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HomeMy WebLinkAbout4 - Final Report Utility Rate Structure and Billing System Evaluation Study - Volume 1 City of Boulder Final Report Utility Rate Structure and Billing System Evaluation Study Volume 1 – Utility Rate Structure Evaluation January 2004 Prepared by Economic and Engineering Services, Inc. In Association with Langham Consulting Economic and Engineering Services, Inc.  January 16, 2003 Ms. Joanna Crean Ms. Carol Linn City of Boulder Department of Public Works 1739 Broadway Boulder, Colorado 80306 Subject: Volume 1 – Evaluation of Rate Structures EES Project #3-03-197 Dear Ms. Crean and Linn: Economic and Engineering Services, Inc. (EES), in association with Langham Consulting Services, Inc. (Langham) were retained by the city of Boulder to provide a comprehensive evaluation of the city’s water rate structures and utility billing system. This volume represents the culmination of our efforts to review the city’s water rate structures. Volume 2 of our report provides the comprehensive review of the city’s utility billing system. This report discusses our approach, findings, conclusions and recommendations concerning the city’s water utility rate structures. We have developed this report based upon “generally accepted” water rate setting techniques. We appreciate your contributions and assistance, along with that of city’s management team and the Water Resources Advisory Board (WRAB), in the development of this report. Thank you for the opportunity to provide this technical assistance. Sincerely, EES,I. CONOMIC AND NGINEERING ERVICESNC Thomas E. Gould Principal TEG:smn th 10900 NE 4 Street, Suite 1110 Post Office Box 1989 Bellevue, Washington 98004 Bellevue, Washington 98009 www.ees-1.com Bellevue • Olympia • Portland • Tri-Cities • Vancouver, B.C. Telephone 425 452-8100 Fax 425 454-4189 Contents Executive Summary ............................................................................................ES-1 1 Introduction and Overview of the Study 1.1 Introduction..........................................................................................................1-1 1.2 Goals and Objectives in Evaluating the Rate Structures......................................1-1 1.3 Overview of the Volume 1 Report.......................................................................1-1 1.4 Summary..............................................................................................................1-2 2 Review of the City of Boulder’s Goals and Objectives for Setting Water Rate Structures 2.1 Introduction..........................................................................................................2-1 2.2 Evolution of the City’s Rate Structure.................................................................2-1 2.3 Review of the City’s Past Rate Design Goals and Objectives.............................2-2 2.4 Attributes of a Sound Rate Structure...................................................................2-4 2.5 Review of the City’s Current Rate Design Structure...........................................2-8 2.6 Review of the Attributes of the City’s Current Rates..........................................2-9 2.7 Summary............................................................................................................2-11 3 Overview of Water Rate Structure Terminology and the Rate Structure Alternatives to be Evaluated 3.1 Introduction..........................................................................................................3-1 3.2 Rate Structure Terminology.................................................................................3-1 3.2 Overview of the Rate Structure Alternatives to be Evaluated.............................3-5 3.4 Summary............................................................................................................3-15 4 Evaluation of the Alternative Rate Structures 4.1 Introduction..........................................................................................................4-1 4.2 Prioritization of the Rate Design Attributes.........................................................4-1 4.3 Development of the Rate Structure Evaluation Criteria......................................4-2 4.4 Process Used to Score and Evaluate the Rate Structures.....................................4-6 4.5 Summary of the Rate Structure Evaluation and Scoring.....................................4-6 4.6 Summary..............................................................................................................4-9 Contents i  City of Boulder— Volume 1—Evaluation of Water Rate Structures 5 Selection of Final Rate Design Alternatives and Development of Block Thresholds 5.1 Introduction..........................................................................................................5-1 5.2 Review of the Top Scoring Rate Structures.........................................................5-1 5.3 Establishment of Customer Classes of Service....................................................5-2 5.4 Definition of Seasons...........................................................................................5-5 5.5 Defining the First (Initial) Block Size.................................................................5-6 5.6 Defining the Second Block Size..........................................................................5-8 5.7 Defining Third and Fourth Block Sizes.............................................................5-13 5.8 Other Rate Design Features...............................................................................5-14 5.9 Considerations of Modifications to the City’s Existing Rate Structures...........5-15 5.10 Specific Rate Structures to be Evaluated by Class of Service...........................5-15 5.11 Summary............................................................................................................5-21 6 Development and Evaluation of the Rate Structures 6.1 Introduction..........................................................................................................6-1 6.2 Review of the City’s Existing Rate Structure......................................................6-1 6.3 Overview of the Approach to Pricing..................................................................6-1 6.4 Analysis of Customer Usage Characteristics.......................................................6-5 6.5 Establishment of Fixed Service (Meter) Charges................................................6-6 6.6 Overview of the Analysis.....................................................................................6-6 6.7 Review of the Single-Family Residential Rate Structures...................................6-8 6.8 Review of the Multi-Family Residential Rate Structures..................................6-30 6.9 Review of the Commercial/Large User Rate Structures....................................6-40 6.10 Review of the Metered Irrigation Rate Structures.............................................6-51 6.11 Summary Matrices of Proposed Rate Options...................................................6-58 6.12 Other Potential Rate Structure Enhancements...................................................6-63 6.13 Summary............................................................................................................6-64 7 Peer Review of Rate Structures 7.1 Introduction..........................................................................................................7-1 7.2 Review of Other Front Range Communities.......................................................7-1 7.3 Water Budget Rate Structure Review..................................................................7-3 7.4 Summary............................................................................................................7-10 8 Rate Structure Conclusions and Recommendations 