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HomeMy WebLinkAbout01-28-19 City Commission Packet Materials - A3. Water and Wastewater Rate Study Work SessionCommission Memorandum REPORT TO: Honorable Mayor and City Commission FROM: Kristin Donald, Finance Director SUBJECT: Water and Wastewater rate studies workshop MEETING DATE: January 28, 2019 AGENDA ITEM TYPE: Action RECOMMENDATION: Listen to the presentation; take public comment, and direct staff and consulting firm regarding: • Policy Issue 1 - Conservation-Based Residential Water Rates • Policy Issue 2 - Drought Surcharges and Drought Reserve Funding • Policy Issue 3 - Reserve Policies and Targets • Policy Issue 4 - COSA based rate setting BACKGROUND: In August 2017, the City put out a request for proposals for water and wastewater rate studies and AE2S Nexus, LLC was selected and signed a professional services agreement November 6, 2017. The expenditures are funded from the Water and Wastewater funds as outlined in the budget. AE2S presented the preliminary results of their rates studies for the water and wastewater funds on August 20, 2018 Commission meeting. Based on the feedback from that meeting a inflationary rate for water and wastewater was adopted and staff continued to work with the consultant on the study. Staff have reviewed and revised capital plans for the funds, which were then adopted December 3, 2018. The next step is getting key policy decisions to complete the rate design. AE2S will be conducting the discussion to get feedback on key policy areas: Policy Issue 1 - Conservation-Based Residential Water Rates 1. Should Tier 1 be limited to primarily essential water use (6 CCF) or include some element of minor outdoor consumption (8 CCF)? 2. Does the Commission agree that primary outdoor use tiers (2nd and 3rd Tier) be established based on typical/peak Single Family residential watering needs? 3. Should the rate structure include an excessive outdoor water use tier (4th tier)? 4. Are there any concerns with the price step factors between tiers (see Table 1)? Policy Issue 2 - Drought Surcharges and Drought Reserve Funding Drought Surcharge Policy Feedback: 190 1. Is the drought surcharge rate structure as proposed in line with Commission policy objectives? 2. Given the potential for significant surcharges in the event of Stage 3-4 drought, does the Commission believe drought surcharges should be capped and to what level? Drought Reserve Policy Feedback: 1. If surcharge caps are desired, should a corresponding drought reserve be funded? 2. What does the Commission believe should be the target reserve balance? 3. How many years is appropriate to accumulate the reserve? 4. Should the reserve be accumulated through a standard volumetric rate increase or a user class increase based on the anticipated benefit of use of the reserves during drought? Policy Issue 3 - Reserve Policies and Targets 1. Given the current approach to funding Operating and Debt Reserves, does the Commission have a desire to better define policy to include Renewal & Replacement, Rate Stabilization, and Drought Contingency Reserves? 2. If the Commission desires to set policy for and develop any of these additional Reserves, are the preliminarily proposed targets appropriate for planning purposes? Policy Issue 4 - COSA based Rate-Setting Water: 1. Going forward, does the Commission desire to apply user class-specific adjustments to the Water rate structures that will work to generate revenue from each class that is commensurate with the associated cost for each class? 2. If cost of service correction is a priority, how aggressively should it be approached? Wastewater: 1. Going forward, does the Commission desire to apply user class-specific adjustments to the Wastewater rate structures that will work to generate revenue from each class that is commensurate with the associated cost for each class? 2. If cost of service correction is a priority, how aggressively should it be approached? The final rate study will be brought back to the commission prior to the budget discussions in May with rate adoption by September. UNRESOLVED ISSUES: None ALTERNATIVES: As suggested by the Commission FISCAL EFFECTS: To be determined Report compiled on: January 18, 2019 Attached: Policy Issue 1 - Conservation-Based Residential Water Rates Paper Policy Issue 2 - Drought Surcharges and Drought Reserve Funding Paper Policy Issue 3 - Reserve Policies and Targets Paper Policy Issue 4 - COSA based Rate-Setting Paper 191 Policy Issue #1: Conservation-Based Residential Water Rates 1 POLICY ISSUE #1: CONSERVATION-BASED RESIDENTIAL WATER RATES KEY DRIVERS KEY DEFINITIONS ESSENTIAL USE • The American Water Works Association’s M1 Manual, Principles of Water Rates, Fees, and Charges, defines essential water use as “The quantity of water needed to meet basic human needs, including drinking water for survival, basic hygiene and sanitation purposes, and household needs such as preparing food.” • This study estimated essential water use through the review of winter consumption data when outdoor use is negligible. SINGLE FAMILY RESIDENTIAL USE • Based on GIS analysis of Bozeman’s single family parcels, a typical single family residential user is approximately 8,100 square foot lot with 53 percent pervious area. • Analysis of winter consumption data indicates that a typical single family residential user consumes approximately 4.67 CCF per month for essential use. • In consideration of Bozeman’s climate and typical vegetative cover practices, the average monthly CCF for a typical Single Family user to meet irrigation needs was determined to be 19 CCF. EXCESSIVE USE • For the purposes of this study, excessive use was defined as outdoor water use in excess of 2.0 times the typical Single Family user’s outdoor water requirement for turfgrass during peak irrigation season of July, when conditions are exceptionally hot and dry. In 2014, the City completed an Integrated Water Resource Plan (IWRP) to identify future water supply needs and outline recommendations for meeting those needs. The City identified water conservation as the most important component in managing the City’s future water supply. The commissioning of a water rate study to evaluate and recommend conservation-based water rates was a key component of the IWRP Implementation Plan. A key component to any successful water conservation program is the adoption of a conservation-based rate structure to send appropriate pricing signals for inefficient use of water and to ultimately increase water use efficiency over time. The conservation-based rates will apply specifically to the single family residential user class. Single family residential was selected because it is the largest user class within Bozeman’s water system and has the greatest conservation potential, with approximately 70 percent of the single family residential summer use going to lawns and landscapes. 192 Policy Issue #1: Conservation-Based Residential Water Rates 2 TIERED WATER RATE ALTERNATIVES There is no perfect approach to designing conservation-based water rates, but the City can begin evaluating alternatives by defining key characteristics of its current usage and approach to rates. As a part of the study and alternative development, the following tier definitions were established: The primary goals and considerations are identified and discussed below: 1. APPROPRIATE PRICING TO PROMOTE WATER USE EFFICIENCY: The primary goal of each of the alternatives was not to eliminate outdoor use, but to reduce inefficient use and eliminate excessive use on the water system from the Single Family residential customer class. With a tiered conservation based rate structure, the best way to do this is to establish appropriate pricing signals as outdoor usage increases from responsible to inefficient to excessive. 2. EFFECTIVE REVENUE GENERATION: Another goal is to maintain equal revenue generation within the first three tiers, with the intention that excessive usage in Tier 4 will eventually be eliminated over time as customers realize the effect of pricing on their water use at this level. Before Tier 4 usage is eliminated, the City can direct the revenue generated from this Tier towards a specific use such as the contemplated drought reserve (see separate drought surcharge/reserve policy paper) or other water conservation initiatives. 3. ESSENTIAL AND RESPONSIBLE OUTDOOR USE AFFORDABILITY: The primary consideration in the development of the tiers is the affordability of both essential and responsible outdoor use. The amount of indoor water use required for basic living purposes is sometimes referred to as “Lifeline” water use and can be of particular concern for fixed income users. In the tier pricing of each alternative, focus is placed on the ability to maintain a water rate in the first tier that is affordable for this first block of usage where there is little ability for customers to reduce usage. Regarding Responsible outdoor use, when striving for conservation, it is appropriate to charge more for outdoor water use than for indoor water use. However, for the “Responsible Use” Tier 2, all alternatives were established to keep water as affordable as possible in this tier. TIER 1 Essential Use TIER 2 Responsible Outdoor Use TIER 3 Inefficient Outdoor Use TIER 4 Excessive Outdoor Use 69.0% 87.0% 100.0% 100.0% 0.0% 10.0% 20.0% 30.0% 40.0% 50.0% 60.0% 70.0% 80.0% 90.0% 100.0% Existing Alternative 1 Alternative 2 Alternative 3 Single Family and Low Income Residential CHART 1: PROBABILITY OF ACHIEVING REVENUE TARGET 193 Policy Issue #1: Conservation-Based Residential Water Rates 3 4. THE RELATIONSHIP OF TIER SIZE TO PRICING REQUIRED: An additional consideration is the relationship between tier size and volumetric rate required as water usage increases in each block. The volumetric rate for each tier is directly related to the size of the tier and the total water sales anticipated within that tier. This is especially important when considering the affordability of the essential use tier (Tier 1). As the size of Tier 1 increases, so does the rate required with in this tier. This is primarily driven by the increase in the total water sales projected to be generated from the first Tier as its size increases. Therefore, for all alternatives presented, this first tier size (and associated rate required) was established at or below the existing first tier size. With these goals and considerations in mind, Table 1 summarizes the