of clarification and addition, an administrative act is integrated, complemented, determined, and specified, without the possibility of varying, revoking, or in any way modifying what was decided by the Administration. Clarification and addition are not, therefore, a procedural instrument for revocation or substitution of an administrative decision, but rather precisely, a remedy to enforce what has been ordered, authorized, or permitted (the will of the body or entity).

On September 2, 2021, the representative of AyA filed the aforementioned challenge, (Integrated Document System 010983-2021, folio 98), therefore, the appeal filed is within the legal deadline established for this purpose.

Regarding the request for addition and clarification, pursuant to article 229 of the General Public Administration Law, a supplementary and exceptional recourse is made to article 63 of the Civil Procedure Code, which contains a deadline of three days from the notification of the judgment for the party to request a "clarification and addition" thereof; therefore, the request is within the legal deadline stipulated for its filing.

IV. ANALYSIS ON THE MERITS

I. Arguments of a legal nature

Regarding what has been stated, it is necessary to clarify that public hearings, as a mechanism of citizen participation that represents the space for exercising the constitutional right established in article 9 of the Political Constitution, are an essential part of the processing of various procedures carried out at ARESEP.

In this regard, Law N°7593 and its regulations have established a special procedure for making various decisions, where the holding of the public hearing has the special characteristic of providing transparency to those decisions and providing the space for participation that corresponds to interested parties.

Thus, article 36 of the aforementioned Law exhaustively lists the matters that must be submitted to a public hearing, as follows:

Having explained the above, it is worth adding that the Water Superintendency has provided the pertinent means and facilities for providers to participate and comment on the regulatory measures issued in resolution RE-00018-IA-2021, if they consider they are affected by them. For this reason, said resolution was duly justified, published, and notified through the means indicated by the operators, facilitating their digital access to the case file. It is not considered that there has been any obstacle to the effective enjoyment and exercise of their rights, giving the best attention to the arguments contained in their challenge, as is indeed being done in this written response to their request for addition, clarification, and appeal for revocation with a subsidiary appeal against resolution RE-00018-IA-2021. Reason for which the appellant's argument is unfounded and is rejected.

Law N°7593, in articles 14, subsections a) and c), and 24, provides, respectively:

From the above derives the legal basis for the Water Superintendency to require from providers of public services in the water sector, regulatory information requirements regarding quality and within the deadlines established in the appealed resolution. It is the provider's responsibility to submit the justifications demonstrating the convenience of longer deadlines for their technical evaluation, which will be assessed in the technical opinion that follows. Reason for which the appellant's argument is unfounded and is rejected.

Regarding the articles mentioned by the appellant, the Technical Regulation: Provision of Aqueduct, Sanitary Sewerage, and Hydrant Services issued by the Regulatory Authority, establishes:

a. Determine if the services are operated and maintained in accordance with the provisions of this Regulation and other current technical standards, b. Verify that management is carried out efficiently, c. The processing of complaints and reports, d. The resolution of rate proceedings, and e. Any other function established by Law (...)."

a. Updated records of service levels, b. Copies of laboratory analyses on the quality of the water provided, c. Maps showing the main elements of the systems they operate, d. Records of the systems they operate, detailing costs and installation dates, e. An updated cadastre of connections, geographically and in a database that includes, among others, all the data necessary to locate the property benefited by the service provisions, identify the subscriber, characterize the type of service, and carry out billing and collection tasks, f. An updated census of the populations occupying precarious lands and the condition in which they find themselves regarding the use of the services, g. A water resource protection program to guarantee the sustainability of the Water Resource, h. Annual maintenance programs for their systems, i. Records of the complaints and reports they receive, as well as the respective information on the processing, investigation, actions taken in this regard, and their results, j. Results of surveys on the perception of the quality of services, k. A detailed record of all sources of water resources used to provide aqueduct service, l. The plans and programs specified in this regulation: infrastructure maintenance plan, water meter maintenance plan, hydrant control plan, environmental management plan, water quality control plan, m. Infrastructure maintenance plan, n. Annual corrective and preventive maintenance plan for water meters in accordance with the Water Meter Technical Standard AR-HSA-2008 or the one in force at the time, and o. An updated cadastre of water meters, as specified in the Water Meter Technical Standard AR-HSA-2008 in force at the time (...)."

It is worth clarifying to the appellant that the articles 16, 17, and 18 transcribed do not indicate that the presentation of the information is annual. On the other hand, regarding the annual programs and plans indicated in article 17, subsections h) and n), this refers to the fact that they must be projected over a one-year term and not that their presentation is annual, since control over the progress of their execution can be verified with a periodicity of less than one year.

It is important, regarding this issue, to indicate that the cited regulation was issued by the Regulatory Authority by virtue of the competence that Law N°7593 grants it in its article 25, to issue and publish technical regulations specifying the conditions of quality, quantity, reliability, continuity, timeliness, and optimal provision with which public services must be provided.

Note that the regulation itself is clear in indicating that the information requested exhaustively deals with the minimum information that must be maintained in the systems; therefore, providers are subject to the regulatory body requesting them to provide more complete, reliable, updated, and accurate regulatory information about public services.

The legal basis for requesting the information requirements, as was clearly set forth in the appealed resolution, RE-0018-IA-2021, is found in Law N°7593 itself. In this regard, article 6, subsection a) of the cited regulatory body establishes the obligation of ARESEP to regulate and oversee accounting, financial, and technically the providers of public services to verify the correct management of the factors affecting the cost of the service. Likewise, and as provided by article 14, subsections a) and c), it is the obligation of providers to comply with the provisions issued by ARESEP regarding service provision, in accordance with the provisions of the respective laws and regulations, and to timely provide the Regulatory Body with the information it requests related to service provision. Furthermore, article 24 expressly establishes that they must provide reports, data, file copies, and any other electronic or written means where financial, accounting, economic, statistical, and technical information related to the provision of the public service they provide is stored.

Due to the above, the appellant's request for revocation concerning this point is rejected.

To exercise these regulatory powers, it is necessary for the Water Superintendency to have accurate and updated information regarding quality related to the provision of public services in the water sector, allowing for its agile and timely monitoring and analysis; this is why administrative measures such as the resolution being appealed are issued, to have the necessary information within the established deadlines and timeframes; all of this, acting within the framework of the principle of legality.

From article 33 of Law N°7593, it follows that every tariff petition must be justified; in addition, applicants must have complied with the conditions established by ARESEP in previous settings or interventions carried out in the exercise of its powers. Therefore, providers must comply with the information requested in resolution RE-00018-IA-2021, so that the Regulatory Authority has reliable, trustworthy, and consistent information that allows for the correct application of the tariff-setting methodologies issued by the Board of Directors, as well as to effectively exercise the regulation of regulated services, for the benefit of the interests of users and providers.

II. Arguments of a technical nature

I. Regarding ANNEX 1-PRODUCT QUALITY INFORMATION CAC-001 Aqueduct Operational Control

Regarding the data entry form CAC-001 Aqueduct Operational Control, only information is requested on the operational control parameters of the aqueduct systems that the operator must record in the semi-annual quality reports, as indicated in Decree 38924-S in article 11 and its annex 3 and its amendment in Decree 41499-S. The data entry form does not, in any instance, state information about the sewerage system that would lead to ambiguity in what is requested with respect to the sewerage service.

II. Regarding ANNEX 1-PRODUCT QUALITY INFORMATION CAC-003-Disinfection

For those aqueduct systems that use more than one type of disinfection, in the instructions of the data entry form, column "TIPO DE DESINFECCIÓN" (TYPE OF DISINFECTION), it is clearly indicated that all types of disinfection in the aqueduct system must be stated, all in the cell being filled in for the type of disinfection of the corresponding system. It is clarified that the separation between one type of disinfection and another when there are several types of disinfection can be done using a comma.

III. Regarding ANNEX 1-PRODUCT QUALITY INFORMATION CAL-001-Sewerage Operational Control

Regarding the data entry form CAL-001 Sewerage Operational Control, this only requests information on the parameters of measurements by the generating entity in wastewater treatment systems that form part of the sewerage systems, as indicated in Decree 33601-MINAE-S.

The data entry form does not, in any instance, state information about the aqueduct system that would lead to ambiguity of what is requested.

It is important to mention that the data entry form has a column called "OBSERVACIONES" (OBSERVATIONS), in which they can add or expand upon any detail that AyA considers important about the information it is presenting.

IV. Regarding ANNEX 1-PRODUCT QUALITY INFORMATION CAP-001-General Treatment Plants

Regarding the data entry form CAP-001-General Treatment Plants, the information required corresponds to both Wastewater Treatment Plants and Potable Water Treatment Plants, since part of the information is similar in both types of treatment systems.

Furthermore, for those information fields that are specific to Wastewater Treatment Plants or Potable Water Treatment Plants, the instructions for the templates clearly stipulate to which type of treatment (wastewater or potable water) the information that the operator must state corresponds.

By way of example, it is indicated that, in the case of information referring to treated flow rate, frequency of sludge extraction, sludge disposal, and sludge manager, requested in the data entry form CAP-001, this is general information that both Potable Water and Wastewater Treatment Plants share.