8.1 Introduction..........................................................................................................8-1 8.2 Single-Family Residential Rate Structures Recommendations...........................8-1 8.3 Multi-Family Residential Rate Structures Recommendations.............................8-3 8.4 Commercial/Large User Rate Structures Recommendations..............................8-4 8.5 Metered Irrigation Rate Structures Recommendations........................................8-6 8.6 Summary..............................................................................................................8-7 Contents ii  City of Boulder— Volume 1—Evaluation of Water Rate Structures Executive Summary Introduction Economic and Engineering Services, Inc. (EES) and Langham Consulting Services, Inc. (Langham) were retained by the city of Boulder to provide a comprehensive evaluation of the city’s water rate structures and utility billing system. In providing this review, a two-volume report has been developed. Volume 1 discusses the evaluation of the city’s water rate structure. Volume 2 discusses the review and evaluation of the utility billing system. Goals and Objectives for the Study In conducting this study, the city had multiple goals and objectives. Provided below is a listing of the goals and objectives for the study. Assist the city in developing and selecting a rate structure that focuses on using water efficiently and conserving water during drought and non-drought years. Assist the city in developing and selecting a rate structure that is flexible and responsive to changing conservation needs under drought conditions. Review the city’s current rate design/structure and provide, as appropriate, alternative rate designs that are contemporary, cost-based, defensible and meet the specific rate design objectives of the city. Provide a detailed review and evaluation of the relevant business requirements needed in the utility billing system, regardless of the rate structure selected. Assist the city in an evaluation and analysis of software and vendor options, which meet the city’s overall needs, and are also capable of billing the proposed rate structure(s). Provide a well-written report of the findings, conclusions and recommendations associated with the evaluation of the city’s water rate structure and utility billing system. Provide effective public presentations to the Water Resources Advisory Board, the City Council and the public concerning the findings, conclusions and recommendations of this study. Work effectively with the Water Resources Advisory Board (WRAB), the City Council and the public concerning the findings, conclusions and recommendations of this study. Evaluation of the City’s Water Rate Structures The first major portion of the overall study undertaken for the city was to review the water rate structures. Provided below is an overview of the process used to evaluate the rate structures, and the findings, conclusions and recommendations of this portion of the study. – The first step of the 4VSGIWW9WIHXS)ZEPYEXIXLI'MX]vW6EXI7XVYGXYVIW process used to evaluate the city’s rate structures was to gain an understanding of the past goals Executive Summary ES-1  City of Boulder—Volume 1 – Evaluation of Water Rate Structures and objectives used to establish the city’s water rates. A number of city documents and reports were reviewed and some understanding of the past rate design goals and objectives were determined. The city’s rate design goals and objectives have evolved over time, however, it appears that the focus has historically been upon the following areas: RSR EVENUE TABILITY AND ELIABILITY RS EVENUE UFFICIENCY E QUITY RS,CCI EVENUE TABILITYONSERVATION AND USTOMER MPACT C/EU ONSERVATIONFFICIENT SE CSB(..C-B) OST OF ERVICEASED IEOSTASED In moving forward, it was determined that the city should review and prioritize the rate design goals and objectives that should be used for this study. In this process, specific rate design goals and objectives were defined for the city, utilizing the generally accepted list developed by James 1 C. Bonbright. The list of ten rate design goals and objectives (rate design attributes), were then prioritized based upon input from the Water Resources Advisory Committee and utility management/staff. The prioritized rate design attributes were then weighted for purposes of evaluating and scoring various rate structures. A summary of the weighting used to evaluate the rate structures is shown below in Table ES-1. Table ES-1 Summary of the Weighting of the Evaluation Criteria By the Ten Attributes Attribute Description Weighting Effectiveness in yielding total revenue requirements............................................................20% Discourage wasteful use, while promoting all justified types and amounts of use................20% Revenue stability and predictability.......................................................................................15% Fair allocation of total cost of service among the customer classes of service to attain equity................................................................................................................15% Dynamic in its ability to respond to changing supply and demand conditions and/or environmental concerns.................................................................................................10% Simple and easy to understand; easy to administer..................................................................8% Stability and predictability of the rates themselves..................................................................6% Avoidance of undue discrimination in rate relationships.........................................................3% Reflects all present and future costs (internalities and externalities) and benefits of providing utility service.................................................................................2% Freedom from controversy as to interpretation................................................................... 1% Total Weighting ...........100%   James C. Bonbright; Albert L. Danielsen and David R. Kamerschen, Principles of Public Utility Rates, (Arlington,  VA: Public Utilities Report, Inc., Second Edition, 1988), p. 383-384. Executive Summary ES-2  City of Boulder—Volume 1 – Evaluation of Water Rate Structures For each of the attributes mentioned in Table ES-1, specific evaluation criteria was utilized, and a weighted scoring system developed. Given that, each conceptual rate structure could be fairly evaluated and “scored” based upon the city’s prioritized list of attributes. – One of the objectives of the study was 6IZMI[SJXLI'SRGITXYEP6EXI(IWMKRW to review various rate structures and explore in detail those rate structures that appeared most appropriate in meeting the city’s objectives. To begin this process, twenty different conceptual rate structures were reviewed with the WRAB. The rate structures are conceptual in that they describe the basic rate, but not the specifics of the size of the consumption blocks or the actual rate to be charged for each block. By using conceptual rate structures at this point in the evaluation, the focus is truly on the structure, and not on the technical/analytical details of the rate structure. In some cases, these rate structures were variations of a specific type of rate structure (e.g. water budget). However, the purpose of creating the variations was to determine the specific components of the structure that best fit the overall rate attributes of the city. In the end, the final rate structures will be a balance of complexity to achieve water efficiency and conservation, and simplicity for customer understanding and administrative purposes. Upon reviewing the twenty (20) conceptual rate designs with the WRAB, two additional rate structures were evaluated, to bring the total number of conceptual rate structures