current rate structure and the three alternative structures that have been developed for consideration. Chart 2 below represents the structure of the proposed alternatives as they relate to total annual consumption for a recent year (2017) for the single family residential customer class. TABLE 1: ALTERNATIVE SINGLE-FAMILY RESIDENTIAL STRUCTURE COMPARISON Tier 1 Essential Use Tier 2 Responsi- ble Outdoor Use Tier 3 Inefficient Outdoor Use Tier 4 Excessive Outdoor Use Tier Size (CCF) Alternative 3 0-8 8-25 25-44 44+ Alternative 2 0-6 6-25 25-55 55+ Alternative 1 0-6 6-19 25+ Existing 0-8 8-15 15+ Rate per CCF Alternative 3 $2.55 $3.57 $5.18 $7.76 Alternative 2 $2.40 $3.24 $4.54 $6.81 Alternative 1 $2.40 $3.00 $3.75 Existing $2.55 $2.75 $3.24 Step Factor Alternative 3 1.40 1.45 1.50 Alternative 2 1.35 1.40 1.50 Alternative 1 1.25 1.25 Existing 1.08 1.18 8 6 6 8 7 19 19 19 75+ 65+ 30 19 35+ 44+ 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 Existing Alternative 1 Alternative 2 Alternative 3 34% of Consumption <3% of Consumption $2.55 $3.57 $5.18 $7.76 Policy Issue #1: Conservation-Based Residential Water Rates 4 ANALYSIS OF POTENTIAL RATE STRUCTURES As described earlier, tier sizing was primarily established based on essential and responsible outdoor use data specific to the City of Bozeman. The pricing signal and increase factors applied in the development of alternatives were based on the project teams professional experience in developing successful conservation rate structures for other communities in Montana and across the region. As stated earlier, judging the anticipated effectiveness of each rate structure alternative in reducing consumption and generating appropriate revenue was done through the use of a probabilistic water sales forecasting model. The model allows for simulations to be run considering multiple factors that could affect water demand such as weather, growth, and pricing structure. Chart 3 below indicates the model simulation results regarding the projected decline in water sales as compared to the existing structure for the Single Family user class for each of the presented alternatives. ANALYSIS OF EXISTING TIERED SINGLE FAMILY RATE STRUCTURE: Based on the results of the sales forecasting model and the Study teams experience with developing conservation based rate structures for other clients throughout the region, the performance and sizing of the current rate structure was evaluated for effectiveness in promoting conservation and options for improvement. The following bullets summarize the observations from this review: • Tier 1 – The current size of this tier appears to be larger than necessary when considering essential use data. The City of Bozeman’s average residential winter water use per account (i.e. when outdoor water use is negligible) is 4.67 CCF, which suggests quite a bit of outdoor water use is likely being charged at the Tier 1 rate. • Tier 2 – The rate for this tier appears to provide a minimal pricing signal over Tier 1 pricing to promote efficient outdoor consumption with an increase factor of only 1.08 ($2.75/$2.55). It is recommended that this first step be established closer to a 1.25 increase factor over the Tier 1 pricing. Additionally, based on an analysis of typical residential lot size and irrigable area, it is recommended that the City consider expanding this tier size to provide a more appropriate volume for the responsible irrigation based on vegetative cover practices and climatic conditions in the Bozeman region. • Tier 3 – This tier also appears to provide a less than adequate price signal. With an increase factor of 1.18 ($3.24/$2.75), this price signal is greater than that from Tier 1 to Tier 2, but still appears to be inadequate for the third or final tier of the rate structure where the goal is to persuade the customer to make better outdoor water use decisions and curb usage back to Tier 2 pricing. Effective price signals for a third tier which is meant to address inefficient outdoor water use practices often are seen in the range of a 1.25 to 1.50 factor of increase over Tier 2. Moreover, the review of successful conservation rates from around the region supports the creation of a fourth tier to definitively distinguish inefficient water use from excessive water use. 1. Tier Sizing 2. Price Signal Adequacy 3. Appropriate Increase Factors Between Tiers THE ANALYSIS OF ALTERNATIVES FOCUSES ON IDENTIFYING AND CONSIDERING THREE IMPORTANT CHARACTERISTICS 0.8% 6.8% 7.4% 0.0% 1.0% 2.0% 3.0% 4.0% 5.0% 6.0% 7.0% 8.0% Alternative 1 Alternative 2 Alternative 3 Single Family and Low Income Residential CHART 3: FORECASTED REDUCTION IN WATER SALES 195 Policy Issue #1: Conservation-Based Residential Water Rates 5 • Beyond Tier 3 – In the existing rate structure, there is no current consideration for excessive use pricing of large volume residential consumers. The most effective conservation rate structures provide a clear distinction between residential consumers with inefficient water use and those with excessive water use well outside the scope of reasonable consumption. A fourth tier increase factor of at least 1.50 is recommended to make this distinction and send a clear price signal to those users putting excess strain on the system. SUMMARY OF ANALYSIS OF ALTERNATIVE SINGLE FAMILY RATE STRUCTURES The following summarizes the Study teams observations for each alternative structure in consideration of the review of the effectiveness of the existing rate structure and the results projected from the water sales forecasting analysis. Alternative 1: Model results project that Alternative 1 is likely to provide the least effective conservation results as compared to the current rate structure. This result was not unexpected considering that, of the three alternatives analyzed, this is the only one that does not provide a fourth penalty tier for excessive use. • Tier 1: Alternative 1 decreases essential use to 6 CCF, smaller than the current tier size of 8 CCF. This decrease in tier size also lowers the projected total water use to be sold in this tier, resulting in lower rates for this tier. • Tier 2: This tier is appropriately sized, based on the responsible outdoor water use defined in the analysis of single family residential billing records. The increase factor of 1.25 ($3.00/$2.40) is the least aggressive of the alternatives but does send a reasonable price signal for responsible outdoor use. • Tier 3: The price signal from Tier 2 to 3 is equal to the price signal from Tier 1 to 2. This increase factor appears to be insufficient to adequately deter inefficient and excessive usage. With inefficient and excessive consumption bundled under one rate in the third tier, this structure acts in a similar fashion to the City’s current rate, as reflected in the minor 0.8 percent forecasted reduction. Alternative 2: While not the most aggressive alternative considered for tier pricing and tier size compression, at a projected 6.8 percent reduction, this alternative is projected to be effective in reducing inefficient and excessive outdoor consumption without unnecessary limitations to outdoor water use. • Tier 1: Like Alternative 1, Alternative 2 defines essential use at consumption up to 6 CCF, less than the current structure. This savings is reflected in the decreased rate of $2.40 per CCF. • Tier 2: This tier is sized to accurately reflect the typical responsible outdoor use of 19 CCF. This alternative also provides a greater price signal than the existing structure or Alternative 1, with an increase factor of 1.35 ($3.24/$2.40) over Tier 1. • Tier 3: Alternative 2 is projected to have a more effective conservation structure due to its differentiation between inefficient and excessive water use. Tier 3 sizing of 30 CCF appears to provide a sufficient volume of outdoor use and provides an increase factor of 1.40 ($4.54/$3.24) over Tier 2. • Tier 4: Excessive use under Alternative 2 is defined as all use over 55 CCF (6+19+30). With this 4th tier and an increase factor of 1.50 ($6.81/$4.54), this alternative sends a much stronger price signal for excessive use as compared to Existing and Alternative 1. Alternative 3: Alternative 3 was the most aggressive conservation rate structure considered with regard to tier pricing steps and tier compression. While Alterative 3 has a greater forecasted reduction than Alternatives 1 and 2, it does not appear to be significantly more effective than Alternative 2. In comparison to Alternative 2, Alternative 3 reduces the Tier 3 size by 9 CCF, while only improving the expected consumption reduction by 0.6 percent, as indicated in Chart 3. • Tier 1: Alternative 3 extends essential water use (Tier 1) to 8 CCF. By expanding volume in the first tier from 6 CCF to 8 CCF, expected water sales in Tier 1 increase by greater than 60 percent, while flow in Tiers 2 and 3 are expected to decrease by 50 and 30 percent, respectively. The reduction in water sales at the higher Tier 2 and Tier 3 rates would force a higher rate at Tier 1 as compared to Alternative 1 and 2, directly impacting essential water use pricing. • Tier 2: Similar to Alternatives 1 and 2, Alternative 3 Tier 2 sizing is established at 19 CCF. This alternative has the highest Tier 2 increase factor at 1.40 ($3.57/$2.55). This tier covers up to 27 CCF rather than the 25 CCF as found in Alternatives 1 and 2 due to the expanded size of Tier 1. • Tier 3: Alternative 3 limits the inefficient water use (Tier 3) to 46 CCF, in comparison to the Alternative 2 cap of 55 CCF. As stated, this creates the most significant compression of the Tiers 1-3 for any of the alternatives considered, which as a result creates the highest pricing required of any alternative in Tiers 1-3. • Tier 4: The rate for this tier sends the same price signal as the Alternative 2 pricing step for excessive outdoor use with the increase factor of 1.50 ($7.76/$5.18). 