V. Regarding ANNEX 2 - SERVICE QUALITY INFORMATION -CAS-008- Special Cases

Both article 95 and article 97 of the ARESEP Service Provision Regulation ARPSAYA-2015 apply only to the aqueduct service, and not to the sewerage service.

In the CAS-008-Special Cases form, the sewerage service was included, but it is clarified that the information required is only for the aqueduct service; therefore, the form in question is updated so that in the tab called "SERVICIO" (SERVICE), only "Acueducto" (Aqueduct) is stated.

VI. Regarding ANNEX 2 - SERVICE QUALITY INFORMATION - CAS- 009-Availabilities

In the data entry form CAS-009, the concepts of "Disponibilidades Nuevas" (New Availabilities) and "Disponibilidades Denegadas" (Denied Availabilities) refer to new and denied availabilities as a boolean. Therefore, so that this does not lead to confusion, it is clarified in this data entry form that the type of data to be entered corresponds to an integer instead of a boolean and that the corresponding definitions are as follows:

. New availabilities: number of service availabilities granted in the indicated period, in the respective system.

. Denied availabilities: number of service availabilities denied in the indicated period, in the respective system.

I. Regarding ANNEX 1-PRODUCT QUALITY INFORMATION CAP-001-General Treatment Plants

Regarding the proportionality of the deadlines within which the information from the data entry forms CAP-001-Treatment Plants must be submitted, it is the operator's duty to have the information updated and duly recorded in an information system in order to comply with the information requirements requested in a timely and proper manner by the regulatory body or another interested party.

Most of the information requested varies little over time; therefore, once it has been tabulated, what corresponds in subsequent submissions is the updating of the cells that have changed.

Thus, the deadlines granted for the presentation of the information do not represent any impediment for AyA to have, by the indicated dates, the information requested for this data entry form.

II. Regarding ANNEX 1-PRODUCT QUALITY INFORMATION CAP-002-Specific Treatment Plants

Regarding the proportionality of the deadlines within which the information from the data entry forms CAP-002-Specific Treatment Plants must be submitted, it is the operator's duty to have the information updated and duly recorded in an information system in order to comply with the information requirements requested in a timely and proper manner by the regulatory body or another interested party.

Most of the information requested varies little over time; therefore, once it has been tabulated, what corresponds in subsequent submissions is the updating of the cells that have changed.

Thus, the deadlines granted for the presentation of the information do not represent any impediment for AyA to have, by the indicated dates, the information requested for this data entry form.

III.Regarding ANNEX 1-PRODUCT QUALITY INFORMATION-D. Information required for potable water and wastewater treatment systems -CAP-001-General Treatment Plants:

In case any sanitary permit is pending processing or is in the process of renewal before the Ministry of Health, AyA must indicate the justification for the case in the observations field provided by the template. Said observations box was placed among the data entry forms anticipating the need for any clarification by the provider regarding the information they stated in the form.

The deadlines for approval, renewal, or processing by the Ministry of Health regarding operating permits are the exclusive competence of said public entity, and ARESEP therefore does not have the authority to expedite those procedures; however, those deadlines do not represent any impediment for AyA to present the information requested in the data entry form CAP-001-General Treatment Plants and, in the event that the sanitary permit is in the process of approval or renewal, to indicate the clarification in the corresponding observations box.

IV. Regarding ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-001 - Times and Related Services

The sectorization of systems, both hydraulically and commercially, allows for the management of technical and commercial losses; thus optimizing service conditions. In this context, it allows for optimization from operation to reading routes. This is something that AyA should have carried out some time ago to operate the systems under its responsibility.

AyA's situation in relation to information systems has been managed by this Regulatory Authority since 2016 through resolutions, official letters, and transitional provisions of the current Service Provision Regulation AR-PSAYA-2015, with the deadline having been extended on repeated occasions for both the SIG-COA, which is part of the RANC project, and for the Technological Platform Modernization Project. In relation to the latter, in official letter 704-RG-2016 of August 24, 2016, the Regulatory Authority formalized the pressing need for AyA to "(...) execute in the shortest possible time the update in hardware and software of the indicated computer systems." On April 24, 2019, through resolution RE-0001-IA-2019, the Water Superintendency established in the Therefore II:

"Indicate to AyA that it must finalize the implementation of the new information processing system no later than December 31, 2021, and present semi-annual reports on the progress of this technological project in the months of January and July of each year." After the publication of the resolution, official letter GG-2019-02690 was received, in which only the date of the preliminary hearing for the Technological Platform Modernization Project was indicated, in which it was expected that a detailed schedule, completion dates, justifications, and other relevant aspects would be included to establish the current situation and progress of the project.

On August 21, 2019, the Regulatory Authority responded to AyA through official letter OF-0651-IA-2019, stating that the information provided in official letter GG-2019-02690 did not meet expectations, and therefore, it was not accepted as real progress on the project.

On October 3, 2019, through official letter GG-2019-03428, AyA submitted official letter N°GG-DSI-2019-00781, which shows the progress of the Technological Platform Modernization Project as part of compliance with the resolution (RE-0001-IA-2019) and with official letter OF-0651-IA-2019. Said document details the activities carried out, relevant aspects, next steps, and attaches the schedule with the deadlines executed and to be executed.

On January 30, 2020, AyA, via official communication GG-2020-0276, sent to the Regulatory Authority "the progress report for the Modernization Project during the last semester of 2018 and the schedule updated to January 31, 2020." On March 9, 2020, the Regulatory Authority sent official communication OF-0175-IA-2020 to AyA, in which it requests a report clearly indicating the current status of the project for the change in the technological platform and whether this project considers or not the issue of computer systems for ASADAS. Said requested report is in line with what is established in resolution RE-0001-IA-2019.

AyA, in its official communication PRE-2020-00346 of March 17, 2020, mentions that the report was already sent on January 30, 2020, and also responds that the scope of the project does not consider computer systems for the ASADAS.

On August 5, 2020, AyA issued the Project Progress Report for the first semester of the year 2020.

On August 20, 2020, the Regulatory Authority, via official communication OF-690-IA-2020, calls AyA's attention to the delays experienced in the schedules that have been submitted since 2019, for which "project execution is expected to begin in October 2021 once the contracting stage is completed, so that if there are no delays, the first phase would conclude in December 2023, to immediately begin the second phase, projected to conclude in October 2027." On July 5, 2021, the Regulatory Authority informed AyA via official communication OF-0395-IA-2021 that, to date, the semi-annual progress report for the technological platform modernization project established in the Por Tanto II of Resolution RE-0001-IA-2019 has not been received.

On August 18, 2021, AyA sent document GG-DSI-2021-00603, which contains the semi-annual report for the technological platform modernization project.

Through Resolution GG-2021-0236, AyA cancels the tender process for Public Tender (Licitación Pública) N°2020LN-000005-0021400001, called "Technology platform modernization services for AyA's business processes." According to the operator's argument, following Decreto Ejecutivo N°42560-H: "(.) The Administration, in a responsible manner and in the interest of the public good, resolves to postpone this Tender, since said renegotiations could impact the current tender by affecting the costs of some of the 11 components of the tender in question or incorporating new components, therefore, in addition to considering the economic effects of the crisis facing the country due to the COVID-19 emergency situation (.)." Therefore, this Regulatory Entity considers that this issue has been recurrent, and it is also observed that in accordance with resolution RE-0001-IA-2019, the Intendencia de Agua establishes in its Por Tanto II that AyA must have implemented the "new information processing system, no later than December 31, 2021, in order to ensure the correct and efficient management of the information necessary both for operational purposes and for transparency in its management." The Regulatory Authority considers that the requested information is not new; furthermore, the information management by the provider must be efficient, especially information of great relevance for operational purposes, such as that requested by data entry form CAS-001 - Times and Related Services. Therefore, AyA must have this information to comply with what is requested in RE-0018-IA-2021.

V. ANEXO 2 - SERVICE QUALITY INFORMATION - CAS-0012 - Interruptions

On this point, AyA refers to CAS-0012, the correct reference being CAS-002, as CAS-0012 does not exist.

It is clarified that AyA currently does disaggregate the information corresponding to the indicators of discontinuity in the sewerage service; namely: Density of blockages (taponamientos), overflows, and the number of breakdowns that arise from failures and breaks in the connections and in the system network. Reference is made to the reports annually sent by the GAM Subgerencia of Dirección RyT and the regional directorates through the Benchmarking and DIAA matrices, classifying service interruptions as broken down by the tab called "CAUSA" in data entry form CAS-002. Points 8 through 17 of said tab are associated with the sewerage service and with what is established in articles 34 through 41 of standard AR-PSAYA-2015.

Thus, the deadlines granted for the presentation of the information do not represent any impediment for AyA to have, by the indicated dates, the information requested for this data entry form.

Regarding the recording of information, AyA's situation in relation to information systems has been addressed by this Regulatory Authority since 2016 through resolutions, official communications, and transitional provisions of the current Reglamento de Prestación de Servicios AR-PSAYA-2015, with the deadline for the Technology Platform Modernization Project having been extended on repeated occasions. In relation to the latter, in official communication 704-RG-2016 of August 24, 2016, the Regulatory Authority formalized the urgent need for AyA to "execute, in the shortest time possible, the hardware and software update of the indicated computer systems." On April 24, 2019, through resolution RE-0001-IA-2019, the Intendencia de Agua established in Por Tanto II:

"(.) Instruct AyA that it must complete the implementation of the new information processing system, no later than December 31, 2021, and present semi-annual reports on the progress of this technological project in the months of January and July of each year (.)." After the publication of the resolution, official communication GG-2019-02690 is received, which only indicates the date of the preliminary hearing for the Technology Platform Modernization Project, in which it was expected that a detailed schedule, completion dates, justifications, and other relevant aspects would be included to establish the current status and progress of the project.