to twenty-two (22). Each of the twenty-two conceptual rate structures were evaluated and scored to provide a list of the “Top 5” rate structures. Shown in Table ES-2 is a summary of the “Top 5” rate structures. Executive Summary ES-3  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Table ES-2 Summary of the “Top 5” Rate Structures Final Score Rate Structure Description (Out of 400) Seasonal rates with fixed thresholds and a 2-block winter rate plus goal based incentives.........213 Seasonal rates with fixed thresholds and a 2-block winter rate...................................................195 4-block water budget; block 1 – fixed threshold, block 2 – “typical” lot size and irrigation requirements, succeeding blocks based on relationship to outdoor goal with the target set and fixed each year. No monthly adjustments for weather and ET..........187 4-block water budget; block 1 – fixed threshold, block 2 – “typical” lot size and irrigation requirements, succeeding blocks based upon relationship to outdoor goal. Target is set and fixed each year. No monthly adjustment for weather and ET plus a discount for city approved irrigation systems with rain sensors and weather-based controllers..............................................................................................................................181 Indoor water use based upon a fixed threshold, with outdoor use determined based upon an assumed “typical” lot size and irrigation requirements. Succeeding blocks based upon relationship to outdoor goal. Billing period goals are adjusted for actual weather and ET. Forward looking goals are communicated via the monthly billing statement......................................................................................................175 Seasonal rates with a fixed threshold adjusted based upon water supply availability and a 2-block winter rate........................................................................................................175 It is important to note that the “Top 5” actually contained six different conceptual rate structures because of a tie in scoring. In addition, the top scoring rate structure does not imply that this is the “best” rate structure. The rate structure must be specifically analyzed and developed to determine its suitability for city purposes. – Using the (IZIPSTMRKERH)ZEPYEXMRKXLI6EXI7XVYGXYVI%PXIVREXMZIW selection of the “Top 5” conceptual rate structures, the next step in the process was to begin to take the conceptual rate structures and develop the specific elements of each rate structure. This aspect of the process is summarized below. Water rates are often developed by customer classes of service. Customer classes of service imply that there are differences between customers in their facility requirements and usage characteristics. In summary, four different customer classes of service were analyzed as a part of this study. They were as follows: Commercial/Large User Single-Family Residential Metered Irrigation Multi-Family Residential Executive Summary ES-4  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Given the defined customer classes of service, each of the conceptual rate structures was reviewed for applicability for the class of service. The conceptual rate designs were now taking shape as they could be applied to each customer class of service. An element of each rate design was the size of the consumption blocks and the basis for establishing them. A major focus of this study has been on water budget rate structures, and the method used to stnd establish an indoor budget (i.e. 1 block of consumptive use) and the outdoor budget (i.e. 2 block of consumption use/irrigable requirements). For single-family customers, the development st of the 1 block (indoor use) considered three different methods for establishing a reasonable st amount. The primary method used to establish the 1 block was based upon the planning criteria of the utility (gallons/capita/month) and an assumed household size. Each of the three methods produced roughly the same results (amount of water), and the indoor allotment was established at 5,000 gallons/month for a single-family customer. There are a number of different methods that nd can be used to establish the outdoor (2 block) allotment of water. In general, an average lot size of 9,000 square feet was assumed, with 5,200 square feet of irrigable area. Based upon this irrigable area and an irrigation rate of 15 gallons/square foot, 25,0000.60 the total water allotted for 0.50 20,000 irrigation was 78,000 gallons. 0.40 This amount of water was 15,000 Block 2 0.30 shaped on a monthly basis to Ave. ETo 10,000 reflect changing irrigation re- 0.20 quirements (evapotranspiration) 5,000 0.10 throughout the year. In 00.00 addition to the 78,000 gallons for the irrigation period, addi- tional water was provided in the winter months, along with May and June (city’s water supply direct flow period). While the previously described approach applies to a lot size of 9,000 square feet, the concepts can be applied to any lot size, and rate structure alternatives were developed that used customer specific nd lot sizes to determine the customer’s 2 block size. rdth The remaining single-family residential block sizes (3, 4, etc.) were established in relation to the “outdoor” goal. The basic concept is that the majority of customers should be able to meet their needs with the first two blocks of water. Any water over and above the first two blocks may indicate inefficient use. A similar process, as was described above, was used to establish the block sizes for each of the customer classes of service. For each class of service, the block sizes were customized to reflect the characteristics of the specific customer class of service. Executive Summary ES-5  City of Boulder—Volume 1 – Evaluation of Water Rate Structures – The final key component of the evaluation was (IZIPSTQIRXSJXLI6EXIW 4VMGI establishing the prices or rates for each rate structure. To develop the rates for each rate structure, the city’s most recent cost of service study was utilized. This study provided the  foundation or basis for establishing the fixed service (meter) charges and the consumption charges for the city. In that respect, the rate structures developed herein should be considered “cost-based.” – Six (IZIPSTQIRXSJXLI7MRKPI*EQMP]6IWMHIRXMEP6EXI%PXIVREXMZIW different rate structure alternatives were developed, analyzed and evaluated for the single-family residential customers. In summary form, the six rate structures reviewed were as follows: S-FRRS1 – Seasonally Differentiated Rate INGLEAMILY ESIDENTIAL ATETRUCTURE Structure With A 2-Block Winter Rate And A 3-Block Summer Rate. S-FRRS2 – Water Budget With Four (4) INGLEAMILY ESIDENTIAL ATETRUCTURE Consumption Blocks. Block 1 Is Fixed For Indoor Use, Block 2 Is Based Upon The Irrigation Requirements Of A 9,000 Square Foot Lot Size, And Block 3 Uses 150% Of Block 2 To Determine Size. S-FRRS3 – Water Budget With Four (4) INGLEAMILY ESIDENTIAL ATETRUCTURE Consumption Blocks. Block 1 Is Fixed For Indoor Use, Block 2 Uses Three Different “Bins” to Determine Irrigation Requirements, And Block 3 Uses 125% Of Block 2 To Determine Size. S-FRRS4 – Water Budget With Five (5) INGLEAMILY ESIDENTIAL ATETRUCTURE Consumption Blocks. Block 1 Is Fixed For Indoor Use, Block 2 Is Based Upon Tax Assessed Lot Size, Block 3 Is 125% Of Block 2, And Block 4 Is 150% Of Block 2. S-FRRS5 – Water budget with Four (4) INGLEAMILY ESIDENTIAL ATETRUCTURE Consumption Blocks. Block 1 is Fixed For Indoor Use, Block 2 is Based Upon Either a Customer Provided Irrigable Size, or a Default of 5,200 square Feet of Irrigable Area. Succeeding Blocks Based Upon Relationship to Block 2. S-FRRS6 – Existing City Rate Structure Modified INGLEAMILY ESIDENTIAL ATE TRUCTURE To Reflect Current City Goals. Of the six single-family residential rate structures that were evaluated, it was concluded that rate structures 1, 4 and 6 appeared to be viable alternatives for the city to consider. – Three (IZIPSTQIRXSJXLI1YPXM*EQMP]6IWMHIRXMEP6EXI%PXIVREXMZIW different rate structure alternatives were developed, analyzed and evaluated for the multi-family residential customers. In summary form, the three rate structures reviewed were as follows: M-FRRS1 – Seasonally Differentiated Rate ULTIAMILY ESIDENTIAL ATETRUCTURE Structure with a 2-Block Winter Rate and a 3-Block Summer Rate.  