196 Policy Issue #1: Conservation-Based Residential Water Rates 6 EFFECT OF POLICY CHANGE ON RATES AND AFFORDABILITY As noted, a key consideration in the determination of the preferred rate structure alternative is the affordability and expected impacts over existing rates. Table 3 shows the average monthly charge to a typical single family residential customer using the alternative rate tiers and calculating the percentage change from the City’s existing rates at varying levels of usage. The table is constructed to demonstrate the anticipated change in typical Single Family residential customer’s monthly bill based on winter, summer, and annual usage under each alternative. TABLE 3: ESTIMATED MONTHLY CHARGES – SINGLE FAMILY RESIDENTIAL CUSTOMER 4.67 CCF 19.3 CCF 129.19 CCF Winter Average Summer Average Annual Average At Existing Rates $27.61 $69.28 $539.67 Alternative 1 Rates $26.91 $70.00 $538.36 % Change from Existing -2.50% 1.00% -0.24% Alternative 2 Rates $26.91 $73.19 $554.32 % Change from Existing -2.50% 5.60% 2.71% Alternative 3 Rates $27.61 $76.44 $575.46 % Change from Existing 0.00% 10.30% 6.63% 197 Policy Issue #1: Conservation-Based Residential Water Rates 7 PRELIMINARY RECOMMENDATIONS Pending feedback from the Commission, based on the conservation goals and considerations discussed herein, Alternative 2 is the recommended approach of the Study team at this time. A TIER 1 VOLUME OF 6 CCF IS RECOMMENDED As noted previously, the average residential winter water use per account is 4.67 CCF. When reviewing the data at a winter consumption level of 6 CCF, over 80 percent of all standard single family residential bills and 90 percent of all low income residential bills were found to use less than this amount during this season of negligible outdoor consumption. TIER 2 VOLUME OF 19 CCF IS RECOMMENDED Analysis of local evapotranspiration (the sum of precipitation and plant water lost to solar radiation), average single family residential lot size, average single family residential pervious area, and single family residential water use data by City Staff determined a prudent lawn watering value to be 19.0 CCF. TIER 3 VOLUME OF 30 CCF AND TIER 4 VOLUME EQUAL TO ALL USE IN EXCESS OF TIER 3 IS RECOMMENDED It is recommended that the new rate structure utilize four tiers to allow aggressive incentives to reduce consumption for those users in great exceedance of recommended watering practices. Based on local data, City Staff calculated a monthly water volume equivalent to twice the peak monthly water required (49 CCF = Tier 2 + Tier3) to irrigate an average property size, accounting for evapotranspiration. COMMISSION FEEDBACK REQUESTED The City Commission is requested to provide feedback on the alternatives presented while considering the following: 1. Should Tier 1 be limited to primarily essential water use (6 CCF) or include some element of minor outdoor consumption (8 CCF)? 2. Does the Commission agree that primary outdoor use tiers (2nd and 3rd Tier) be established based on typical/peak Single Family residential watering needs? 3. Should the rate structure include an excessive outdoor water use tier (4th tier)? 4. Are there any concerns with the price step factors between tiers (see Table 1)? 198 Policy Issue #2: Drought Surcharge Rates and Drought Reserve Funding 1 POLICY ISSUE #2: DROUGHT SURCHARGE RATES AND DROUGHT RESERVE FUNDING KEY DRIVERS The DMP ultimately recommended a 4-stage drought response plan with defined system-wide water reduction targets. Table 1 below summarizes the stages and associated targets at each stage: In short, the recommended responses are as follows: Per the recommendations of the DMP, the City is considering the development of drought rates and reserves in order to address these vulnerabilities and to ensure the financial stability of the water utility in the event of a drought. The drought rates and reserve are contemplated to serve two key functions: reducing water use in times of drought and maintaining adequate revenues without extreme rate increases once water use is reduced. Stage 1 – Drought Watch asks for increased communication on dry conditions; Stage 2 – Drought Advisory implements mandatory watering restrictions; Stage 3 – Drought Warning prohibits lawn watering; and Stage 4 – Drought Emergency rations water supplies for essential uses. In 2017 the City of Bozeman (City) completed its Drought Management Plan (DMP), outlining the City’s vulnerability to drought, describing ways to mitigate that vulnerability, and providing a drought response strategy. The DMP outlines the City’s drought related characteristics below: “Chronic drought is a part of the Gallatin Valley’s history and is of particular concern to the City of Bozeman as the City has experienced rapid growth in recent decades. The impact of drought on Bozeman is further compounded by its location in the headwaters of the Gallatin River watershed, the susceptibility of the City’s source waters to drought conditions, and limited water storage.” TABLE 1: DROUGHT RESPONSE PLAN TARGETS Drought Stage Stage 1: Drought Watch Stage 2: Drought Advisory Stage 3: Drought Warning Stage 3: Drought Emergency System-Wide Water Reduction Target 10% 20% 30% 40% 199 Policy Issue #2: Drought Surcharge Rates and Drought Reserve Funding 2 OPTIONS FOR CONSIDERATION Drought surcharge rates and drought reserves work hand-in-hand for drought management and the City should consider utilizing both financial tools when planning for a drought scenario. Those unfamiliar with drought management planning may ask “Why is funding a drought reserve with near-term increases necessary? Can’t the City just raise rates during a drought?” The key to a successful drought management financial plan is a balanced integration of drought surcharge rates during a drought and the funding of a drought reserve with near term regular rate increases before the drought occurs. To analyze the options for establishing drought rates and a drought reserve, the project team analyzed potential drought rate structures, the framework of a drought reserve, and the mechanisms for funding the reserve with near-term increases. Before adopting either the rates or the reserve target, policy direction from the City Commission is desired in a number of key areas: THERE ARE TWO KEY REASONS THAT SURCHARGING RATES DURING DROUGHT ALONE MAY NOT BE THE BEST APPROACH TO COVER LOST REVENUE IN THE EVENT OF A DROUGHT: 1. If the City were to surcharge rates to cover all anticipated lost revenues in the event of a Stage 3 drought, Single Family volumetric rates are projected to require an increase of nearly 186 percent. The effects of an increase of this nature would likely cause further instability and potential for further revenue loss. 2. Additionally, the required rate increase will cause significant affordability issues. In the scenario described above, low- volume essential use and low-income user’s costs are expected to see increases of nearly 80 percent. FIGURE 1: THE RELATIONSHIP BETWEEN DROUGHT SURCHARGES AND DROUGHT RESERVE FUNDING Higher Drought Surcharges Increase During Drought Lower Near-Term Rate Increases for Drought Reserve Funding DROUGHT SURCHARGE RATES: • Drought Rate Structure Design • Maximum Rate Increase Targets for Drought Pricing on Essential Use • The Relationship Between the Drought Reserve and Drought Rates DROUGHT RESERVE FUNDING: • Target Drought Reserve Balance and Reserve Funding Timeframe • Near-term Rate Increase strategy for Funding the Drought Reserve 200 Policy Issue #2: Drought Surcharge Rates and Drought Reserve Funding 3 ANALYSIS OF OPTIONS | DROUGHT SURCHARGE RATE DROUGHT RATE STRUCTURE DESIGN The primary goal of a drought rate structure is to encourage conservation through increased rates in the event of a drought and to supplement lost revenue from watering restrictions. Drought rates are different from the regular rate structures for water service in that they are temporary in nature. When considering the design of drought rates, it is common practice to tie the drought declaration/ stage to the criteria for implementing and removing drought rates. As described in the DMP, the following guiding principles are key considerations in the implementation of drought rates: • There should be a clear relationship between price and demand. • Drought rates should not be used alone but should be incorporated into an overall program to increase customer awareness of the drought’s severity and importance of saving water. • Drought rate pricing signals should be developed in a manner that carefully considers the cost of water for essential uses. • Drought rates should match the severity of the drought and drought response measures. • Public information is important in helping customers understand drought rates. In order to achieve the objectives of these guiding principles, the project team developed and analyzed the potential effectiveness of a class-based volumetric surcharge. A class-based volumetric surcharge incorporates an increasing block surcharge tied to the varying reduction abilities of each user class. This method is often considered a more effective drought surcharge when compared to other surcharge alternatives available such as a common fixed charge increase or an equivalent volumetric surcharge for all customers. A key consideration in the development of a class-based volumetric surcharge structure is the ability of each class to reduce non- essential water use. In order to determine the total water use reduction potential by class, the project team reviewed detailed winter vs. summer water use records. Table 2 shows the estimated maximum outdoor water use reduction potential for each class based on this review of winter vs. summer consumption for each class. In reviewing the outdoor water use reduction potential for each class, it is important to note that there is varied potential in each class to reduce use in times of drought. The Single Family Residential and Government classes display the largest potential to reduce water use by eliminating a majority of outdoor watering practices as required in times of a Stage 3-Drought Warning and a Stage 4-Drought Emergency. It is also important to note the difficulty in estimating reduction potential for MSU given the seasonal fluctuation in student 1. Is the proposed drought surcharge rate structure in line with Commission policy objective? 2. Should drought surcharges be capped? 3. What are the surcharge rate cap goals? KEY POLICY QUESTIONS ASSOCIATED WITH DROUGHT SURCHARGE RATES INCLUDE: TABLE 2: ESTIMATED MAXIMUM WATER USE REDUCTION POTENTIAL ON NON-ESSENTIAL OUTDOOR USE TOTAL Single Family and Low Income Residential 50% Multi-Family Residential 16.