On August 21, 2019, the Regulatory Authority responded to AyA via official communication OF-0651-IA-2019, that the information submitted in official communication GG-2019-02690 does not meet expectations, and is therefore not accepted as real project progress.

On October 3, 2019, via official communication GG-2019-03428, AyA sent official communication N°GG-DSI-2019-00781, which shows the progress of the Technology Platform Modernization Project as part of compliance with the resolution (RE-0001-IA-2019) and official communication OF-0651-IA-2019. This document details the activities carried out, relevant aspects, steps to follow, and attaches the schedule with the deadlines executed and to be executed.

On August 5, 2020, AyA issued the Project Progress Report for the first semester of the year 2020.

On August 18, 2021, AyA sent document GG-DSI-2021-00603, which contains the semi-annual report for the technological platform modernization project.

"(.) The Administration, in a responsible manner and in the interest of the public good, resolves to postpone this Tender, since said renegotiations could impact the current tender by affecting the costs of some of the 11 components of the tender in question or incorporating new components, therefore, in addition to considering the economic effects of the crisis facing the country due to the COVID-19 emergency situation (.)." Therefore, this Regulatory Entity considers that this issue has been recurrent, and it is also observed that in accordance with resolution RE-0001-IA-2019, the Intendencia de Agua establishes in its Por Tanto II that AyA must have implemented the "new information processing system, no later than December 31, 2021, in order to ensure the correct and efficient management of the information necessary both for operational purposes and for transparency in its management." The Regulatory Authority considers that the requested information is not new; furthermore, the information management by the provider must be efficient, especially information of great relevance for operational purposes, such as is the case of interruptions in the service. Therefore, AyA must have this information to comply with what is requested in RE-0018-IA-2021.

VI. Regarding ANEXO 2 - SERVICE QUALITY INFORMATION - CAS-003- Pipe replacement plan

The Regulatory Authority grants resources via tariffs through depreciation expense for asset replacement, and the condition of pipes is no exception. The use of these resources must be made transparent within the replacement investment plans and defined for what they were used.

Thus, it is not considered that there is any impediment to the presentation of said information by AyA.

VII. Regarding ANEXO 2 - SERVICE QUALITY INFORMATION - CAS-004 - Hydrometer maintenance

The Regulatory Authority grants resources via tariffs through depreciation expense for asset replacement, and meter maintenance is no exception. The use of these resources must be made transparent within the replacement investment plans and defined for what they were used.

AyA's situation in relation to information systems has been addressed by this Regulatory Authority since 2016 through resolutions, official communications, and transitional provisions of the current Reglamento de Prestación de Servicios AR-PSAYA-2015, with the deadline having been extended on repeated occasions both for the SIG-COA, which is part of the RANC project, and for the Technology Platform Modernization Project. In relation to the latter, in official communication 704-RG-2016 of August 24, 2016, the Regulatory Authority formalized the urgent need for AyA to "execute, in the shortest time possible, the hardware and software update of the indicated computer systems." On April 24, 2019, through resolution RE-0001-IA-2019, the Intendencia de Agua established in Por Tanto II:

On October 3, 2019, via official communication GG-2019-03428, AyA sent official communication N°GG-DSI-2019-00781, which shows the progress of the Technology Platform Modernization Project as part of compliance with the resolution (RE-0001-IA2019) and official communication OF-0651-IA-2019. This document details the activities carried out, relevant aspects, steps to follow, and attaches the schedule with the deadlines executed and to be executed.

AyA, in its official communication PRE-2020-00346 of March 17, 2020, mentions that the report was already sent on January 30, 2020, and also responds to the inquiry raised regarding the project's scope regarding the ASADAS, where it is mentioned that this scope is not contemplated in this project.

On August 5, 2020, AyA issued the Project Progress Report for the first semester of the year 2020.

On August 20, 2020, the Regulatory Authority, via official communication OF-690-IA-2020, calls AyA's attention to the delays experienced in the schedules that have been submitted since 2019, for which "(.) project execution is expected to begin in October 2021 once the contracting stage is completed, so that, if there are no delays, the first phase would conclude in December 2023, to immediately begin the second phase, projected to conclude in October 2027 (.)." On July 5, 2021, the Regulatory Authority informed AyA via official communication OF-0395-IA-2021 that, to date, the semi-annual progress report for the technological platform modernization project established in the Por Tanto II of Resolution RE-0001-IA-2019 has not been received.

On August 18, 2021, AyA sent document GG-DSI-2021-00603, which contains the semi-annual report for the technological platform modernization project.

"(.) The Administration, in a responsible manner and in the interest of the public good, resolves to postpone this Tender, since said renegotiations could impact the current tender by affecting the costs of some of the 11 components of the tender in question or incorporating new components, therefore, in addition to considering the economic effects of the crisis facing the country due to the COVID-19 emergency situation (.)." Therefore, this Regulatory Entity considers that this issue has been recurrent, and it is also observed that in accordance with resolution RE-0001-IA-2019, the Intendencia de Agua establishes in its Por Tanto II that AyA must have implemented the "new information processing system, no later than December 31, 2021, in order to ensure the correct and efficient management of the information necessary both for operational purposes and for transparency in its management." The Regulatory Authority considers that the requested information is not new; furthermore, the information management by the provider must be efficient, especially information of great relevance for operational and billing purposes, such as is the case of hydrometer maintenance. Therefore, AyA must have this information to comply with what is requested in RE-0018-IA-2021.

VIII. Regarding ANEXO 2 - SERVICE QUALITY INFORMATION - CAS-005 - Hydrant Maintenance

The appellant indicates the following regarding the filed appeal: "(.) It is pertinent to verify the need to expand the type of maintenance performed on hydrants, as it should not focus solely on the asset replacement activity, but on another series of tasks that must be considered in the maintenance process itself, given that Form - CAS-005 Hydrant Maintenance develops two types of maintenance, specifically, preventive maintenance (mantenimiento preventivo) and corrective maintenance (mantenimiento correctivo). "Preventive maintenance," which is performed in order to extend the useful life of hydrants by ensuring good operational functioning for the use of the Benemérito Cuerpo de Bomberos, among the tasks broken down are: clearing vegetation that obstructs its physical location, cleaning the valve cover, cleaning the hydrant, greasing threads, painting the hydrant, checking and changing gaskets, changing hardware, constructing pedestals and concrete bases, raising the foot valve, measuring pressure and flow, among others. Meanwhile, "corrective maintenance" is broken down into the following tasks: Replacement of hydrants, leaks in the main pipe, leak in the foot valve, relocation of a hydrant to a new location, intervention due to a vehicle collision, rehabilitation of hydrants, among others (.)." According to what was stated by AyA, it is considered appropriate to expand the type of maintenance performed on hydrants, thereby partially upholding the appeal for revocation (recurso de revocatoria) filed by the Instituto Costarricense de Acueductos y Alcantarillados (AyA) against resolution RE-0018-IE-2021 of August 30, 2021, issued by the Intendencia de Agua, which refers to ANEXO 2 - SERVICE QUALITY INFORMATION - CAS-005, and the type of maintenance performed on hydrants is included in the relevant annex, segregated into two types of maintenance:

. Preventive maintenance . Corrective maintenance.

With reference to the changes of the name of column F to be called "Planned Hydrant Type" and column H to be called "Executed Hydrant Type," the Intendencia does not see the technical need to execute the suggested change, given that the current names in the data entry form are clearly understood, therefore the names currently found in the data entry form for columns F and H are maintained, corresponding to "PLANNED HYDRANT TYPE TO REPLACE" and "EXECUTED REPLACED HYDRANT TYPE" respectively.

IX. Regarding ANEXO 2 - SERVICE QUALITY INFORMATION - CAS-006

- Complaints:

The zoning (sectorización) of both hydraulic and commercial systems allows for the management of technical and commercial losses, thus optimizing service conditions. In this context, it allows for optimization from operations to meter reading routes. This is something the Institute should have done long ago to operate the systems under its charge.

Additionally, AyA's situation in relation to information systems has been addressed by this Regulatory Authority since 2016 through resolutions, official communications, and even transitional provisions of the current Reglamento de Prestación de Servicios AR-PSAYA-2015, with the deadline having been extended on repeated occasions both for the SIG-COA, which is part of the RANC project, and for the Technology Platform Modernization Project. In relation to the latter, in official communication 704-RG-2016 of August 24, 2016, the Regulatory Authority formalized the urgent need for the Instituto Costarricense de Acueductos y Alcantarillados (AyA) to "(.) execute, in the shortest time possible, the hardware and software update of the indicated computer systems." On April 24, 2019, through resolution RE-0001-IA-2019, the Intendencia de Agua established in Por Tanto II:

On August 5, 2020, AyA issued the Project Progress Report for the first semester of the year 2020.