Integrated Utilities Group Final Report, Volume II, Water, Wastewater, and Stormwater Rate Study and Plant  Investment Fee Analyses (November 2001) Executive Summary ES-6  City of Boulder—Volume 1 – Evaluation of Water Rate Structures M-FRRS2 – Water Budget With Six (6) ULTIAMILY ESIDENTIAL ATETRUCTURE Consumption Blocks. Blocks 1 and 2 Are Fixed Per Unit Thresholds, Block 3 Is Based On The Customer Specific Irrigable Area, and Succeeding Blocks Based Upon Relationship To Outdoor Goal. M-FRRS3 – Water Budget With Five (5) ULTIAMILY ESIDENTIAL ATETRUCTURE Consumption Blocks. Blocks 1 and 2 Are Fixed Per Unit Thresholds, Block 3 Is Based On The Customer Specific Irrigable Area, and Succeeding Blocks Based Upon Relationship To Outdoor Goal. Based upon the evaluation of the three multi-family residential rate structures, it was concluded that all three options are viable for the city to utilize. Of the three options, Option 2 may be the least desirable because of the use of six blocks. It was concluded that rate alternatives 1 and 3 appear to be the most viable options for the city. – Three (IZIPSTQIRXSJXLI'SQQIVGMEP0EVKI9WIV6EXI%PXIVREXMZIW different rate structure alternatives were developed, analyzed and evaluated for the commercial/large user customers. In summary form, the three rate structures reviewed were as follows: C/LURS1 – Seasonally Differentiated Rate Structure OMMERCIALARGE SERATETRUCTURE With A 2-Block Winter Rate And A 2-Block Summer Rate. Block 1 set at 100% of Average Monthly Consumption. C/URS2 – Seasonally Differentiated Rate Structure OMMERCIALLARGE SERATETRUCTURE With A 2-Block Winter Rate And A 2-Block Summer Rate. Block 1 set at 90% of Average Monthly Consumption. C/URS3 – Non-Seasonal Rate Structure With Two OMMERCIALLARGE SERATETRUCTURE Blocks. The First Block Size Is Based Upon the Customer Meter Size and the Average Monthly Use of the Customers With That Same Meter Size. It was concluded that all three alternatives are viable options for the city. Alternative 2, which is a variation of Alternative 1, appears to be the better choice of the first two alternatives. Alternative 3, while a viable alternative may produce some large rate impacts to specific customers, given that it is a significant change from the city’s current approach for commercial customers (i.e. use of individual average winter consumption (AWC) vs. group average). – Three different (IZIPSTQIRXSJXLI1IXIVIH-VVMKEXMSR6EXI%PXIVREXMZIW rate structure alternatives were developed, analyzed and evaluated for the metered irrigation customers. In summary form, the three rate structures reviewed were as follows: MIRS1 – Uniform Rate. ETERED RRIGATION ATETRUCTURE MIRS2 – Water budget with Three (3) Consumption ETERED RRIGATION ATETRUCTURE Blocks. Block 1 is Based Upon Customer Specific Irrigable Area, Succeeding Blocks are Based Upon Relationship To Outdoor Goal (Block 1). Executive Summary ES-7  City of Boulder—Volume 1 – Evaluation of Water Rate Structures MIRS3 – Inverted Block Rate with Three (3) ETERED RRIGATION ATETRUCTURE Consumption Blocks. Block 1 is Based Upon 90% of the Customer’s Average Summer Consumption (ASC), Succeeding Blocks are Based Upon Relationship To Outdoor Goal (Block 1). Of the three alternatives, the first rate structure was too simple and lacked the incentives for efficient use that the city desires. Of the remaining two options, the second rate structure, which used measured irrigable area, seems to be the best choice. Water budgets are ideal for this type of customer. While the third option is a viable option, it is simply a default should the city not decide to implement a water budget rate structure for this particular class of service. – A peer review was conducted of other Front-Range 4IIV6IZMI[SJ6EXI7XVYGXYVIW utilities to determine their rate structures. Of the sixteen (16) Front-Range utilities surveyed, only one (1) utilized water budget rate structures (Highlands Ranch). The predominate rate structure utilized appeared to be an inverted block rate structure. It should be noted that Boulder currently utilizes a form of an inverted block rate structure. The peer review also examined in detail those utilities that have or had water budgets in place. This included the Irvine Ranch Water District in California. In most cases, water budget rate structures were implemented during severe droughts as a response to the need for efficient use. One of the more interesting findings was that cost of service was not used as a basis to establish the rates or the prices for the blocks. When the prices were established for the water budget rate structures, a comprehensive cost of service study was not conducted to determine the rates for each block. Rather, some utilities determined a “melded rate” by dividing it water supply costs by total consumption. This provided the pricing for the base rate block of consumption. The pricing for the subsequent blocks was set at a "punitive" level to reduce excess water use. If available, the excess revenue received from the “penalty rates” is used to offset the revenue deficiency from the residential low volume discount rate. From a purely technical rate design perspective, it could concluded that these are not cost-based rates since they are not based upon cost of service principles, and they are not designed to collect a specific target revenue requirement. Finally, in the peer review it was noted that none of the utilities that use water budgets are currently using water budget rate structures for their commercial customers. Rather, the utilities used rate structures similar to those proposed herein for the commercial customers. Evaluation of the City’s Billing System The city’s present utility billing system was developed in-house in the early 1980’s and it has served the city well over the years. However, during the drought of 2002, the limitations of the present system came to light as alternative rate structures were suggested to encourage more efficient use and conservation. The objective of this portion of the study was to evaluate the city’s billing system. Provided below is a summary of the findings, conclusions and recommendations of this portion of the study. Executive Summary ES-8  City of Boulder—Volume 1 – Evaluation of Water Rate Structures – The city’s utility billing system, 6IZMI[SJXLI'MX]vW4VIWIRX&MPPMRK7]WXIQ developed in the early 1980’s, was modified to a 3-tier client/server application in 1997. The system bills, records payments, and tracks consumption for all water, wastewater, and stormwater/ flood management customers. The current system also records meter inventory and maintenance information. – One of the first steps in evaluating the need for any new &YWMRIWW4VSGIWW6IZMI[ utility billing system software is to gain an understanding of the current business process. For this study, the business process is documented such that it will enable the city to communicate to potential vendors the specific software requirements needed to meet the city’s business process. In developing the business process review, Langham obtained data and information in two distinct and different ways. The information reviewed and included in this report was obtained through written documentation provided by the city of Boulder, as well as personal interviews conducted with city staff. The business process review focused on the following areas: Monthly Utility Rates and Fees (Water, Wastewater, Stormwater & Flood Management Rates) Billing Process Bill Printing Payment Process/Cash Receipting Credit and Collections Courtesy Reminder Letters Final Notice Letters Payment Agreement Cash Only Designation Bankruptcy Customer Service Meter Field Service/Work Orders – 4SXIRXMEP)RLERGIQIRXWXSXLI&MPPMRK7]WXIQERH&YWMRIWW4VSGIWW After an extensive review of the current utility business process, it was evident that there were several areas in which changes to the current utility billing system could potentially benefit the city. Below is a summary listing of some of these possible enhancements to the current billing system and business process. The list below only includes those enhancements that are considered most beneficial or significant. Therefore, this list of enhancements is not meant to be all encompassing. Monthly Utility Rates and Fees (Water, Wastewater, Stormwater & Flood Management Rates) Increase Flexibility and Ease of Changing Rates Bill for Additional Services (current system limited to only 3 services) Executive Summary ES-9  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Billing Process Additional Automation of Functions Currently Manually Conducted by City Staff Ability to “Master” Bill – Bill Consolidation Flexible Bill Format and Messaging Ability of Billing Service Representatives to Generate Duplicate Bills On-Line Bill Review Improved Cashiering Credit and Collections Improved Credit History by Customer Customer Service Enhanced Customer Information (identify life support customers, planned outages, automatic generation of customer information letters, etc.) Meter Field Service/Work Orders Expanded Upload of Meter Reads (Areas) Per Evening (Note: current system is limited to 18 areas per evening) Increase Number of Meter Reads Per Billing Cycle (i.e. ability to read multiple times per month, but only bill once per month. Current system bills once a month when meter is read and information is uploaded). While the city’s present billing system is operating properly and successfully achieving its main task (i.e. billing the customer), the current system lacks flexibility in certain areas. As has been noted in this section of the report, an updated system could provide benefits in the area of more efficient operations, better customer communication, and most importantly, greater flexibility, particularly as it relates to the potential for different rate structures. – As the city moves forward with the decision on billing &Y]:IVWYW&YMPH%REP]WMW software solutions, a key decision will be whether to buy pre-packaged vendor software, or a custom-built solution. As a part of the study, a comparison of the potential advantages and disadvantages of each of these alternatives was developed. The advantages of building custom software is the amount of control over the final design and features of the software. Counter-balancing those advantages are the potential risks primarily related to the cost of the development of the software, maintenance of the software and the quality of the final software that is developed. The advantages of purchasing vendor software center around a well developed, documented and tested product that uses a “best practices” approach. In contrast, the disadvantages of purchasing vendor software focus on those situations where the vendor software may not perfectly fit the city’s business process, and the possible implications of modifying or not modifying the software to exactly meet the city’s business process. A cost analysis is an integral part of the review of the advantages and disadvantages for building versus buying a system. Vendors that focus on the municipal utility market were contacted as a part of this study. In addition to vendor products, the estimated cost to build a custom system from “scratch” were provided by the vendor currently used to support the city’s utility billing system. A summary of the estimated costs from the various vendors in comparison to a custom- built system are shown in Graph ES-1. Executive Summary ES-10  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Graph ES-1 Comparison of Estimated Vendor Costs Versus Building Costs $1,200,000.00 $1,000,000.00 $800,000.00 $600,000.00 Maintenance Fee Implementation $400,000.00 Licensing / Development $200,000.00 $0.00 Vendors  As a part of the cost of any system are the implementation costs and issues. A checklist of implementation issues was provided to assure that the city understands the potential problem areas regardless of whether the system is custom-built or a pre-packaged software solution. – The objective of the peer review is to understand the approach and 4IIV'SQTEVMWSRW systems used by other comparative utilities. The utilities selected for this review were from states with a focus on conservation and conservation-based rates. These states included Arizona, California, Colorado, New Mexico and Utah. In addition, some Florida utilities were included since water conservation is also an important issue in that state. In general, the peer review found a number of utilities that have custom-built systems. However, it appears that most utilities utilize pre-packaged vendor software. In addition, very few utilities have “water budget” rate structures, but the vast majority do use an inverted block rate structure. Those communities that have implemented “water budget” rate structures have used either a custom developed billing system or have customized/ reprogrammed their existing billing system. As would be expected, the level of satisfaction with both custom-built and pre-packaged software varied from user to user. – A review 6IZMI[SJ6EXI7XVYGXYVI%PXIVREXMZIWERH4SXIRXMEP:IRHSVW was undertaken of each of the rate structures alternatives that were chosen to be evaluated in detail. The objective was to identify for each rate structure any issues or concerns that a potential vendor may have with using “pre-packaged” software to bill the rate structure. Executive Summary ES-11  City of Boulder—Volume 1 – Evaluation of Water Rate Structures The majority of the components within the rate structures being evaluated by the city are supported by existing software vendor products. These components include various customer classes, summer/winter rate differentials, the tiered (inverted) block structure, history based consumption calculations and the additional information such as impervious area, lot size, pervious area, and number of living units. However, many of the water budget rate structures reviewed included options for utilizing historical weather and ET. When reviewing these structures, the calculation of the water allocation will require specific logic for the city. The cost of this software modification will vary depending on the flexibility of the vendor’s current product, and the complexity of the rate structure. As the rate structure becomes more complex, the access to information via reports and ad hoc queries may become more complex even with additional effort from city Information Technology and vendor staff. In summary, it would appear that all of the non-water budget rate structures can be handled currently by vendor software with potentially little or no modifications. The exception to that comment is the calculation of average summer consumption and average monthly consumption based upon a three-year historical period for the commercial and metered irrigation rate structures. In contrast to this, the water budget rate structures may be difficult for vendors to provide, depending upon the level of complexity of the final rate structure. Even the simplest water budget rate structure may have a limited number of vendors capable of billing a water budget rate structure, without some modification to their software. The more complex water budgets may have a very limited number of vendors, and would probably require custom modifications. Billing System Evaluation Recommendations – This report is the beginning of a process to provide better tools to support the city of Boulder’s goals and objectives. An improved billing system can automate processes that could improve productivity and eliminate duplication of data and manual effort. These automated processes could be provided by expanding the current system, redesigning and developing a system to meet the specific needs of the city or purchasing a vendor supplied system. Obviously, there are advantages and disadvantages to each potential solution, which must be carefully evaluated and weighed by the city. From analysis conducted as a part of this study, a number of conclusions and recommendations have been reached. Provided below is a discussion of the billing system recommendations. The next step for city of Boulder should be to complete the final definition of the functional requirements and release a Request for Information (RFI) for a new billing system. Only after reviewing the responses to the RFI will the city know whether there is a vendor supplied package that can meet all the requirements, as currently defined. Langham is of the opinion that the benefits to purchasing a vendor supplied product out- weigh the benefits to building a product. Langham reaches this conclusion based upon the fact that a vendor software product would be available and ready for configuration, while involving less risk and more control of total costs. However, if the city selects a rate structure that is not widely used in the industry then purchasing a pre-packaged vendor product may not be quite as advantageous. Executive Summary ES-12  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Section 1 Introduction and Overview of the Study 1.1 Introduction Economic and Engineering Services, Inc. (EES) and Langham Consulting Services, Inc. (Langham) were retained by the City of Boulder to provide a comprehensive evaluation of the city’s water rate structures and utility billing system. In providing this review, a two-volume report has been developed. Volume 1 discusses the evaluation of the city’s water rate structure. Volume 2 discusses the review and evaluation of the utility billing system. 1.2 Goals and Objectives in Evaluating the Rate Structures The city had multiple goals and objectives in evaluating the water utility rate structures. Provided below is a listing of the goals and objectives for this portion of the study. Assist the city in developing and selecting a rate structure that focuses on using water efficiently and conserving water during drought and non-drought years. Assist the city in developing and selecting a rate structure that is flexible and responsive to changing conservation needs under drought conditions. Review the city’s current rate designs/structures and provide, as appropriate, alternative rate designs that are contemporary, cost-based, defensible and meet the specific rate design objectives of the city. Work effectively with the Water Resources Advisory Board (WRAB), the City Council and the public concerning the findings, conclusions and recommendations of this study. In conducting this study for the city, the approach used to evaluate the various rate structures was designed specifically to meet the above goals and objectives. At the same time, it was designed specifically to provide to WRAB and the city, a non-biased decision framework to evaluate the various rate structures. 1.3 Overview of the Volume 1 Report This report is designed to document the approach used to evaluate the various rate structures. As the rate structure evaluation study progressed, technical memorandums were written at key decision points. This report has incorporated the technical memorandums into this report to provide a detailed discussion and review of the study. In addition, other material and discussion has been included within this report to provide a complete and comprehensive documentation of our findings, conclusions and recommendations. Introduction and Overview of the Study 1-1  City of Boulder—Volume 1 – Evaluation of Water Rate Structures The following section of this report will discuss the City of Boulder’s goals and objectives in designing and setting their water rate structures. This section of the report provides the basis around which rate structures are often established, and compares those rate structure attributes to the city’s existing rate structures. Next, Section 3 of the report provides an overview of rate setting terminology and begins the process of considering a number of different rate structures for evaluation and review. In total, twenty-two (22) different rate structures are evaluated using an evaluation process. Section 4 discusses the prioritization of the city’s rate design goals and objectives and the evaluation process that was undertaken to take the twenty-two rate structures and narrow them down to a “Top 5” for further detailed review. Section 5 uses the “Top 5” rate structures as a starting point to place greater clarity and definition of how the “Top 5” rate structures will be specifically applied to each class of service. Given specific definitions of the rate structure for each class of service, the final task in the evaluation process is the development of the pricing for each of the rate structures, along with a comparison to the city’s existing rate structure. This aspect of the study is discussed in Section 6. Section 7 of the report provides a “peer” review of the rate structures used by other water utilities, how they compare to the rate structures being proposed within this study, and some of the issues associated with those rate structures. Finally, Section 8 summarizes the findings, conclusions and consultant recommendations from this study. 1.4 Summary This section of the report has provided a brief overview of the report prepared for the city reviewing the current water rate structure, and evaluating alternative water rate structures. The next section of the report will discuss the process used to review the city’s goals and objectives in establishing their water rates. Introduction and Overview of the Study 1-2  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Section 2 Review of the City of Boulder’s Goals and Objectives for Setting Water Rate Structures 2.1 Introduction The City of Boulder has been providing water service to its citizens since the mid-1870’s. Since that time, the methods of charging for water service have changed dramatically as the system has expanded, but more importantly, as the need to protect and encourage efficient use for the resource has changed. The city’s water rates have always functioned around the major goal of collecting sufficient revenues to meet the utility’s financial requirement. However, in more recent years, other rate setting goals and objectives, other than simply meeting the city’s revenue requirements, have become more prominent. The review that follows will examine the city’s historical rate design goals and objectives. This has been documented by reviewing the city’s historical documents (e.g. past rate studies, comprehensive planning documents and City Council/Water Resources Advisory Board minutes/notes). The purpose of the review is to gain a better understanding of the city’s historical perspective as it related to the establishment of rates. The city’s historical rate setting goals and objectives can then be compared to “generally accepted” or traditional rate design goals and objectives, that other contemporary water utilities may utilize. From this list of goals and objectives, a comparison can be made to the city’s existing rate structure to determine how well it meets the city’s desired goals and objectives (attributes). 