% Government 54% MSU 14% Commercial 28% Industrial <5% Total System-wide for all Classes 33% 201 Policy Issue #2: Drought Surcharge Rates and Drought Reserve Funding 4 population (i.e. student population declines when outdoor use increases in the summer). Lastly, in reviewing the usage demands for Industrial, there appears to be insignificant outdoor water use, and therefore a minor ability to reduce water demands without affecting day-to-day business practices. In reviewing the total system-wide reduction potential indicated in Table 2, another key consideration is that even with the elimination of all estimated outdoor water consumption, the overall estimated reduction does not achieve a target of 40% for a Stage 4 Drought Emergency. Therefore, in order to achieve these target reductions, the specific actions by Stage and Class as indicated in the Drought Response Measures section within the DMP would be required across all customer classes to achieve total reduction targets. Considering estimated reduction potential by class on outdoor water use restrictions/additional reduction potential to be achieved from targeted Drought Response Measures, the project team developed reduction targets by Class and Stage as presented in Table 3 to achieve the total Stage Reduction Targets. Considering the reduction targets by class and the guiding principles as outlined in the City’s DMP, the proposed drought surcharge rate structure presented in Table 4 was developed to align with the following surcharge pricing goals: • Surcharge Pricing Goal #1: Drought rate pricing signals should be developed in a manner that carefully considers the cost of water for essential uses. • Surcharge Pricing Goal #2: Drought rates should match the severity of the drought and drought response measures. Specifically, Tiers 2-4 are significantly increased to penalize outdoor water use after the lawn water ban is established in Stage 3 and Stage 4 droughts. • Surcharge Pricing Goal #3: Drought rates should be established to replace, as much as possible, the anticipated revenue lost from water use reduction in each class. TABLE 3: WATER USE REDUCTION TARGETS BY STAGE AND CLASS STAGE 1 STAGE 2 STAGE 3 STAGE 4 Single Family and Low Income Residential 10.0% 20.0% 50.0% 55.0% Multi-Family Residential 10.0% 16.0% 16.0% 26.0% Government 10.0% 20.0% 55.0% 60.0% MSU 10.0% 14.0% 14.0% 24.0% Commercial 10.0% 20.0% 27.0% 36.0% Industrial 10.0% 10.0% 10.0% 20.0% Estimated Overall Reduction 10.0% 18.4% 33.0% 40.4% Stage Reduction Target 10.0% 20% 30% 40% TABLE 4: TARGET RATE INCREASES BY STAGE AND CLASS Single Family and Low Income Residential Tier 1 0.0% 10.0% 20.0% 25.0% Tier 2 10.8% 29.0% 100.0% 200.0% Tier 3 10.8% 29.1% 100.0% 200.0% Tier 4 10.8% 29.1% 100.0% 200.0% Multi-Family Residential 11.1% 19.0% 19.0% 25.0% Government 11.1% 25.0% 25.0% 25.0% MSU 11.1% 16.3% 16.3% 25.0% Commercial 11.1% 25.0% 25.0% 25.0% Industrial 11.1% 11.1% 11.1% 11.1% 202 Policy Issue #2: Drought Surcharge Rates and Drought Reserve Funding 5 Table 5 outlines the process used to develop the surcharge increase by class and stage in order to align with the stated pricing goals: TABLE 5: DROUGHT STAGE AND USER CLASS SURCHARGE RATE DESIGN SUMMARY USER CLASS (Estimated Max Reduc- tion from Outdoor Use) PRICING GOAL #1 Essential Use Impacts PRICING GOAL #2 Drought Surcharge Aligned w/Drought Severity PRICING GOAL #3 Replacement of Lost Revenue from Water Sales Reductions Single Family and Low Income Residential (50%) In order to minimize impacts to essential use pricing, the largest increases were applied to Tiers 2-4 for outdoor consumption. In addition, the maximum surcharge was capped at 25% for Tier 1 essential use. Stage 1 and 2 surcharges established in Tiers 2-4 to curb outdoor water use to reduction goal. Stage 3 and Stage 4 surcharges established to eliminate/ significantly penalize all outdoor water use in Tiers 2-4. Stage 1 and 2 surcharges established to replace anticipated lost revenue from water use reduction. Stage 3 and Stage 4 restrictions are expected to result in significant loss in revenue from this class in Tiers 2-4. Additionally, surcharge cap on Tier 1 increase is not high enough to replace all anticipated revenue loss from higher Tier use. Multi-Family (16%) Maximum surcharge is capped at 25% in Stage 4. Stage 1 surcharge established to curb outdoor water use. Stage 2, Stage 3, and Stage 4 surcharges established to eliminated nearly all outdoor use. Stage 1-3 surcharges established to replace lost revenue from water reduction. With water use reduction Policy Issue #2: Drought Surcharge Rates and Drought Reserve Funding 6 MAXIMUM INCREASE TARGET FOR DROUGHT PRICING ON ESSENTIAL USE When considering a maximum increase target, the City should consider the realistic essential use impacts for all classes. When considering Single Family residential users, the financial implication of the contemplated drought surcharge increases for minor consumption and low-income users are significant given that these users are going to be asked to participate in replacing lost revenue from higher consumption users when restrictions are implemented. The City of Bozeman’s essential use per residential user, defined as the average single family residential winter water use per account, is 4.67 CCF. Table 6 below shows a comparison of the current Tier 1 volumetric rate, potential rate increases, and resulting monthly bill required to offset expected revenue losses from a Stage 3 drought. The 186 percent rate increase is included to simulate the required rate increase during a Stage 3 drought if surcharge caps and a drought reserve are not utilized. THE RELATIONSHIP BETWEEN DROUGHT RESERVE AND DROUGHT RATES As indicated in the sections prior, without the presence of surcharge caps and drought reserves to offset revenue loss, the one-time surcharge rate increases and affordability implications are anticipated to be significant. To establish a mechanism to offset these affordability concerns, the project team modeled the use of a drought reserve in combination with the capped surcharge increases for each class. Drought rates and the drought reserve are mutually supporting and an effective drought management plan will utilize both resources in the event of a drought. Droughts may last months, one year, or multiple years and the City will not know the full extent of the drought until it has ended. For that reason, the City should consider the funding of a drought reserve to a target amount ahead of a drought in order to draw upon the reserve in the time of need. In summary of Pricing Goal #3 as discussed in Table 5, the draft surcharges for Stage 1 and Stage 2 are expected to adequately replace anticipated revenue losses. Rate caps prevent most of the customer classes from fully recovering lost revenues during Stage 3 and Stage 4. To maintain financial stability in the face of decreasing revenues during these drought stages, the City should consider establishing a policy identifying target drought reserves and how the reserve should be implemented in the event of a drought. TABLE 6: POTENTIAL SURCHARGE INCREASES IMPACTS ON SINGLE FAMILY TIER 1 ESSENTIAL USE DRAFT SURCHARGE STRUCTURE - IMPACTS BY DROUGHT STAGE STAGE 1 STAGE 2 STAGE 3 STAGE 4 EQUIVALENT ONE-TIME SURCHARGE INCREASE* Fixed Charge $15.70 $15.70 $15.70 $15.70 $15.70 Volumetric Rate $2.55 $2.81 $3.06 $3.19 $7.29 Volumetric Rate Surcharge (%) 0% 10% 20% 25% 186% Monthly Bill @ 4.67 CCF $27.61 $28.80 $29.99 $30.59 $49.76 Monthly Bill Total Increase (%) 0% 4% 9% 11% 80% * Equivalent one-time surcharge represents the total estimated increase on Tier 1 consumption that would be required (absent of a surcharge cap) to replace the revenue lost from Tier 2-4 consumption in the event of a Stage 3 drought. 204 Policy Issue #2: Drought Surcharge Rates and Drought Reserve Funding 7 ANALYSIS OF OPTIONS | DROUGHT RESERVE TARGET DROUGHT RESERVE BALANCE AND RESERVE FUNDING TIMELINE The revenue shortfall analysis completed by the project team estimates that with a 25% surcharge rate cap in place, one year of a Stage 3 drought would create a revenue shortfall of approximately $2.2 million. Table 7 shows the estimated reserve requirements to fund the shortfall created by a Stage 3 or 4 drought with a duration of one to three years. Once the City has established the target reserve balance, it should create a policy for the funding length of time appropriate to fully fund the reserve. When establishing this policy, the City should consider how this will affect user rates and potential risks associated with the selected timeframe. In considering user rate impacts, it should be noted that the rate impacts indicated in Table 8 are separate from those indicated prior for drought surcharges. The rates indicated in Table 8 on the following page are the one-time increases (dependent upon the funding timeframe selected) that would be required on every unit of water sold ahead of a drought in order to accumulate the required reserves and minimize the required drought surcharges. As shown in Table 8, a shorter timeframe will have a more dramatic impact on user rates and may cause an unintended change in consumption. However, the longer the funding timeframe, the higher the risk a drought will occur before the reserve is fully funded. 1. What is the corresponding target level of reserves? 2. What is the timeframe for accumulating the reserves? 3. From which customer classes should the reserves primarily be generated? KEY POLICY QUESTIONS ASSOCIATED WITH THE DROUGHT RESERVE FUNDING INCLUDE: TABLE 7: DROUGHT RESERVE ESTIMATES BY STATE AND DURATION STAGE 3 STAGE 4 1 Year $2,200,092 $2,524,039 2 Year $4,400,184 $5,048,078 3 Year $6,600,276 $7,572,117 205 Policy Issue #2: Drought Surcharge Rates and Drought Reserve Funding 8 DROUGHT RESERVE FUNDING STRATEGY The City should also decide the method used to fund the drought reserve. There are two primary methods for consideration: common volumetric increases across all classes and user class specific increases. For the first method, the City could choose to fund the drought reserve with a volumetric surcharge applied to all units of water. This method is perceived as fair and equitable by users and is relatively simple to implement. Table 8 is an example of the pricing requirements of a common volumetric surcharge on all units of water. The City may also wish to fund the drought reserve through a user class specific surcharge. For example, the Single Family, Government, and Commercial user classes account for a large percentage of the system’s annual non-essential use consumption. The City could decide that these users receive the primary benefit from funding the reserve, as they receive the largest benefit of the reserves accumulated when revenue is lost from these classes after surcharge increase caps are enacted. TABLE 8: RESERVE FUNDING EXAMPLE YEAR TO BUILD RESERVE WATER SALES (CCF) RESERVE TARGET $/CCF 1 Year 2,526,015 $2,200,092 $0.87 2 Years 5,111,225 $2,200,092 $0.43 5 Years 13,236,685 $2,200,092 $0.17 8 Years 21,948,921 $2,200,092 $0.10 10 Years 28,032,673 $2,200,092 $0.08 206 Policy Issue #2: Drought Surcharge Rates and Drought Reserve Funding 9 PRELIMINARY RECOMMENDATIONS It is recommended to consider the following: DROUGHT SURCHARGE: 1. Establishing a class-based volumetric surcharge rate structure with increases as outlined in Table 4; 2. Setting a maximum surcharge increase target for essential use to address potential affordability issues. DROUGHT RESERVE: 1. Creating the reserve and a policy to utilize the drought reserve to offset revenue shortfalls during stage 3 and stage 4 droughts; 2. Establish target reserve level corresponding to the City’s risk tolerance; 3. Setting the drought reserve full funding timeframe also corresponding to the City’s risk tolerance; 4. Funding the drought reserve through a volumetric surcharge to be applied to either all units of water or priced specifically by user class. COMMISSION FEEDBACK REQUESTED Drought Surcharge Policy Feedback: 1. Is the drought surcharge rate structure as proposed in line with Commission policy objectives? 