On August 18, 2021, AyA sent document GG-DSI-2021-00603, which contains the semi-annual report for the technological platform modernization project.

"(.) The Administration, in a responsible manner and in the interest of the public good, resolves to postpone this Tender, since said renegotiations could impact the current tender by affecting the costs of some of the 11 components of the tender in question or incorporating new components, therefore, in addition to considering the economic effects of the crisis facing the country due to the COVID-19 emergency situation (.)." Therefore, this Regulatory Entity considers that this issue has been recurrent, and it is also observed that in accordance with resolution RE-0001-IA-2019, the Intendencia de Agua establishes in its Por Tanto II that AyA must have implemented the "new information processing system, no later than December 31, 2021, in order to ensure the correct and efficient management of the information necessary both for operational purposes and for transparency in its management." The Regulatory Authority considers that the requested information is not new; furthermore, the information management by the provider must be efficient, especially information of great relevance for operational and customer service purposes, such as is the case of the recording and control of complaints. Therefore, AyA must have this information to comply with what is requested in RE-0018-IA-2021.

X. Regarding ANEXO 2 - SERVICE QUALITY INFORMATION - CAS-010 - Infrastructure

Infrastructure not only visualizes its condition, but also its congruence with the tariff base in terms of assets (retirements, additions), which are made with different periodicities. The Property, Plant, and Equipment account can present movements every month. The Regulatory Authority requests quarterly information on these types of movements, but at the accounting level, a transfer, retirement, addition, or reclassification can occur at any time.

Additionally, infrastructure maintenance plans make the infrastructure very changeable from one semester to another.

The need for the Regulatory Authority to have, at a minimum, this information every 6 months is evident in order to obtain, in a timely manner, the variations that may occur at any time in the normal operation of any supply system, whether for maintenance reasons or due to the addition of new infrastructure to the system.

XI.Regarding ANEXO 2 -SERVICE QUALITY INFORMATION II. INFORMATION REQUIRED FOR PERIODIC MONITORING OF SERVICE QUALITY - B Information required for aqueduct and sewerage services. Point v. - Subsection 1) Update of the special-type wastewater discharge cadastre that enter its system:

It is clarified to AyA that the provisions requested have been contemplated and reiterated to that operator through the Reglamento de Prestación de Servicios ARPSAYA-2015, in articles 34 through 41, which was published on September 22, 2014, by resolution RJD-101-2014 in Digital Scope N° 150 to La Gaceta No. 186 of September 29, 2014; (Folios 495 to 580). Therefore, what is indicated in this point is not accepted.

It is important to mention that the information requested in this point is vital and necessary for the healthy operation of any sewerage system operated by a provider of this public service.

XII. With reference to the arguments regarding the information that AyA must present on the ASADAS

In Anexo 2- II.A.iii. (ANEXO 2-SERVICE QUALITY INFORMATION.

II.Information required for periodic monitoring of service quality) it reads that, "In the case of CAS-001 Times and related services, additionally, AyA must present the information corresponding to the ASADAS."

In this regard, it is clarified to AyA that what it must present for the ASADAS is CAS-002 Interruptions, instead of CAS-001 Times and related services, therefore the indication from annex 2-II.A.iii mentioned above is eliminated, and what is indicated in annex 2-II.B.iii is updated, so that it reads, "In the case of CAS-002 Interruptions and CAS-009 Availabilities, additionally, AyA must present the corresponding information for the ASADAS." In relation to the service quality information from data entry forms CAS-002 and CAS-009, given that the ASADAS are local entities that, by delegation from AyA, administer, operate, and provide maintenance and development to both aqueduct and sewerage systems; regarding the issue of service interruptions, the ASADAS have reported this information and informed AyA, and this is on record in OF-0217-IA-2021.

The ASADAS have the duty to provide information to anyone with a legitimate interest in accessing it. This may be an official from one of the institutions that must oversee the actions of the ASADAS or the persons benefited by the service they provide. The Sala Constitucional has expressed itself in this sense through Voto N° 16283-12, in which it grants an Amparo appeal, obligating an ASADA to provide information on the minutes and on the persons who gave sworn statements or appeared to request the service, to a private individual, highlighting in its Considerandos "the right of any private individual to access the public information held by the appellant association" (Voto N°16283-12).

Furthermore, AyA has the obligation to evaluate and oversee the ASADAS, as mentioned in Decreto 42582-S-MINAE "Reglamento de las Asociaciones Administradores de Sistemas de Acueductos y Alcantarillados Comunales," where Article 37, subsections e) and h), indicate the aforementioned obligations:

"(.) Evaluate: Carry out a systematic, comprehensive, and periodic evaluation of the functioning of the ASADAS, as a mechanism to establish their category, determine critical and improvable areas, and guide the training and technical assistance programs provided by the Institution.

Oversee: Carry out oversight processes in the face of irregularities reported or detected in the functioning of the ASADAS and through management evaluation (.)." In the case of the quality of the sewerage service proper, and specifically, those ASADAS that provide that service, the information supply applies to them only for the CAS-002: Interruptions and CAS 009: Availabilities data entry forms; it is clarified that AyA, regarding sewerage service interruptions, must supply the information corresponding to the service discontinuity indicators; namely: Density of blockages, overflows, and the number of breakdowns caused by faults and breaks in the connections and the system network. The foregoing, according to the classification of service interruptions as broken down in the tab called "CAUSA" of the CAS-002 data entry form (points 8 to 17 of said tab). Regarding the CAS-009 data entry form, AyA must supply information related to new availabilities associated with this service, in the event it is granting them, and in accordance with the sewerage coverage of each ASADA.

It is emphasized that the recording of information for the CAS-002 and CAS-009 data entry forms does not apply to all ASADAS in the national territory, but only to those where problems of service interruption and availability occur.

Regarding ANEXO 1-INFORMACIÓN DE CALIDAD DEL PRODUCTO, AyA is requested to submit the CAC-002-Drinking Water Analysis, CAC-003-Disinfection, CAP-001 General Treatment Plants, and CAP-002-Specific Treatment Plants data entry forms for the ASADAS.

Regarding the CAC-002 and CAC-003 data entry forms, the ASADAS' information must be submitted by AyA, since as the delegating entity for the aqueduct service, it must guarantee that the service provided by the ASADAS complies with quality regulations. Thus, in the case of CAC-002, this is done through the records held by the National Water Laboratory via surveillance, sanitary quality seal, specific programs, or direct contract with the provider; and in the case of CAC-003, concerning disinfection issues in the ASADAS, non-compliance with disinfection or other matters related to water quality can threaten the health of the population receiving water from a provider to which AyA delegated the aqueduct service.

Given this situation, it is important to highlight the obligations AyA has towards the ASADAS, as already indicated previously and stated in Decreto 42582-S-MINAE "Reglamento de las Asociaciones Administradores de Sistemas de Acueductos y Alcantarillados Comunales," in its Article 37, subsections e) and h).

Indeed, since November 27, 2008, through resolution RRG-9289-2008, the Regulatory Authority had required AyA, within a maximum period of eight years, to comply with and develop the following activities:

"(.) a) Implement disinfection in all aqueduct systems delegated for administration that do not have this system.

b)Achieve compliance with the Reglamento de Calidad de Agua Potable by the operators of the aqueducts delegated for administration.
c)Implement in the aqueducts delegated for administration, minimum dynamic service pressures of 98.1 KPa (10 meters of water column), available 85% of the time at ground level at the property line.
d)Establish an action plan for the operators of the aqueduct systems delegated for administration to implement universal measurement of service consumption (micro-metering).
e)Update the data, as required in the SICEO, for all rural aqueducts. Additionally, incorporate into said system, for each aqueduct delegated for administration, a detail of the projects under development, indicating: objectives, costs, financing, schedule, and the size of the population served. Furthermore, for projects built with community participation, indicate the amount of the community contribution.
f)For updating the data of the current tariff model, obtain updated information from the 118 aqueducts chosen as a statistical sample, on tariffs, market, fixed assets, service quality, type of supply: gravity, pumping, mixed, with purification system; watershed situation, operational and administrative organization, administrative and operation costs.
g)Present information on the operation and maintenance costs for all aqueducts delegated for administration with a purification system (purification plants).
h)Complete the chart of accounts for the aqueduct systems delegated for administration, submitted in a timely manner, with its respective descriptive manual, and begin the application stage.
i)Identify the aqueduct systems delegated for administration that have sewerage systems and wastewater treatment systems, and formalize the tariffs.
j)Present, within a maximum period of six months from the notification of this resolution, a tariff proposal for new services, connection, and reconnection (disconnection) for the aqueduct systems delegated for administration.
k)Present, within a maximum period of six months from the notification of this resolution, a proposal to define the so-called "Community Contribution" for the aqueduct systems delegated for administration.
l)Develop a diagnosis and a strategy to develop watershed protection or rehabilitation projects in each of the rural aqueducts, according to the prioritization of the systems carried out for this purpose.
m)For the 118 aqueducts defined as a statistical sample, identify the percentage of subscribers requiring some type of subsidy, in order to develop a subsidy policy proposal.
n)Define a format and the requirements that the operators of the aqueduct systems delegated for administration must request, to issue declarations of water availability and to authorize the installation of new services, connections, and reconnections.
o)For the operators of the aqueduct systems delegated for administration that have water availability problems, develop contingency plans to provide the service during those times (.)." Thus, in view of the evaluation and oversight that AyA must carry out, this entity should be clear about which aqueduct systems holding delegation agreements have a disinfection system and which do not, even more so when this is a matter involving a potential health impact and in which AyA must guarantee water quality as the delegating entity of the aqueduct service. Additionally, it must have the respective quality information in order to issue the necessary recommendations and advise the ASADAS in resolving any non-compliances detected in water quality matters.