2.2 Evolution of the City’s Rate Structure A review was undertaken of the city’s historical documents to gain a better understanding of the evolution of the city’s rates and the goals and objectives that may have been used to establish them. The purpose of this review was not to document the actual rates, per se, but rather the policy perspectives that were used to establish the rates. Our review identified the evolution of the city’s water rates that first began as “rents” for services since there were virtually no meters when water service began. Historically, this was a common practice for water utilities to base their rates on potential end uses (e.g. number of seats in a restaurant, etc.). By the early 1900’s water use was restricted due to drought conditions. The city’s customers were requested to conserve water during this time, which prompted the discussion of metering of water and selling “rents” at a fair price. In 1908, metering of service began with those who had “extensive” water use. Two years later, additional metering was installed. Charges for different customers varied from continuing the Review of the City of Boulder’s Goals 2-1  and Objectives for Setting Water Rate Structures City of Boulder—Volume 1 – Evaluation of Water Rate Structures “rents” philosophy, to a flat rate and even free service for the Hotel Boulderado to encourage tourists to sample Boulder’s “famous” water. By 1965, the city’s residential customers were completely metered. The utility ran into a deficit during the first few years requiring an increase in rents. The deficit necessitated that more industries be metered to solve the deficit issue. Throughout time the city has attempted to add greater equity and fairness to the water rates through variable meter charges and a consumption rate based on the amount of water consumed. In 1988, the city adopted an inverted block rate charge in an effort to encourage water conservation. Under this approach, average winter consumption is calculated to determine the size of the first block of consumption. The following two blocks of the inverted block structure are determined based upon the size of the first block. The city continues to use the inverted block rate structure that was developed and implemented in 1988. However, with the drought of 2002, the city has modified its rates to incorporate “drought surcharges” or “drought rates” whereby the rate to be charged during drought conditions is established, and implemented as the city declares the various stages of drought. As the drought conditions worsen, the rate charges increase. As indicated by the city’s historical documentation, the first rate structure was a simple charge assessed to citizen’s for the opportunity to receive water service and to provide a means for the city to recover costs. Throughout time, and as changing conditions dictated, the city has implemented more sophisticated rates that take into account a blend of financial, operational, environmental and community goals. 2.3 Review of the City’s Past Rate Design Goals and Objectives A review of city documents was undertaken to determine the city’s past goals and objectives in setting its water rates. A variety of documents were reviewed that had some relationship to the rate setting process (e.g. past rate studies, drought plans, etc.). In establishing water rates, some typical goals and objectives may be items such as, rates that are easy to understand and administer, that produce sufficient revenues, that provide revenue stability and encourage conservation. This list is by no means all inclusive, but rather illustrates the types of goals and objectives that are often considered in the rate setting process. In summary, we found a limited amount of written documentation concerning the specific goals and objectives that were used to establish the city’s rates, past and present. In many cases, we believe the goals and objectives were discussed in the rate setting process, but not clearly documented in written form. In addition, EES did not find any prioritization of the goals and objectives. In other words, we found no documentation that stated that one goal was more important or preferable over another. With the change of the city’s rates and rate structures over time, as would be expected, the goals and objectives have also evolved. The review of the city’s past and present rate structures indicates a significant change from the initial approach of charging “rent” for water service to the drought rates that are in place today. As with any growing and evolving utility, some of the Review of the City of Boulder’s Goals 2-2  and Objectives for Setting Water Rate Structures City of Boulder—Volume 1 – Evaluation of Water Rate Structures goals and objectives of the past have been refined to account for the changing issues and concerns of modern times. Our review of the city’s historical and current documentation revealed the following city rate design goals and objectives: RSR. The rate structure should minimize fluctuation in EVENUE TABILITY AND ELIABILITY revenues due to changes in demand. During the 1988 rate review the city determined that  revenue stability was one of its most important objectives.  RS. The rate structure should be formulated to meet the utility’s EVENUE UFFICIENCY operating and maintenance costs, maintain required reserves and meet debt service coverage (DSC) requirements. Utility assesses fees and charges to ensure that revenues are  sufficient to meet operating and maintenance costs, and to maintain the financial integrity of the utility. In order to meet the goals of providing safe and reliable water to its customers,  all water utilities must collect revenues sufficient to cover their operating and maintenance costs, meet DSC requirements and fund designated reserves.  E. Any discomfort, difficulty and sacrifice due to the drought should be shared and QUITY not borne by just one type of customer or water use. Fairness to all customers in the  establishment of the rates.  RS,CCI. These three objectives EVENUE TABILITYONSERVATION AND USTOMER MPACT were initially defined by Boulder’s City Council during the 1987 rate study. Reflects  balancing of conservation goals, customer impacts and fiscal management. Boulder’s  current rate structure is conservation-oriented and designed to encourage efficient use of water by sending a clear price signal for high or excessive water use.  C/EU. Enhance the city’s philosophy of conservation by using ONSERVATIONFFICIENT SE the water pricing structure to encourage the efficient use of water and to discourage or penalize inefficient uses.Relying on pricing mechanisms or rate structures alone, without  mandatory restrictions (in a drought), may not produce water use reductions fast enough to deal effectively with a serious drought situation.   3 Water Resources Advisory Board (WRAB) Meeting Minutes, March 17, 2003, p. 11. 4 Rate and PIF Review/Update, IUG, October 16, 1995, p. ES-2. 5 Debt service coverage is a financial test and legal rate covenant associated with the issuance of revenue bonds and other certain types of long-term debt. Debt service coverage is used to assure bondholders of the City’s ability to repay the debt. 6 Water Resources Advisory Board (WRAB) Meeting Minutes, March 17, 2003, p. 1. 7 City of Boulder 2003 Budget, Volume 1, Utility Rates Section, p. 29. 8 City of Boulder Drought Plan, Volume 2, February 2003, p. 59. 9 City of Boulder Drought Plan, Volume 1, February 2003, p. 9. 10 Rate and PIF Review/Update, IUG, October 16, 1995, Volume 2: Appendix D - initial project meeting of the commercial/industrial pricing and implications for rate structures. 11 Rate and PIF Review/Update, IUG, October 16, 1995, p. 3-1. 12 Comprehensive Utility Rate Evaluation, Ernst & Young, June 1992, p. C-8. 13 City of Boulder Drought Plan, Volume 2, February 2003, p 60. 