2. Given the potential for significant surcharges in the event of Stage 3-4 drought, does the Commission believe drought surcharges should be capped and to what level? Drought Reserve Policy Feedback: 1. If surcharge caps are desired, should a corresponding drought reserve be funded? 2. What does the Commission believe should be the target reserve balance? 3. How many years is appropriate to accumulate the reserve? 4. Should the reserve be accumulated through a standard volumetric rate increase or a user class increase based on the anticipated benefit of use of the reserves during drought? 207 Policy Issue #3: Reserve Policies and Targets 1 POLICY ISSUE #3: RESERVE POLICIES AND TARGETS KEY DRIVERS OPTIONS FOR CONSIDERATION BASIS FOR THE POLICY DIRECTION SOUGHT OPERATING RESERVE An Operating Reserve is meant to address a system’s cash-flow needs and the lag between expenses incurred and revenues received. Water systems can have wide ranges in operating revenue from month to month depending on the season, while operating expenses are largely fixed and consistent from one month to the next. RENEWAL AND REPLACEMENT (R&R) RESERVE The Renewal and Replacement (R&R) Reserve is a capital reserve intended to meet on-going system renewal/ replacement needs. By consistently funding such a reserve, a system can avoid capital-driven spikes in utility cash flow requirements. DEBT SERVICE RESERVE Debt Service Reserves are typically established based on terms within bond documents. Most debt covenants require the establishment of a restricted reserve based on the highest annual payment. The required reserve amount is held for the life of the loan and can be used to make the final payment. RATE STABILIZATION RESERVE A Rate Stabilization Reserve is established to dampen necessary rate increases in the event of unexpected expenses or decreased revenues. DROUGHT RESERVE Drought Reserves are considered in areas where the water supply is limited, at risk or particularly susceptible to climatic conditions in any given year. Targets for such reserves are system-specific and account for the level of risk acceptable to the utility decision makers. This topic is addressed in a separate paper. Direction given on this topic will be key to establishing final rate strategy recommendations. Reserve management is an important aspect of operating financially sustainable utilities. While the majority of utility costs are fixed and relatively stable from month to month, revenues can fluctuate widely due to seasonality, climate fluctuations, emergencies, or conservation efforts. The City of Bozeman maintains operating and capital reserve accounts for its utilities to manage revenue volatility and avoid spikes in required rate increases. The City has incorporated reserve planning into its budget, capital and rate- planning efforts to periodically evaluate the suitability of reserve funding goals and targets given the near- and long-term revenue needs for the Water and Wastewater systems. 208 Policy Issue #3: Reserve Policies and Targets 2 ANALYSIS OF OPTIONS | WATER SYSTEM OPERATING RESERVE The American Water Works Association (AWWA) recommends a minimum operating reserve balance equal to 45 days of operating and maintenance (O&M) expenses. It is common, however, for utilities to set reserve targets ranging from 90 and 180 days. The City’s operating reserve currently has a target balance of 45 days. Due to successful conservation efforts, the City of Bozeman has seen decreasing water use, yet continues to have high summer water demands. This variability results in greater than 50 percent of water revenue generation occurring in the months of June through October, with less than seven percent monthly in the remaining months. Due to on-going conservation efforts and the potential for further reductions in water use, recommendations from the 2018 study include adoption of an operating reserve target equal to 90 days of O&M expense. Table 1 shows the target operating reserve balance from 2019 to 2024. RENEWAL AND REPLACEMENT RESERVE An industry rule of thumb suggests that, at a minimum, systems should set aside funds in reserves annually in an amount equal at least to annual depreciation. This is the current approach used by the City. Depreciation, however, is known to be inadequate in terms of providing future replacement of assets. As a result, it is suggested that systems consider the Replacement Cost New (RCN) when determining reserve targets and annual contributions. A third approach involves analysis using a Weibull distribution to estimate the remaining lifespan of system pipelines and calculate projected annual reinvestment needs. For the purpose of this study, the third method was utilized to estimate necessary R&R pipeline reserve contributions for 2019 to 2024. In addition, adjusted depreciation values were used to estimate the annual replacement needs for vertical assets. Once the annual contributions were established, planned additions to the asset base through rate-funded capital and debt service principal payments were subtracted from the annual estimated renewal needs to correct for investments/reinvestments being made to the system. Table 2 summarizes the planning level values used to project revenue adequacy and the need for future revenue increases under this approach. Due to significant debt obligations, additional contributions to capital reserve were not projected for 2020 through 2024. This indicates the City is annually making a prudent level of investment in its system. TABLE 1: ESTIMATED WATER OPERATING RESERVE BALANCE (2019-2024) 2019 2020 2021 2022 2023 2024 Operating Reserve (Water Enterprise Fund) $1,590,159 $1,652,124 $1,716,863 $1,784,506 $1,855,188 $1,919,192 TABLE 2: APPROACH TO WATER R&R RESERVE PLANNING (2019-2024) 2019 2020 2021 2022 2023 2024 Adjusted Depreciation (Facilities) $2,421,007 $2,493,637 $2,728,446 $3,276,966 $3,375,275 $3,476,534 + Forecasted Renewal and Replacement (Pipelines) $202,361 $272,229 $272,229 $272,229 $272,229 $272,230 = Total Forecasted Reinvestment $2,623,368 $2,765,866 $3,000,675 $3,549,195 $3,647,504 $3,748,763 - Rate-Funded CIP $980,273 $2,017,226 $2,114,886 $1,603,041 $1,655,232 $1,570,506 - DS Principal $1,175,873 $1,209,470 $1,429,027 $2,140,405 $2,268,488 $2,484,239 = Additional Capital Contribution $467,222 $ - $ - $ - $ - $ - 209 Policy Issue #3: Reserve Policies and Targets 3 Debt Service Reserve The City manages its water debt service reserve fund in accordance with requirements within the bond covenants. No policy changes are required due to the specificity of the reserve levels stipulated within the bond covenants. Table 3 summarizes the estimated debt service reserve balances required from 2019 to 2024. Rate Stabilization Reserve A utility can fund the rate stabilization reserve by allocating available surplus or a specific portion of net revenues. The City has not yet established a rate stabilization reserve; however, the reserve is recommended and has been incorporated into the preliminary increase strategy established in Policy Paper #4 – Cost of Service-Based Rate Setting. Note that given other reserve considerations facing the Water Utility, at this time a specific target level for rate stabilization was not recommended to avoid potentially increasing rate revenue requirements to fund multiple reserves at once. In the absence of adoption and implementation of drought contingency reserve goals, it is suggested that the City revisit the rate stabilization concept to develop a target. It is common to set a target for such a reserve based on the amount of revenue need to offset a specified percentage rate increase (ranging two to 10 percent) or a value equal to some percentage of annual rate-funded capital. TABLE 3: ESTIMATED WATER DEBT SERVICE RESERVE BALANCE (2019-2024) 2019 2020 2021 2022 2023 2024 Bond Reserve Fund $1,774,060 $2,114,661 $3,403,798 $3,531,426 $3,810,789 $4,271,806 Bond Reserve Target $1,774,060 $2,114,661 $3,403,798 $3,531,426 $3,810,789 $4,271,806 Bond Reserve Target Met? Yes Yes Yes Yes Yes Yes 210 Policy Issue #3: Reserve Policies and Targets 4 ANALYSIS OF OPTIONS | WASTEWATER SYSTEM OPERATING RESERVE The AWWA recommends a minimum operating reserve balance equal to 45 days of operating and maintenance (O&M) expenses. While wastewater revenues are often not as volatile as water system revenues, it is still very common to see wastewater operating reserve targets ranging from 60 to 180 days of O&M expense. To provide consistent goals for the Water and Wastewater utilities, an operating reserve target equal to 90 days of O&M expense is recommended. Table 4 shows the target operating reserve balance from 2019 to 2024. RENEWAL AND REPLACEMENT RESERVE The City currently sets reserves based on annual depreciation. For the purpose of this study and similar to the approach for the Water Utility, a Weibull analysis was utilized to estimate necessary R&R pipeline reserve contributions for 2019 to 2024. In addition, adjusted depreciation values were used to estimate the annual replacement needs for vertical Wastewater Utility assets (Facilities). Once the annual contributions were established, the required additional