On the other hand, it is noted that the information regarding the CAP-001 and CAP-002 data entry forms for the ASADAS is already being submitted by AyA, as requested in official letters OF-0200-IA-2021 and OF-0201-IA-2021.

Therefore, no impediment is observed to prevent AyA from keeping the record of the requested information in its databases and providing a copy of said information through the CAC-002, CAC-003, CAS-002, CAS-009, CAP-001, and CAP-002 data entry forms for the ASADAS.

XIII.Regarding the request for the presentation of quality results for AyA, ESPH, and ASADAS systems in its possession, also including those conducted through surveillance, sanitary quality seal, specific programs, or direct contract with the provider:

Regarding the presentation of water quality results in AyA's possession for different aqueduct service providers, such as the systems operated by AyA itself, ESPH, and ASADAS, as well as for surveillance programs, sanitary quality seal, specific programs, or direct contract with other providers.

It must be remembered that the Instituto Costarricense de Acueductos y Alcantarillados is a state entity and a public, autonomous institution, vested with the functions of governing body and operator of the public aqueduct and sewerage services in the Costa Rican state.

Furthermore, it is emphasized that as indicated in the first article of the Ley General de Salud, the health of the population is a public interest good, where the presence of chemical substances and biological and physical agents in water for human consumption can affect human health and the balance of ecosystems.

Considering also that, by protecting the water resource, which is a heritage and a public domain good of the State, health is protected, and it is a necessary element to achieve the country's sustainable development.

And that, from the regulatory standpoint exercised by ARESEP in public aqueduct and sewerage services, Article 5 of Ley 7593 indicates that compliance must be ensured with the norms of quality, quantity, reliability, continuity, timeliness, and optimal provision for the services in which AyA is the operator.

Therefore, to ensure the respective compliance with the quality norms for the aqueduct and sewerage services provided by AyA, specifically to verify compliance with the water quality norms and the measurement frequencies dictated by Decretos 38924-S "Reglamento para la Calidad del Agua Potable" and its amendment in Decreto 41499-S, and Decreto 33601-MINAE-S "Reglamento de Vertido y Reuso de Aguas Residuales," it is necessary to have the information regarding the water quality analyses in AyA's possession. Under the principle of inter-institutional coordination, AyA is requested to submit this information, as it is the primary source generating the quality information, coming from a technical entity with vast experience in water quality analysis, as is AyA through the National Water Laboratory, both for water for human consumption and for discharge water resulting from wastewater treatment.

Furthermore, given the importance for the population's health of the quality of the drinking water provided through the aqueduct service, and the environmental impact generated by the discharge from wastewater treatment from the sewerage service, it is pertinent for the regulatory body to have the water quality results carried out in each period as quickly as possible and efficiently, so that ARESEP also has the information as quickly as possible to be able to oversee compliance with quality norms. This is even more critical in cases where the population's health could be seriously affected by non-compliances in water quality, in addition to efficiently fulfilling the functions and powers indicated in Articles 5 and 6 of Ley 7593 for ARESEP regarding the regulation and oversight of the public services concerning AyA.

This is how this information requirement is requested from AyA, in order for ARESEP to have the information in a more reliable and rapid manner within the framework of inter-institutional coordination.

On the other hand, Ley 7593, in its Article 24, related to the supply of information by public service providers, indicates that:

"(.) At the request of the Regulatory Authority, the regulated entities shall supply reports, data, file copies, and any other electronic or written medium where financial, accounting, economic, statistical, and technical information related to the provision of the public service they provide is stored. For the exclusive fulfillment of its functions, the Regulatory Authority shall have the power to inspect and register the legal and accounting books, vouchers, reports, equipment, and facilities of the providers. (As amended by Article 41, subsection a) of Law 8660 of 8/8/2008, published in Alcance 31, to La Gaceta 156 of 13/8/2008) (.)" It is also recalled that the requested information regarding water quality held by AyA has been submitted to ARESEP since 2020 through quarterly deliveries. In response, AyA itself, through official letter GG-2020-03789 and memorandum PRE-J-2020-03829, issued a legal opinion related to access to the databases of the National Water Laboratory (LNA), stating regarding the water quality information held by AyA, that:

"(.) It can be within reach of any interested party, even more so it must be for other Costa Rican State institutions such as ARESEP, which requires it for the full fulfillment of its competencies as a regulator and overseer of public services, according to its constituent law.

It is important to mention that the National Water Laboratory of AyA is responsible for generating actions related to information for its clients (ASADAS or ESPH) regarding those data that may be provided to private individuals or State institutions, as indicated in Articles 11, 30, and 46 of the Constitución Política, as well as the jurisprudence of the Sala Constitucional of the Corte Suprema de Justicia. The foregoing, in order to avoid non-compliances in the evaluations carried out by the ECA on the application of the INTE/ISO/IEC 17025:2017 standard, which could affect the Laboratory's accreditation (.)." Therefore, it is necessary to maintain the request for the water quality information held by AyA for its own systems, ESPH, and ASADAS, in AyA's possession through the National Water Laboratory, also including those conducted through surveillance, sanitary quality seal, specific programs, or direct contract with the provider.

XIV. Regarding the request for the presentation of the Drinking Water Quality Report

Regarding the presentation of the Drinking Water Quality Report in PDF format and complete, for the aqueduct systems operated by AyA.

Thus, for the purposes of ensuring compliance with Decreto 38924-S "Reglamento de Calidad del Agua Potable" and its amendment in Decreto 41499-S, it is necessary for the regulatory body to have the respective Drinking Water Quality Report in PDF format, showing the acknowledgment of receipt by the Ministry of Health. This is so that ARESEP can verify that AyA complies with Article 11 of Decreto 38924-S, which is a quality norm that AyA must comply with as the aqueduct service operator.

Furthermore, this report is important for ARESEP because in it, the provider should indicate the corrective actions to be implemented in the aqueduct system, which is necessary information for the Intendancy's oversight duties in cases where non-conformities in water quality arise.

It is under the principle of inter-institutional coordination that AyA is requested to submit this information, as it is the primary source in the preparation of said report.

In addition to the above, this information is already submitted by AyA each semester through the information matrices sent to ARESEP. Therefore, it is necessary to maintain the request for the Drinking Water Quality Reports in their PDF format and with the acknowledgment of receipt by the Ministry of Health.

XV. Regarding the request to clarify the effective date of resolution RE-0018-IA-2021

It is clarified to AyA that resolution RE-0018-IA-2021 takes effect from its publication date. Therefore, the providers of aqueduct and sewerage services must comply with what is stipulated in this resolution from its publication on August 30, 2021, according to the information delivery periodicities indicated in each of anexos 1, 2, and 3 of said resolution.

V. CONCLUSIONS

Based on the foregoing, the following conclusions can be reached:

1. From a formal standpoint, the motion for addition and clarification and the appeal for revocation filed by the Instituto Costarricense de Acueductos y Alcantarillados (AyA) against resolution RE-0018-IA-2021 are admissible, having been filed in time and form.

2. The information requirements made by the Intendencia de Agua, through resolution RE-0018-IA-2021, regarding quality for the services regulated by this regulatory body, are not included among the exhaustive matters that must be submitted to a public hearing according to Article 36 of Ley N°7593.

3. The Intendencia de Agua has provided the pertinent means and facilities for providers to participate and comment on the regulatory measures dictated in resolution RE-00018-IA-2021, should they consider themselves affected. For this reason, said resolution was duly reasoned, published, and notified through the means indicated by the operators, facilitating their digital access to the case file. It is not considered that there has been any obstacle to the effective enjoyment and exercise of their rights, giving the best consideration to the arguments contained in their challenge, as is effectively being done.

4. The improvement of regulatory instruments is part of a process of continuous improvement and adoption of sound practices and transparency that ARESEP has been developing. This is duly based on the objectives set forth in Article 4 of Ley N°7593, with the purpose of harmonizing and seeking a balance between the interests of users and providers of public services, as well as ensuring provision in accordance with the principle of cost-of-service and the provisions of Article 31 of the same law. Likewise, Ley N°7593, in Articles 14, subsections a) and c), and 24, establishes the obligation of providers to comply with the provisions dictated by ARESEP, as well as to timely supply the information requested from them. From this derives the legal basis for the Intendencia de Agua to request from the public service providers of the water sector the specific regulatory information requirements regarding quality in the formats and deadlines established in the appealed resolution.

5. Article 6, subsection a) of Ley N°7593 establishes the obligation of ARESEP to regulate and oversee the providers of public services in accounting, financial, and technical terms to verify the correct management of factors affecting the cost of the service. Similarly, and as provided in Article 14, subsections a) and c), it is the obligation of providers to comply with the provisions dictated by ARESEP regarding the provision of the service, in accordance with the provisions of the respective laws and regulations, and to timely supply the Regulatory Body with the information requested concerning the provision of the service. Furthermore, Article 24 expressly establishes that they must supply reports, data, file copies, and any other electronic or written medium where financial, accounting, economic, statistical, and technical information related to the provision of the public service they provide is stored.

6. Articles 16, 17, and 18 of the Reglamento Técnico de Prestación de los Servicios de Acueducto, Alcantarillado e Hidrantes N°AR-PSAYA-2015 do not specify that the presentation of information must be annual. In the case of the annual programs and plans indicated in Article 17, subsections h) and n), reference is made to the fact that these must be projected for a one-year term, not that their presentation must be annual, since the progress control of their execution can be verified with a periodicity of less than one year.

7. From Article 33 of Ley N°7593, it is understood that every tariff petition must be justified; in addition, applicants must have complied with the conditions established by ARESEP in previous tariff fixations or interventions carried out in the exercise of its powers. Therefore, AyA must comply with the delivery of the information required through resolution RE-00018-IA-2021, so that the Regulatory Authority has reliable and consistent information to correctly apply the tariff-setting methodologies dictated by the Junta Directiva, as well as to effectively exercise the regulation of the regulated services, for the benefit of the interests of users and providers.

8. The following points are clarified: ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO CAC-001 Aqueduct Operational Control; ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO - CAC-003 - Disinfection; ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO - CAL -001- Sewerage Operational Control; ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO - CAP -001 - General Treatment Plants; ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-008 - Special Cases; ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-009 -Availabilities; and, regarding the arguments about the information that AyA must present on the ASADAS, Anexo 2- II. iii. (ANEXO 2-INFORMACIÓN DE CALIDAD DEL SERVICIOS. II. Information required for periodic service quality monitoring) is clarified. So that they are understood as follows:

I. ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO CAC-001 Aqueduct Operational Control

In it, only information is requested on the operational control parameters of the aqueduct systems that the operator must record in the semi-annual quality reports, as indicated in the Reglamento para la calidad del agua potable N°38924-S in Article 11 and in its anexo 3, and its amendment Decreto N°41499-S. The data entry form does not indicate, in any instance, sewerage system information that would lead to ambiguity regarding what is requested with respect to the sewerage service.

II. ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO - CAC-003 - Disinfection

For those aqueduct systems that use more than one type of disinfection, in the instructions for the data entry form, the "TIPO DE DESINFECCIÓN" column, it is clearly indicated that all types of disinfection present in the aqueduct system must be stated, all in the cell being filled in for the corresponding system's disinfection type. It is clarified that the separation between one type of disinfection and another, when there are several types of disinfection, can be done using a comma.

III. ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO - CAL -001- Sewerage Operational Control

This data entry form only requests information on the parameters of the measurements taken by the generating entity in the wastewater treatment systems that are part of the sewerage systems, as indicated in the Reglamento de vertido y reúso del agua N°33601-MINAE-S. It does not indicate, in any instance, aqueduct system information that would lead to ambiguity regarding what is requested.

It is important to mention that the data entry form has a column called "OBSERVACIONES," in which any detail that AyA considers important about the information being submitted can be added or expanded upon.

IV. ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO - CAP -001 - General Treatment Plants

The required information corresponds to both Wastewater Treatment Plants and Drinking Water Treatment Plants, as part of the information is similar in both types of treatment systems. Additionally, for those information fields that are specific to Wastewater Treatment Plants or Drinking Water Treatment Plants, the template instructions clearly stipulate which type of treatment (wastewater or drinking water) the information to be indicated by the operator corresponds to. As an example, it is noted that, in the case of information referring to treated flow rate, sludge extraction frequency, sludge disposal, and sludge manager, requested in the CAP-001 data entry form, this is general information shared by both Drinking Water and Wastewater Treatment Plants.

V. ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-008 - Special Cases

Both Article 95 and Article 97 of the ARESEP Reglamento de Prestación de Servicios AR-PSAYA-2015 apply only to the aqueduct service, not to the sewerage service. In CAS-008-Special Cases, the sewerage service was included, but it is clarified that the required information is only for the aqueduct service; therefore, in the annex in question, the tab called "SERVICIO" will only indicate "Acueducto."

VI. Regarding ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-009-Availabilities

In the CAS-009 data entry form, the concepts of "New Availabilities" and "Denied Availabilities" refer to new and denied availabilities as a boolean value. Therefore, to avoid confusion, it is clarified in this data entry form that the type of data to be entered corresponds to an integer instead of a boolean, and the corresponding definitions are as follows:

. New availabilities: number of service availabilities granted in the indicated period, in the respective system.

. Denied availabilities: number of service availabilities denied in the indicated period, in the respective system.

With reference to the arguments about the information that AyA must present on the ASADAS In Anexo 2- II. iii. (ANEXO 2-INFORMACIÓN DE CALIDAD DEL SERVICIOS. II. Information required for periodic service quality monitoring) it reads that, "In the case of CAS-001 Times and related services, additionally, AyA must present the information corresponding to the ASADAS." In this regard, it is clarified to AyA that what it must present for the ASADAS is CAS-002 Interruptions, instead of CAS-001 Times and related services. Therefore, the indication in the aforementioned anexo 2-II.A.iii is deleted, and what is indicated in anexo 2-II.B.iii is updated to read, "In the case of CAS-002 Interruptions and CAS-009 Availabilities, additionally, AyA must present the corresponding ASADAS information." 9. Regarding the arguments on the appeal for revocation, it is concluded that:

I.ANEXO 1-INFORMACIÓN DE CALIDAD DEL PRODUCTO-D. Information required for drinking water and wastewater treatment systems -CAP-001-General Treatment Plants: It is the operator's duty to have updated information, duly tabulated in an information system for this purpose, to comply with information requirements requested in a timely manner by the regulatory body or other interested party.

II.ANEXO 1-INFORMACIÓN DE CALIDAD DEL PRODUCTO-D. Information required for drinking water and wastewater treatment systems CAP-002-Specific Treatment Plants: It is the operator's duty to have updated information, duly tabulated in an information system for this purpose, to comply with information requirements requested in a timely manner by the regulatory body or other interested party.

III.ANNEX 1 - PRODUCT QUALITY INFORMATION - D. Information required for drinking water and wastewater treatment systems - CAP-001-General Treatment Plants: The approval, renewal, or processing timeframes by the Ministry of Health regarding operating permits are the exclusive competence of that public entity; therefore, ARESEP does not have the authority to expedite these procedures. However, these timeframes do not represent any impediment for AyA to submit the information requested in the CAP-001-General Treatment Plants data entry form, and in the event that the sanitary permit is in the process of approval or renewal, it should proceed to indicate the clarification in the corresponding observations box.

IV.ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-001 - Timelines and Ancillary Services: The situation of AyA in relation to information systems has been managed by this Regulatory Authority since 2016 through resolutions, official letters, and transitory provisions of the current AR-PSAYA-2015 Regulation for Service Provision, having extended the deadline on repeated occasions. This issue has been recurrent, and it is also observed that, in accordance with resolution RE-0001-IA-2019, the Water Intendancy established in the operative section (Por Tanto) II that AyA must have the new information processing system implemented no later than December 31, 2021. The Regulatory Authority considers that the information requested is not new; furthermore, the information management by the provider must be efficient, especially information of great relevance for operational purposes, such as that requested by the CAS-001 - Timelines and Ancillary Services data entry form. Therefore, AyA must have this information for compliance with what is requested in RE-0018-IA-2021.

V. Regarding ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-0012 - Interruptions

AyA currently does disaggregate the information corresponding to the sewerage service discontinuity indicators; namely: Density of blockages, overflows, and the number of failures occurring due to faults and breaks in the connections and the system network. Reference is made to the reports that the GAM Sub-management of RyT Directorate and the regional directorates send annually through the Benchmarking and DIAA matrices, classifying service interruptions as broken down in the tab called "CAUSA" in the CAS-002 data entry form. Points 8 through 17 of said tab are associated with the sewerage service and with the provisions of articles 34 through 41 of the AR-PSAYA-2015 standard.

Thus, the deadlines granted for the submission of information do not represent any impediment for AyA to have the information requested for this data entry form by the indicated dates.

VI. ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-003 - Pipe Replacement Plan

The Regulatory Authority grants resources through tariff means via depreciation expense for asset replacement (sustitución de activos), and the condition of pipes is no exception. The use of these resources must be transparently reflected within the replacement investment plans and defined for what they were used.

In article 17 of the current ARPSAYA-2015 Regulation for Service Provision, a request is made for these plans; therefore, this information is not new and is submitted within the periodic information matrices that AyA presents prior to this resolution.

VII.Regarding ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-004 - Hydrometer Maintenance: The Regulatory Authority grants resources through tariff means via depreciation expense for asset replacement (sustitución de activos), and the maintenance of meters is no exception. The use of these resources must be transparently reflected within the replacement investment plans and defined for what they were used. The request for this information is not new, as ARESEP has been requesting it, and prior to resolution RE-0018-IA-2021, it was submitted within the periodic information matrices that AyA sent to the regulatory entity.