capital contributions were calculated by subtracting planned additions to the asset base through rate-funded capital and debt service principal payments from the annual estimated renewal needs to correct for investments/reinvestments being made to the system. Table 5 summarizes the projected annual pipeline reinvestment needs, along with adjusted depreciation values for the facilities to estimate necessary R&R reserve contributions for 2019 to 2024. Rate-funded capital from the capital improvements plan and debt service principal was subtracted from the total annual reinvestment estimates to calculate an annual contribution to Wastewater reserves that can be drawn upon for future capital investment needs. TABLE 5: APPROACH TO WASTEWATER R&R RESERVE PLANNING (2019-2024) 2019 2020 2021 2022 2023 2024 Adjusted Depreciation (Facilities) $3,041,025 $3,132,255 $3,226,223 $3,323,010 $3,422,700 $3,525,381 + Forecasted Renewal and Replacement (Weibull Analysis) $639,210 $892,859 $892,859 $892,859 $892,859 $892,859 = Total Forecasted Reinvestment $3,680,235 $4,025,114 $4,119,082 $4,215,869 $4,315,559 $4,418,240 - Rate-Funded CIP $1,969,875 $1,784,964 $1,854,904 $1,353,424 $1,370,842 $1,638,837 - DS Principal $1,576,880 $1,612,880 $1,916,759 $1,954,759 $1,992,759 $2,391,474 = Additional Capital Contribution $133,480 $627,270 $347,419 $907,685 $951,958 $387,929 TABLE 4: ESTIMATED WASTEWATER OPERATING RESERVE BALANCE (2019-2024) 2019 2020 2021 2022 2023 2024 Operating Reserve $1,566,534 $1,644,861 $1,727,104 $1,813,459 $1,904,132 $1,980,297 211 Policy Issue #3: Reserve Policies and Targets 5 Debt Service Reserve No major policy changes are required due to the specificity of the reserve levels stipulated within the bond covenants. Table 6 shows the estimated debt service reserve balances required from 2019 to 2024. Rate Stabilization Reserve Beyond funding the Operating, R&R, and Debt Service reserves, it is recommended that the City identify a Rate Stabilization reserve that can be used to dampen unanticipated rate increases and/or fund unplanned capital needs. The City has not yet established a rate stabilization reserve; however, the reserve is recommended and has been incorporated into the preliminary increase strategy established in Policy Paper #4 – Cost of Service-Based Rate Setting. It is common to set a target for such a reserve based on the amount of revenue need to offset a specified percentage rate increase (ranging two to 10 percent) or a value equal to some percentage of annual rate-funded capital. For the purpose of this study, a specific target value has not been identified. To avoid increasing rate revenue requirements simply for the purpose of funding a reserve account but to have some guideline for funding level, the City could consider a minimum balance within the range of $300,000 to $600,000, which correlate to approximately five to 10 percent increases on the volumetric rate. TABLE 6: ESTIMATED WASTEWATER DEBT SERVICE RESERVE BALANCE (2019-2024) 2019 2020 2021 2022 2023 2024 Bond Reserve Fund $1,788,592 $1,788,592 $1,788,592 $1,788,592 1,788,592 $1,788,592 Bond Reserve Target $1,788,592 $1,788,592 $1,788,592 $1,788,592 $1,788,592 $1,788,592 Bond Reserve Target Met? Yes Yes Yes Yes Yes Yes 212 Policy Issue #3: Reserve Policies and Targets 6 PRELIMINARY RECOMMENDATIONS Tables 7 and 8 outline the recommended Water and Wastewater reserve policies, pending Commission feedback. TABLE 7: RECOMMENDED WATER RESERVE POLICIES AND TARGETS RESERVE TARGET/POLICY TARGET Operating Reserve 90 days of O&M Expense $1,590,000 (Year 1 Target) Renewal & Replacement 5-Year Target based on Projected Renewal Deficiency $668,000 (2024 Target) Debt Service Reserve 1-Year Total Payment per Bond Covenants $1,774,000 (Year 1 Target) Rate Stabilization Reserve Floating Target based on Capital Needs or Offset to X% Rate Increase To Be Determined from Final Rate Modeling Drought Contingency Reserve Discussed in a separate policy paper Dependent on Policies established TABLE 8: RECOMMENDED WASTEWATER RESERVE POLICIES AND TARGETS RESERVE TARGET/POLICY TARGET Operating Reserve 90 days of O&M Expense $1,567,000 (Year 1 Target) Renewal & Replacement 5-Year Target based on Projected Renewal Deficiency $3,356,000 (2024 Target) Debt Service Reserve 1-Year Total Payment per Bond Covenants $1,789,000 (Year 1 Target) Rate Stabilization Reserve Floating Target based on Cash Funded Capital Needs or Offset to X% Rate Increase To Be Determined from Final Rate Modeling COMMISSION FEEDBACK REQUESTED 1. Given the current approach to funding Operating and Debt Reserves, does the Commission have a desire to better define policy to include Renewal & Replacement, Rate Stabilization, and Drought Contingency Reserves? 2. If the Commission desires to set policy for and develop any of these additional Reserves, are the preliminarily proposed targets appropriate for planning purposes? NEXT STEPS If the Commission agrees to establish any Renewal & Replacement, Rate Stabilization, and/or Drought Reserves and establishes planning level targets, the project team will incorporate those parameters into the rate models and provide rate strategies for the City to meeting the financial objectives of the Water and Wastewater Utilities. 213 Policy Issue #4: Cost of Service-Based Rate Setting | Water and Wastewater 1 POLICY ISSUE #4: COST OF SERVICE-BASED RATE SETTING | WATER AND WASTEWATER KEY DRIVERS APPROACH The City of Bozeman strives to follow the Industry Standard practice of establishing a fair and equitable rate structure designed to generate revenue from each class that is commensurate with the cost to serve each class. The City of Bozeman provides water and wastewater service to residential and commercial user classes, Montana State University (MSU), and an industrial customer. The City is undergoing a period of rapid growth and is planning to ensure continued equitability to customers through all stages of this growth period. To assist City leaders in managing the City’s water resources and water infrastructure, ensure overall financial health of the utilities, and to maintain fair and equitable rate structures for water and wastewater services, the City completed a comprehensive Water and Wastewater Rate Study. Related to the Water Utility in particular, the City is considering enhancing its existing conservation rate structure, adopting a drought surcharge, and funding a drought reserve to further address resource management and system readiness in the face of water scarcity. These topics will be addressed in separate policy papers. FIGURE 1: COSA METHODOLOGY FUNCTIONALIZATION Functionalize Budget into Primary Categories of Service Classify Costs of Primary Budget Categories Based on Causative Elements Allocate Costs to Specific User Classes CLASSIFICATION ALLOCATION A Cost of Service Analysis (COSA) is typically completed periodically to address changes in service requirements, revenue requirements, operational practices, system expansion/modification, and other objectives as they relate to how the user classes drive cost. A graphic depicting an industry-standard approach to COSA is shown in Figure 1. 214 Policy Issue #4: Cost of Service-Based Rate Setting | Water and Wastewater 2 The methodology involves development of typical Test Year revenue requirements (operation and maintenance expenses and capital expenditures), as well as the review by class of account numbers, average and peak flows, irrigation demand (for the Water Utility), and strength values (for the Wastewater Utility) from a year of typical operations. Test Year costs are then evaluated in terms of system function and are ultimately allocated to each user class based on number of accounts, average and maximum flow, and strength contributions (in the case of Wastewater). The resulting allocated costs are then compared to revenue generated by each class, on a percentage basis, to assess the equitability of the rate structure. The results of the 2018 Water and Wastewater analyses are shown in Tables 1 and 2, respectively. The values in Tables 1 and 2 were derived based on the 2018 budget, a five-year average of rate-funded capital, and 2017 user accounts, flow values, and flow characteristics (for Wastewater). The percent difference columns in Tables 1 and 2 are calculated as the revenue percentage minus the cost percentage, divided by the cost percentage. A percent difference within +/- 10 percent is generally considered to be within an acceptable range. A percent difference outside of +/- 10 percent indicates that revisions to the rates and/or structure should be considered to improve overall equitability. TABLE 1: 2018 WATER COSA RESULTS CUSTOMER CLASS % OF COST % OF REVENUE % DIFFERENCE Single Family/Low Income Residential 49.8% 53.0% +6.3% Multi-Family Residential 20.0% 20.3% +1.5% Government 3.1% 1.8% -40.2% MSU 6.0% 6.0% +0.6% Commercial 20.1% 16.0% -20.2% Industrial 0.5% 0.6% +23.6% City Park Irrigation 0.7% 0.5% -30.9% Total 100% 100% TABLE 2: 2018 WASTEWATER COSA RESULTS CUSTOMER CLASS % OF COST % OF REVENUE % DIFFERENCE Single Family Residential 36.3% 41.7% +15.0% Multi-Family Residential 24.4% 23.5% -3.6% Commercial 25.4% 22.5% -11.3% Government 1.3% 1.2% -8.9% MSU 10.3% 8.3% -19.7% Industrial 2.3% 2.8% +19.8% Total 100% 100% 215 Policy Issue #4: Cost of Service-Based Rate Setting | Water and Wastewater 3 POLICY ISSUES TO ADDRESS | WATER The results of the Water COSA indicate that, based on the assumptions in this analysis, there is some disparity between the user classes under the existing rate configuration. In particular, on a percentage basis: • The Government class is contributing revenue sizably less than its cost; • The Commercial class is contributing revenue less than its cost; • The Industrial class is contributing revenue greater than its cost; and • The City Park Irrigation class is contributing revenue less than its cost. It should be noted that the results of this analysis regarding differences by class are relatively consistent with the last Cost of Service analysis performed for the City in 2008. Therefore, the key policy issue to address by the City Commission is in regard to the approach for correcting and establishing cost-based Water rates into the future. POLICY ISSUES TO ADDRESS | WASTEWATER The results of the Wastewater COSA indicate that, based on the assumptions in this analysis, there is some disparity between the user classes under the existing rate configuration. In particular, on a percentage basis: • The Single Family Residential class is contributing revenue slightly greater than its target cost; • The Commercial class is contributing revenue slightly less than its target cost; • The MSU class is contributing revenue less than its target cost; and • The Industrial class is contributing revenue greater than its target cost. The key policy issue to address by the City Commission is in regard to what approach, if any, should be taken to correct and establish cost-based Wastewater rates into the future. OPTIONS FOR CONSIDERATION | WATER The Water COSA results showed that Government, Commercial, and City Park Irrigation user classes are contributing revenue at a level less than their associated costs of service. The Industrial user class is contributing revenue at a level greater than its associated cost of service. To correct cost of service inequities moving forward, the City should consider user class-specific adjustments to the volumetric rates. Table 3 illustrates how the rate adjustments by class can work toward cost of service correction and Table 4 shows the resulting Water cost of service percentage differentials associated with the rates in Table 3. Boxes shaded in green highlight when the cost of service for the user class is projected to fall within the goal of +/-10 percent. TABLE 3: COST OF SERVICE CORRECTIVE VOLUMETRIC RATES - WATER 2019 2020 2021 2022 2023 USER CLASS $/CCF $/CCF $/CCF $/CCF $/CCF Single Family/Low Income Residential Tier 1 $2.68 $2.40 $2.40 $2.40 $2.40 Tier 2 $2.89 $3.27 $3.30 $3.33 $3.36 Tier 3 $3.40 $4.59 $4.64 $4.69 $4.74 Tier 4 $ - $6.88 $6.95 $7.02 $7.09 Multi-Family Residential $2.06 $2.10 $2.14 $2.18 $2.22 Commercial $1.81 $1.95 $2.07 $2.19 $2.32 Government $1.87 $2.02 $2.14 $2.27 $2.41 MSU $2.33 $2.42 $2.52 $2.57 $2.62 Industrial $1.81 $1.81 $1.81 $1.81 $1.81 CFF = ONE HUNDRED CUBIC FEET 216 Policy Issue #4: Cost of Service-Based Rate Setting | Water and Wastewater 4 IT IS IMPORTANT TO NOTE THE FOLLOWING WHEN REVIEWING THE RATE ILLUSTRATIONS RESULTS IN TABLES 3 AND 4: • The forecasted increases are developed in consideration of meeting the projected future rate revenue requirements of the Water Utility over the next five years. These revenue requirements may vary based on decisions the Commission may make with this study and into the future regarding operations, maintenance, capital improvements, and reserve funding levels. If changes are made to the rate revenue requirements, up or down, a revised increase by class adjustment strategy would likely be required. • Single Family Residential: The jump in cost of service differential shown in 2020 is largely related to increase in revenue expected from the draft revised conservation-based rate structure. If the Commission requests changes to the tiered pricing strategy of this structure (see Conservation rate structure policy paper), this will affect the projected cost of service targets for this class. • Multi-Family Residential: Given the increases in projected revenue requirements that are expected to largely be covered by increased rate revenue from the residential class (with adjustments to the tiered rate structure), the Multi-Family cost of service differential is corrected downward to target with minimal projected adjustment to the volumetric rate for this class into the future. • Commercial: The commercial class was shown to have a relatively high seasonal water use peaking factor. This high peaking factor on the system resulted in higher allocation of peak demand-related cost for this user class. The results of the COSA for this class seem reasonable when taking into consideration the relatively low volumetric rate paid on all seasonal peak consumption. Currently the commercial class only pays $1.81 per one hundred cubic feet (CCF) versus $2.89/CCF and greater in the residential class for pricing in the upper tiers. • Government: The cost of service results for this class were similar to the Commercial class, but with a greater differential due to higher seasonal peak demands. Currently the Government class pays $1.87/CCF versus $2.89/CCF and greater in the residential class. Cost of service for this class will be difficult to correct without significant one-time adjustments. • MSU: Similar to Multi-Family Residential, increased rate revenue from the residential class is driving down the cost of service differential and requiring minimal projected adjustment to the volumetric rate for this class into the future. • Industrial: The cost of service results for this class are driven largely by relatively steady year-round demands. Cost of service is shown to be correctable in the next three years by maintaining the existing volumetric rate for this user across the modeled period. TABLE 4: WATER COST OF SERVICE % DIFFERENTIAL USER CLASS 2019 2020 2021 2022 2023 Single Family/Low Income Residential +2.9% +12.0% +11.0% +10.1% +9.2% Multi-Family +10.9% -1.3% -1.1% -0.7% -0.4% Government -40.8% -45.2% -44.7% -44.1% -43.5% MSU +7.5% -2.9% -3.2% -5.2% -7.2% Commercial -14.8% -21.1% -18.7% -16.3% -13.8% Industrial +30.8% +14.1% +11.5% +9.1% +6.7% 217 Policy Issue #4: Cost of Service-Based Rate Setting | Water and Wastewater 5 OPTIONS FOR CONSIDERATION | WASTEWATER The Wastewater COSA results showed that, with the exception of the Single Family Residential user class, each non-industrial user class is contributing revenue at a level less than its associated cost of service. As of 2018, the Multi-Family Residential, Commercial, Government, and MSU user classes were subject to the same volumetric charge for wastewater flow. To correct cost of service inequities moving forward, these user classes would need to have class-specific volumetric rates. Table 5 illustrates how individualized rates by class can work toward cost of service correction. Table 6 shows the cost of service percentage differentials associated with the rates in Table 5. Boxes shaded in green highlight when the cost of service for the user class is projected to fall within the goal of +/- 10 percent as a result of the cost-based volumetric rate structure changes. TABLE 5: COST OF SERVICE CORRECTIVE VOLUMETRIC RATES - WASTEWATER 2019 2020 2021 2022 2023 USER CLASS $/CCF $/CCF $/CCF $/CCF $/CCF Single Family Residential $3.28 $3.28 $3.28 $3.28 $3.28 Multi-Family Residential $3.36 $3.49 $3.63 $3.78 $3.85 Commercial $3.36 $3.56 $3.77 $4.00 $4.24 Government $3.36 $3.70 $4.06 $4.47 $4.92 MSU $3.36 $3.63 $3.92 $4.23 $4.57 Industrial $5.50 $5.67 $5.83 $6.01 $6.19 Commercial $1.81 $1.95 $2.07 $2.19 $2.32 Government $1.87 $2.02 $2.14 $2.27 $2.41 MSU $2.33 $2.42 $2.52 $2.57 $2.62 Industrial $1.81 $1.81 $1.81 $1.81 $1.81 CFF = ONE HUNDRED CUBIC FEET TABLE 6: WASTEWATER COST OF SERVICE % DIFFERENTIAL USER CLASS 2019 2020 2021 2022 2023 Single Family Residential +18.1% +15.7% +13.3% +10.0% +8.8% Multi-Family Residential -2.7% -2.0% -1.4% -0.7% -1.3% Commercial -13.7% -12.4% -11.1% -9.8% -8.2% Government -21.8% -19.4% -16.9% -14.2% -11.1% MSU -22.6% -18.7% -14.6% -10.5% -5.8% Industrial +4.7% +2.8% +0.8% -0.9% -2.5% 218 Policy Issue #4: Cost of Service-Based Rate Setting | Water and Wastewater 6 IT IS IMPORTANT TO NOTE THE FOLLOWING WHEN REVIEWING THE RATE ILLUSTRATIONS RESULTS IN TABLES 5 AND 6: • The forecasted increases are developed in consideration of meeting the projected future rate revenue requirements of the Wastewater Utility over the next five years. These revenue requirements may vary based on decisions the Commission may make with this study and into the future regarding operations, maintenance, capital improvements, and reserve funding levels. If changes are made to the rate revenue requirements, up or down, a revised increase by class adjustment strategy would likely be required. • Single Family Residential: These differentials are slightly different than those presented for 2018 in Table 2 due to the fact that they are projected for the year 2019 with an across-the-board increase and no change to the rate structure. Under this approach, in 2019 the disparity for this user class becomes even more pronounced. If user class-specific adjustments are implemented in the future, the City can work to bring the revenue percentage for this user class closer to its target. • Multi-Family Residential: The COSA results showed that the rate structure was sufficient to generate revenue from this user class that is in line with its cost of service. As a result, the across-the-board increase adopted in 2019 affects the cost of service relationship for this class very little. If user class-specific adjustments are implemented in the future, the City can hold revenue from this user class in line with its cost by applying minimal increases. • Commercial: Similar to the Water COSA results for this user class, the commercial class was shown to be contributing less than its cost under the existing rate structure. Due to the food service industry-related components of its wastewater stream, one-third of the cost of the Industrial Pretreatment Program (IPP) were allocated to this user class, making the unit cost for wastewater from this user class distinctly different from the Residential classes and the Government class. If a user-class specific approach to rate adjustments is adopted, this class will likely see moderate increases for several years to bring the revenue percentage in line with the cost percentage. • Government: The 2019 COSA differential in Table 6 for this class is noticeably different from the 2018 value in Table 2 due to the across-the-board increase in 2019, which exacerbated what was a slight inequity. This is largely because of the small size of this customer class relative to the other classes. If user class-specific adjustments are implemented in the future, the City can bring revenue from this user class in line with its cost by applying moderate increases. • MSU: One-third of the cost associated with the IPP was allocated to this user class due to the food service-related components of its waste stream, making the unit cost for wastewater from this user class distinctly different from the Residential classes and the Government class. In a addition, due to the large area covered by this user class, Inflow and Infiltration (I/I) flow, which was allocated in part to all user classes based on user connections, was allocated based on sewer shed area. This contributes in part to the cost of service disparity calculated for this class. To most accurately account for I/I flow from MSU, wastewater flow could be metered. In the absence of metering wastewater flow, if a user-class specific approach to rate adjustments is adopted, this class will likely see moderate increases for several years to bring the revenue percentage in line with the cost percentage. • Industrial: The results in Table 2 showed this user class paying more than its associated cost of service by approximately 20 percent. By making cost of service-based adjustments to the volumetric rate and the strength charges (discussed below), the City is able to correct this inequity. 