VIII. ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-005

- Hydrant Maintenance: It is considered appropriate to expand the type of maintenance performed on hydrants, thereby partially accepting the appeal for revocation (recurso de revocatoria) filed by AyA against resolution RE-0018-IE-2021 of August 30, 2021, issued by the Water Intendancy, which refers to ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-005, and the type of maintenance performed on hydrants is included in the annex in question, segregated into two types of maintenance:

. Preventive maintenance . Corrective maintenance.

With reference to changing the name of column F to be called "Planned Hydrant Type (Tipo de Hidrante Planificado)" and column H to be called "Executed Hydrant Type (Tipo de Hidrante Ejecutado)", the Intendancy sees no technical need to make the suggested change, given that the current names in the data entry form are clearly understood. Therefore, the current names on the data entry form are maintained for columns F and H, corresponding to "TYPE OF HYDRANT PLANNED TO BE REPLACED (TIPO DE HIDRANTE PLANIFICADO A SUSTITUIR)" and "TYPE OF EXECUTED REPLACED HYDRANT (TIPO DE HIDRANTE SUSTITUIDO EJECUTADO)", respectively.

IX. ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-006 - Complaints

The request for this information is not new, as ARESEP has been requesting it, and prior to resolution RE-0018-IA-2021, it was submitted within the periodic information matrices that AyA sent to the regulatory entity.

X. ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-010 - Infrastructure

The need for ARESEP to have at least this information every six months is evident, in order to obtain in a timely manner the variations that may occur at any time in the normal operation of any supply system, whether due to maintenance reasons or the addition of new infrastructure to the system.

XI.With reference to the arguments regarding the information that AyA must submit about the ASADAS: the information concerning the CAP-001 and CAP-002 data entry forms for the ASADAS is already submitted by AyA, as requested in official letters OF-0200-IA-2021 and OF-0201-IA-2021. Therefore, no impediment is observed for AyA to keep a record of the information requested in its databases and to provide a copy of said information through the CAC-002, CAC-003, CAS-002, CAS-009, CAP-001, and CAP-002 data entry forms for the ASADAS. AyA must submit the information concerning ASADAS indicated in the CAC-002, CAC-003, CAS-002, CAS-009, CAP-001, and CAP-002 data entry forms since this entity, in its capacity as Rector of the aqueduct and sewerage services, is called upon to have clear information on the ASADAS in view of its evaluation and oversight obligations indicated in Decree 42582-S-MINAE in article 37.

XII.On the submission of quality results for AyA, ESPH, and ASADAS systems available to it, also including those conducted for surveillance (vigilancia), sanitary quality seal, specific programs, or direct contract with the provider: In order to ensure compliance with the quality standards for the aqueduct and sewerage services provided by AyA; specifically, to verify compliance with the water quality standards and the measurement frequencies dictated by Decree 38924-S "Regulation for the Quality of Drinking Water" and its amendment in Decree 41499-S, and Decree 33601-MINAE-S "Regulation for the Discharge and Reuse of Wastewater", it is necessary to have the information concerning the water quality analyses available to AyA. Under the principle of inter-institutional coordination, AyA is requested to submit such information, since it is the primary source generating the quality information, coming from a technical entity with vast experience in water quality analysis, such as AyA through the National Water Laboratory, for both water for human consumption and discharge water resulting from wastewater treatment. Furthermore, it is pertinent for the regulatory entity to obtain the water quality results performed in each period as quickly as possible and efficiently, so that ARESEP also has the information promptly to be able to oversee compliance with quality standards, even more so in cases where the health of the population could be seriously affected by non-compliance with water quality. It is necessary to maintain the request for the water quality information that AyA possesses from its own systems, ESPH, and ASADAS which the AyA National Water Laboratory has, also including those conducted for surveillance (vigilancia), sanitary quality seal, specific programs, or direct contract with the provider, because AyA is the primary source for obtaining quality information, coming from a technical entity with vast experience in water quality analysis, as is AyA through the National Water Laboratory, for both water for human consumption and discharge water resulting from wastewater treatment.

In addition, this information has already been submitted by AyA to ARESEP since the year 2020.

10. Regarding the petition concerning the submission of the Drinking Water Quality Report in PDF format and complete for the aqueduct systems operated by AyA.

It must be remembered that AyA is a state entity and a public and autonomous institution, to which the functions of rector entity and operator of the public aqueduct and sewerage services in the Costa Rican state are attributed.

Furthermore, from the regulatory point of view performed by ARESEP over public aqueduct and sewerage services, article 5 of Law No. 7593 indicates that compliance with standards of quality, quantity, reliability, continuity, timeliness, and optimal provision for the services in which AyA is the operator must be ensured.

Thus, for the purposes of ensuring compliance with Decree 38924-S "Regulation for the Quality of Drinking Water" and its amendment in Decree 41499-S, it is necessary for the regulatory entity to have the respective Drinking Water Quality Report in PDF format showing the acknowledgment of receipt by the Ministry of Health, in order to verify that AyA complies with article 11 of Decree 38924-S, which is a quality standard that AyA must comply with as the operator of the aqueduct service.

Also, this report is important for ARESEP because, in it, the provider should indicate the corrective actions to be implemented in the aqueduct system, which is necessary information for the Intendancy's oversight efforts in those cases where non-conformities in water quality arise.

It is under the principle of inter-institutional coordination that AyA is requested to submit such information, as it is the primary source in the preparation of said report.

In addition to the above, this information is already submitted by AyA, every six months through the information matrices sent to ARESEP.

Therefore, it is necessary to maintain the request for the Drinking Water Quality Reports in their PDF format and with the acknowledgment of receipt by the Ministry of Health.

11. Regarding the petition to clarify the effective date of resolution RE-0018-IA-2021: It is clarified to AyA that resolution RE-0018-IA-2021 becomes effective upon its publication. Therefore, the providers of the aqueduct and sewerage services must comply with the provisions of this resolution as of its publication on August 30, 2021, in accordance with the information delivery periodicities indicated in each of the annexes 1, 2, and 3 of said resolution (.)".

II.In accordance with the findings and preceding recitals and on the merits of the case file, the appropriate course of action is to partially accept the appeal for revocation (recurso de revocatoria) filed by AyA against resolution RE-0018-IA-2021 of August 30, 2021; as well as to clarify the observations made by AyA to the annexes to resolution RE-0018-IA-2021, as provided;

THEREFORE (POR TANTO) Based on the powers conferred in Law No. 7593 and its amendments, in the General Law of Public Administration No. 6227, in Executive Decree No. 29732-MP, which is the Regulation to Law No. 7593, and in the Internal Regulation of Organization and Functions of the Regulatory Authority of Public Services and its Deconcentrated Body.

The WATER INTENDENT (INTENDENTE DE AGUA)

I.To partially accept the appeal for revocation (recurso de revocatoria), filed by Mrs. Ileana Vanessa Castro López, in her capacity as Deputy General Manager with powers of unlimited general attorney of the Costa Rican Institute of Aqueducts and Sewerage, against resolution RE-0018-IA-2021, which refers to ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-005- Hydrant Maintenance, as it is considered appropriate to expand the type of maintenance performed on hydrants, including in the annex the type of maintenance performed, segregated into two types of:

. Preventive maintenance . Corrective maintenance.

II.To clarify the observations made by AyA to the annexes to resolution RE-0018-IA-2021 of August 30, 2021, issued by the Water Intendancy.

Consequently, in accordance with the provisions of the operative section (Por Tanto) V of resolution RE-0018-IA-2021, concerning that "The providers may not unilaterally modify the formats established through this resolution. Any modification or improvement they consider important to make must be formally and timely managed through the Water Intendancy for the purpose of conducting the corresponding technical evaluation. If the requested adjustment proceeds, it will be formally communicated to all involved parties", the following Annexes are hereby clarified and updated as indicated herein, which are available on the Regulatory Authority's website (www.aresep.go.cr), for viewing and downloading:

I)ANNEX 1 - PRODUCT QUALITY INFORMATION CAC-001 Operational Control of Aqueduct: It only requests information on the operational control parameters of the aqueduct systems that the operator must record in the semi-annual quality reports, as indicated in the Regulation for the Quality of Drinking Water No. 38924-S in article 11 and in its annex 3 and its amendment Decree No. 41499-S. The data entry form does not indicate, in any instance, information from the sewerage system that would lead to ambiguity regarding what is requested with respect to the sewerage service.
II)ANNEX 1 - PRODUCT QUALITY INFORMATION - CAC-003 - Disinfection: For those aqueduct systems that use more than one type of disinfection, the instructions for the data entry form, in the "TYPE OF DISINFECTION (TIPO DE DESINFECCIÓN)" column, clearly indicate that all types of disinfection present in the aqueduct system must be indicated, all in the cell being filled for the corresponding system disinfection type. It is clarified that the separation between one type of disinfection and another when there are several types of disinfection can be done using a comma.
III)ANNEX 1 - PRODUCT QUALITY INFORMATION - CAL-001- Operational Control of Sewerage: This data entry form only requests information on the parameters of measurements by the generating entity in the wastewater treatment systems that are part of the sewerage systems, as indicated in the Regulation on Water Discharge and Reuse No. 33601-MINAE-S. It does not indicate, in any instance, information from the aqueduct system that would lead to ambiguity regarding what is requested.

It is important to mention that the data entry form has a column called "OBSERVATIONS (OBSERVACIONES)", in which any detail that AyA considers important about the information being submitted can be added or expanded upon.

IV)ANNEX 1 - PRODUCT QUALITY INFORMATION - CAP-001 - General Treatment Plants: The information required corresponds both to Wastewater Treatment Plants and to Drinking Water Treatment Plants, since part of the information is similar in both types of treatment systems. Additionally, for those information fields that are specific to Wastewater Treatment Plants or Drinking Water Treatment Plants, the template instructions clearly stipulate which type of treatment (wastewater or drinking water) the information to be indicated by the operator corresponds to. As an example, it is indicated that, in the case of information related to treated flow, frequency of sludge extraction, sludge disposal, and sludge manager, requested in the CAP-001 data entry form, this is general information that both Drinking Water and Wastewater Treatment Plants share.
V)ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-008 - Special Cases: Both article 95 and article 97 of the ARESEP Regulation for Service Provision AR-PSAYA-2015 apply only to the aqueduct service, and not to the sewerage service.

In CAS-008-Special Cases, the sewerage service was included, but it is clarified that the required information is only for the aqueduct service; therefore, in the annex in question, the tab called "SERVICE (SERVICIO)" will only indicate "Aqueduct (Acueducto)".

VI)Regarding ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-009-Availabilities: In the CAS-009 data entry form, the concepts of "New Availabilities (Disponibilidades Nuevas)" and "Denied Availabilities (Disponibilidades Denegadas)" refer to new and denied availabilities as a boolean.

Therefore, to avoid confusion, it is clarified in this data entry form that the data type to be entered corresponds to an integer rather than a boolean, and that the corresponding definitions are as follows:

. New availabilities (Disponibilidades nuevas): number of service availabilities granted in the indicated period, in the respective system.

. Denied availabilities (Disponibilidades denegadas): number of service availabilities denied in the indicated period, in the respective system.

VII)With reference to the arguments regarding the information that AyA must submit about the ASADAS:

In Annex 2- II. iii. (ANNEX 2-SERVICE QUALITY INFORMATION. II. Information required for periodic monitoring of service quality) it is read that, "In the case of CAS-001 Timelines and related services, additionally, AyA must submit the information corresponding to the ASADAS".

In this regard, it is clarified to AyA that what must be submitted for the ASADAS is CAS-002 Interruptions, instead of CAS-001 Timelines and ancillary services. Therefore, the aforementioned indication in annex 2-II.A.iii is eliminated, and what is indicated in annex 2-II.B.iii is updated so that it reads, "In the case of CAS-002 Interruptions and CAS-009 Availabilities, additionally, AyA must submit the corresponding ASADAS information".

III.To clarify that resolution RE-0018-IA-2021 of August 30, 2021, was published in the official gazette La Gaceta No. 169, Supplement 173 of September 2, 2021; therefore, the providers must comply with the provisions of this resolution as of its publication on September 2, 2021, in accordance with the information delivery periodicities indicated in each of the annexes 1, 2, and 3 of said resolution.

IV.To notify the parties of the resolution to be issued, at the place or means indicated in the case file, or in the one known to the Regulatory Authority.

V.To elevate the subsidiary appeal for reversal (recurso de apelación en subsidio) to the Board of Directors and to warn the appellant that it has three working days, starting from the day following the notification of this resolution, to assert its rights before said appellate body.

No appeal is admissible against this resolution, in accordance with the provisions of articles 343 and 345.1 of the General Law of Public Administration.

LET IT BE NOTIFIED AND PUBLISHED

Reform of Information Requirements on Quality for Services Regulated by the Water SuperintendencyReforma Requerimientos de información en materia de calidad para los servicios regulados por la Intendencia de Agua

IV. ANALYSIS ON THE MERITS

I. Arguments of a legal nature

II. Arguments of a technical nature

I. Regarding ANNEX 1-PRODUCT QUALITY INFORMATION CAC-001 Aqueduct Operational Control

II. Regarding ANNEX 1-PRODUCT QUALITY INFORMATION CAC-003-Disinfection

III. Regarding ANNEX 1-PRODUCT QUALITY INFORMATION CAL-001-Sewerage Operational Control

IV. Regarding ANNEX 1-PRODUCT QUALITY INFORMATION CAP-001-General Treatment Plants

V. Regarding ANNEX 2 - SERVICE QUALITY INFORMATION -CAS-008- Special Cases

VI. Regarding ANNEX 2 - SERVICE QUALITY INFORMATION - CAS- 009-Availabilities

I. Regarding ANNEX 1-PRODUCT QUALITY INFORMATION CAP-001-General Treatment Plants

II. Regarding ANNEX 1-PRODUCT QUALITY INFORMATION CAP-002-Specific Treatment Plants

IV. Regarding ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-001 - Times and Related Services

V. ANEXO 2 - SERVICE QUALITY INFORMATION - CAS-0012 - Interruptions

VI. Regarding ANEXO 2 - SERVICE QUALITY INFORMATION - CAS-003- Pipe replacement plan

Artículo 17 — of the current Reglamento de Prestación de Servicios AR-PSAYA-2015 requests these plans, so this information is not new and is presented within the periodic information matrices that AyA presents prior to this resolution.

VII. Regarding ANEXO 2 - SERVICE QUALITY INFORMATION - CAS-004 - Hydrometer maintenance

VIII. Regarding ANEXO 2 - SERVICE QUALITY INFORMATION - CAS-005 - Hydrant Maintenance

IX. Regarding ANEXO 2 - SERVICE QUALITY INFORMATION - CAS-006

X. Regarding ANEXO 2 - SERVICE QUALITY INFORMATION - CAS-010 - Infrastructure

XII. With reference to the arguments regarding the information that AyA must present on the ASADAS

XIV. Regarding the request for the presentation of the Drinking Water Quality Report

XV. Regarding the request to clarify the effective date of resolution RE-0018-IA-2021

V. CONCLUSIONS

I. ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO CAC-001 Aqueduct Operational Control

II. ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO - CAC-003 - Disinfection

III. ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO - CAL -001- Sewerage Operational Control

IV. ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO - CAP -001 - General Treatment Plants

V. ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-008 - Special Cases

VI. Regarding ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-009-Availabilities

V. Regarding ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-0012 - Interruptions

VI. ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-003 - Pipe Replacement Plan

VIII. ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-005

IX. ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-006 - Complaints

X. ANNEX 2 - SERVICE QUALITY INFORMATION - CAS-010 - Infrastructure

IV. ANÁLISIS POR EL FONDO

I. Argumentos de naturaleza jurídica

II. Argumentos de naturaleza técnica

I. Sobre el ANEXO 1-INFORMACIÓN DE CALIDAD DEL PRODUCTO CAC-001 Control Operativo Acueducto

II. Sobre el ANEXO 1-INFORMACIÓN DE CALIDAD DEL PRODUCTO CAC-003-Desinfección

III. Sobre el ANEXO 1-INFORMACIÓN DE CALIDAD DEL PRODUCTO CAL-001-Control Operativo Alcantarillado

IV. Sobre el ANEXO 1-INFORMACIÓN DE CALIDAD DEL PRODUCTO CAP-001-Plantas de Tratamiento General

V. Sobre el ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO -CAS-008- Casos Especiales

VI. Sobre el ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS- 009-Disponibilidades

I. Sobre el ANEXO 1-INFORMACIÓN DE CALIDAD DEL PRODUCTO CAP-001-Plantas de Tratamiento General

II. Sobre el ANEXO 1-INFORMACIÓN DE CALIDAD DEL PRODUCTO CAP-002-Plantas de Tratamiento Específico

IV. Sobre el ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-001 - Tiempos y Servicios Conexos

V. ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-0012 - Interrupciones

VI. Sobre el ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS- 003- Plan de sustitución de tuberías

VII. Sobre el ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-004 - Mantenimiento de hidrómetros

VIII. Sobre el ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS- 005 - Mantenimiento de Hidrantes

IX. Sobre el ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-006

X. Sobre el ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-010 - Infraestructura

XII. Con referencian a los argumentos de la información que debe presentar AyA sobre las ASADAS

XIV. Sobre la petitoria para la presentación del Reporte de Calidad del Agua Potable

XV. Sobre la petitoria de aclarar la fecha de vigencia de la resolución RE-0018-IA-2021

V. CONCLUSIONES

I. ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO CAC-001 Control Operativo de Acueducto

II. ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO - CAC-003 - Desinfección

III. ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO - CAL -001- Control Operativo Alcantarillado

IV. ANEXO 1 - INFORMACIÓN DE CALIDAD DEL PRODUCTO - CAP -001 - Plantas de Tratamiento General

V. ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-008 - Casos especiales

VI. Sobre el ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-009-Disponibilidades

IV. ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-001 - Tiempos y Servicios Conexos

V. Sobre el ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-0012 - Interrupciones

VI. ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-003- Plan de sustitución de tuberías

VIII. ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-005

IX. ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-006 - Reclamos

X. ANEXO 2 - INFORMACIÓN DE CALIDAD DEL SERVICIO - CAS-010 - Infraestructura

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