219 Policy Issue #4: Cost of Service-Based Rate Setting | Water and Wastewater 7 INDUSTRIAL COST OF SERVICE AND RATE DESIGN In contrast to the non-industrial users, the Wastewater COSA results indicate the Industrial user class is providing revenue at a percentage that exceeds its cost percentage. Rate design efforts evaluating the cost of strength parameters were completed to determine the appropriate strength charges. The 2018 rate schedule included a separate volume charge for the Industrial user class, as well as charges for pounds of biochemical oxygen demand (BOD), total suspended solids (TSS), Phosphorous, and Nitrogen in excess of domestic limits identified in the rate resolution. As part of the COSA, costs associated with each parameter were identified. In addition, total BOD contributed by all customers, and specifically by the Industrial class, was reviewed to develop a recommended modification to the existing approach to BOD charges. This resulted in a recommendation to Commission in August 2018 for a one-time correction to implement a simplified practice that is consistent with other utilities in the region and with City Ordinance. Table 7 summarizes the August 2018 recommended adjusted rate schedule for high strength parameters. The rates shown in Table 7 reflect the cost associated with each strength component. As a result of anticipated increased strength- related revenue generation from industry resulting from the adjusted rate approach, the flow rate for the industrial user class was also recommended to be reduced in August 2018 as shown previously in Table 5 (to maintain equitability for the industrial user class). TABLE 7: COST OF SERVICE CORRECTIVE HIGH STRENGTH RATES - WASTEWATER 2018 RATE APPROACH 2018 CHARGE PER POUND ($) ADJUSTED RATE APPROACH ADJUSTED CHARGE PER POUND ($) BOD Lbs. of BOD up to 830 lbs./day $0.031 Lbs. of BOD in excess of 250 mg/L $0.33 Lbs. of BOD in excess of 830 lbs./day $0.45 Lbs. of BOD in excess of 830 lbs./day, monthly peak day $0.33 TSS Lbs. of TSS in excess of 350 mg/L $0.30 Lbs. in excess of 350 mg/L $0.51 Phosphorus Lbs. in excess of 5 mg/L $5.05 Lbs. in excess of 5 mg/L $5.55 MG/L = MILLIGRAMS PER LITER 220 Policy Issue #4: Cost of Service-Based Rate Setting | Water and Wastewater 8 PRELIMINARY RECOMMENDATIONS | WATER In September 2018, the Commission adopted the Water Volumetric rates shown in Table 8. It is further recommended that the City annually evaluate projected rate revenues in conjunction with budget and capital planning and consider user class-specific adjustments over time to work toward better equitability between the user classes. Figures 2 and 3 present an example of varied increases and the resulting cost of service relationship over time. Figures 4 and 5 present an approach involving across-the-board increases, resulting in maintaining or exacerbating rate inequities. TABLE 8: ADOPTED VOLUMETRIC RATES | WATER USER CLASS $/CCF Single Family Residential Tier 1: 0-8 CCF $2.68 Tier 2: 8-15 CCF $2.89 Tier 3: 15+ CCF $3.40 Multi-Family Residential $2.06 Government $1.87 MSU $2.33 Commercial $1.81 Industrial $1.81 0.0% 2.0% 4.0% 6.0% 8.0% 10.0% 2019 2020 2021 2022 2023 2024 Monthly Bill at 3 CCF ($) COSA Based User Rate Adjustments Single Family/Low Income Residential Multi Family Residential Commercial Government MSU Industrial Average FIGURE 2: COSA-BASED VARIED WATER VOLUMETRIC RATE ADJUSTMENTS CFF = ONE HUNDRED CUBIC FEET 221 Policy Issue #4: Cost of Service-Based Rate Setting | Water and Wastewater 9 -50.0% -40.0% -30.0% -20.0% -10.0% 0.0% 10.0% 20.0% 30.0% 40.0% 2019 2020 2021 2022 2023 2024 % Difference from COSA Target COSA Target Tracking Single Family/Low Income Residential Multi Family Residential Commercial Government MSU Industrial 0.0% 1.0% 2.0% 3.0% 4.0% 5.0% 6.0% 2019 2020 2021 2022 2023 2024 Monthly Bill at 3 CCF ($) COSA Based User Rate Adjustments Single Family/Low Income Residential Multi Family Residential Commercial Government MSU Industrial Average FIGURE 3: COSA-BASED VARIED WATER RATE COSA RESULTS FIGURE 4: ACROSS-THE-BOARD WATER RATE ADJUSTMENTS Target Range +/- 10% 222 Policy Issue #4: Cost of Service-Based Rate Setting | Water and Wastewater 10 -60.0% -50.0% -40.0% -30.0% -20.0% -10.0% 0.0% 10.0% 20.0% 30.0% 40.0% 2019 2020 2021 2022 2023 2024 % Difference from COSA Target COSA Target Tracking Single Family/Low Income Residential Multi Family Residential Commercial Government MSU Industrial FIGURE 5: ACROSS THE BOARD WATER RATE COSA RESULTS Target Range +/- 10% 223 Policy Issue #4: Cost of Service-Based Rate Setting | Water and Wastewater 11 PRELIMINARY RECOMMENDATIONS | WASTEWATER In September 2018, the Commission adopted the volumetric rates shown in Table 9. In addition, updated rates for BOD, TSS, Phosphorus, and Nitrogen were adopted. It is further recommended that the City annually evaluate projected rate revenues in conjunction with budget and capital planning and consider user class-specific adjustments over time to better address equitability between the user classes. Figures 6 and 7 present an example of varied increases and the resulting cost of service relationship. Figures 8 and 9 present an approach if common across the board increases are applied, which is projected to result in maintaining or exacerbating rate inequities. 0.0% 1.0% 2.0% 3.0% 4.0% 5.0% 6.0% 7.0% 8.0% 9.0% 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 COSA Based User Rate Adjustments Residential Multi Family Commercial Government MSU Industrial Average TABLE 9: ADOPTED VOLUMETRIC RATES | WASTEWATER USER CLASS $/CCF Single Family Residential $3.28 Multi-Family Residential $3.36 Commercial $3.36 Government $3.36 MSU $3.36 Industrial $5.50 FIGURE 6: COSA-BASED VARIED WASTEWATER RATE ADJUSTMENTS CFF = ONE HUNDRED CUBIC FEET 224 Policy Issue #4: Cost of Service-Based Rate Setting | Water and Wastewater 12 0.0% 0.5% 1.0% 1.5% 2.0% 2.5% 3.0% 3.5% 4.0% 4.5% 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 COSA Based User Rate Adjustments Residential Multi Family Commercial Government MSU Industrial Average -25.0% -20.0% -15.0% -10.0% -5.0% 0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 % Difference from COSA Target COSA Target Tracking Single Family Multi Family Commercial Government MSU Industrial FIGURE 7: COSA-BASED VARIED WASTEWATER RATE COSA RESULTS FIGURE 8: ACROSS-THE-BOARD VOLUMETRIC WASTEWATER RATE ADJUSTMENTS Target Range +/- 10% 225 Policy Issue #4: Cost of Service-Based Rate Setting | Water and Wastewater 13 -40.0% -30.0% -20.0% -10.0% 0.0% 10.0% 20.0% 30.0% 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 % Difference from COSA Target COSA Target Tracking Single Family Multi Family Commercial Government MSU Industrial FIGURE 9: ACROSS-THE-BOARD WASTEWATER RATE COSA RESULTS Target Range +/- 10% COMMISSION FEEDBACK REQUESTED Water: 1. Going forward, does the Commission desire to apply user class-specific adjustments to the Water rate structures that will work to generate revenue from each class that is commensurate with the associated cost for each class? 2. If cost of service correction is a priority, how aggressively should it be approached? Wastewater: 1. Going forward, does the Commission desire to apply user class- specific adjustments to the Wastewater rate structures that will work to generate revenue from each class that is commensurate with the associated cost for each class? 1. If cost of service correction is a priority, how aggressively should it be approached? NEXT STEPS Feedback on this topic, as well as the topics of Reserve Funding, Conservation Rates, Drought Rates and Drought Reserves will tie in directly with the Cost of Service-based rate setting approach. Given direction on all of these topics, the project team will provide updated documentation and rate models that will assist the City in moving forward in the manner directed by the Commission. 226 target of 26% by Stage 4, the surcharge cap of 25% prevents full revenue replacement. Government (54%) Maximum surcharge is capped at 25% by Stage 2. Similar to Single-Family Stage 1 and Stage 2 surcharges established to curb outdoor water use to reduction goal and Stage 3 and Stage 4 surcharges established to eliminate nearly all outdoor water use. Stage 1 and 2 surcharges established to replace lost revenue from water reduction. With water use reduction target of 60% by Stage 4, the surcharge cap of 25% prevents full revenue replacement. MSU (14%) Maximum surcharge is capped at 25% in Stage 4. Stage 1 surcharge established to curb outdoor water use to reduction goal. Stage 2, Stage 3, and Stage 4 surcharges established to eliminate outdoor water use. With maximum reduction target of 24%, Stage 1-4 surcharges anticipated to replace all revenue loss (i.e. reduction target never exceeds surcharge increase cap) Commercial (28%) Maximum surcharge is capped at 25% by Stage 2. Similar to Single-Family Stage 1 and Stage 2 surcharges curb outdoor water use to reduction goal. Stage 3 and Stage 4 surcharges established to eliminate nearly all outdoor water use. Stage 1 and 2 surcharges established to replace lost revenue from water reduction. With water use reduction target of 36% by Stage 4, the surcharge cap of 25% prevents full revenue replacement. Industrial (<5%) Primarily one customer with very limited current outdoor water use and limited ability to reduce, maximum surcharge was capped at 11.1% by Stage 1. At 10% total reduction target, Stages 1-3 surcharges established to eliminate all outdoor water use. Stage 1-3 surcharges established to replace anticipated lost revenue from water reduction. With further rationing anticipated in Stage 4, Cap of 11.1% insufficient to replace anticipated revenue loss. 203 $2.40 $3.24 $4.54 $6.81 $2.40 $3.00 $3.75 $2.55 $2.75 $3.24 Hundred Cubic Feet (CCF) Tier 1 Tier 2 Tier 3 Tier 4 CHART 2: COMPARISON OF TIER STRUCTURE 34% of Consumption 15% of Consumption 5% of Consumption 194