14 Comprehensive Utility Rate Evaluation, Ernst & Young, June 1992, page B-1 15 City of Boulder Drought Plan, Volume 2, February 2003, p. 53. Review of the City of Boulder’s Goals 2-3  and Objectives for Setting Water Rate Structures City of Boulder—Volume 1 – Evaluation of Water Rate Structures R :  ATE DESIGN EVALUATION CRITERIA Legally defendable Administrative burden Support of conservation goals Fairness to all customers Public acceptance Equitability CSB(..C-B). The city employs a cost of service OST OF ERVICE ASED IEOSTASED methodology in designing water rates consistent of four steps; definition of revenue requirements, allocation of revenue requirements to functional cost components, distribution of functional costs to customer classes and rate design. The Boulder water rate design  methodology incorporates the following customer service characteristics - base, extra capacity (maximum day and maximum hour), conservation, customer/billing and meter.  As can be seen from the above listing, over the years and in various documents, the city has considered a number of different goals and objectives in establishing its rates and the resulting rate structures. However, it is clear that the city does not have a specific detailed list of rate design goals and objectives that they can point to and state that those specific goals and objectives formed the basis for the decision to implement a specific rate structure. 2.4 Attributes of a Sound Rate Structure The attributes of sound rate structures have been documented in a number of rate setting manuals. However, the foundation for evaluating rate structures is generally credited to James C. Bonbright in the Principles of Public Utility Rates. The manual Principles of Public Utility  Rates provides utility managers and policymakers an understanding of pricing policies, theories and economic concepts that support various rate designs. Bonbright’s list of the attributes of a sound rate structure is quoted in a number of other rate manuals and is often paraphrased and simplified in reading utility rate study reports. Bonbright certainly wasn’t the first person to consider the attributes of a sound rate structure. Bonbright simply considered many of the opinions and discussions of the time and condensed them into a compact list. Bonbright offers the following thoughts concerning his list of attributes: “The list that follows is fairly typical, although we have derived it from a variety of sources, instead of relying on any one presentation. Of the ten proposed attributes enumerated in this section, the first three relate to the provision of adequate stable and predictable revenues and rates; the next five are based on cost, efficiency, and equity considerations, and the remaining two deal with the  16 Rate and PIF Review/Update, IUG, October 16, 1995, Volume 2: Appendix D - initial project meeting of the commercial/industrial pricing and implications for rate structures. 17 City of Boulder Drought Plan, Volume 2, February 2003, p 59-60. 18 Rate and PIF Review/Update, IUG, October 16, 1995, p. 3-1. 19 James C. Bonbright; Albert L. Danielsen and David R. Kamerschen, Principles of Public Utility Rates, (Arlington, VA: Public Utilities Report, Inc., Second Edition, 1988), p. 383-384. Review of the City of Boulder’s Goals 2-4  and Objectives for Setting Water Rate Structures City of Boulder—Volume 1 – Evaluation of Water Rate Structures matters of practicality and acceptability. However, the sequence in which the ten attributes are presented is not meant to suggest any order of importance. Moreover, there is, perforce, some inconsistency and redundancy in any such listing. We are simply trying to identify the desirable characteristics of utility performance that regulators should seek to compel through edict.”  Bonbright recognized the challenge of establishing rates and suggests that the list of attributes should be used as a reminder of the many possible considerations in the rate design process. However, he also noted that the list is “also useful in suggesting important reasons why problems of practical rate design do not yield readily to scientific principles of optimum pricing.”  Finally, Bonbright recognized that his list of attributes lacked clear definitions (e.g. how does one define “undue discrimination”), along with overlapping and conflicting characteristics. Provided below are the ten attributes to a sound rate structure as identified by Bonbright. For each of Bonbright’s attributes, we have tried to clarify and state the attribute in easy to understand terminology, along with providing a better definition of those attributes that may be directly applicable to the City. 6IZIRYIVIPEXIH%XXVMFYXIW B: Effectiveness in yielding total revenue requirements under the fair return ONBRIGHT standard without any socially undesirable expansion of the rate base or socially undesirable 20 level of product quality or safety. R: The city’s rates should meet the total revenue requirement needs of the city.  ESTATED D: The rate structure will be developed to cover the total costs of utility EFINITION operations, under a “cash needs” approach – operating, capital, debt service coverage and reserves. B: Revenue stability and predictability, with a minimum of unexpected changes ONBRIGHT seriously adverse to utility companies. R: Revenue stability and predictability, with a minimum of unexpected changes ESTATED seriously adverse to the city’s utility. D: The rate structure will be developed to eliminate swings in revenue generation EFINITION from year to year based on such factors as weather, conservation and customer usage changes. Annual swings in planned revenue should be no greater than 5% and 10%.  20 Ibid, p. 382-383. 21 Ibid. p. 384. 22 The AWWA M-1 Manual, Principles of Water Rates, Fees and Charges, discusses two “generally-accepted” methodologies for establishing revenue requirements. Bonbright refers to a “fair return standard” which typically applies to the “utility/accrual” basis of establishing revenue requirements. Under this methodology, the utility is entitled to earn a “fair” return on its investment. This is the methodology used by privately owned utilities, and some public utilities. In contrast, most municipal utilities, including the City, use the “cash-basis” methodology. Under this approach, the City sums its O&M, debt service and capital improvements funded from rate revenues to equal its revenue requirements. Over time, both methodologies should produce roughly the same revenue requirements. Review of the City of Boulder’s Goals 2-5  and Objectives for Setting Water Rate Structures City of Boulder—Volume 1 – Evaluation of Water Rate Structures B: Stability and predictability of the rates themselves, with a minimum of ONBRIGHT unexpected changes seriously adverse to ratepayers with a sense of historical continuity. (Compare “The best tax is an old tax”). R: From the customer’s perspective, the rates should appear to be stable and result ESTATED in customer bills that are relatively predictable. There should be a continuity of philosophy in the establishment of the rates, with a minimum of unexpected changes seriously adverse to customers. D: The implementation of new rate structures should be consistent with past utility EFINITION rate setting philosophy and minimize customer impacts during any change in rate structure. A typical customer, under normal conditions, and “normal” usage, should not have an adjustment greater than 10% on an annual basis, unless based upon cost of service. 'SWXVIPEXIH%XXVMFYXIW B: Static efficiency of the rate classes and rate blocks in discouraging wasteful ONBRIGHT use of service while promoting all justified types and amounts. in the control of the total amounts of service supplied by the company. in the control of the relative uses of alternative types of service by ratepayers (on-peak versus off-peak service or higher quality versus lower quality of service). R: Efficiency and effectiveness of the rate classes and rate blocks in discouraging ESTATED wasteful use of service while promoting all justified types and amounts. D: The rate structure should promote efficient use of water and discourage or EFINITION penalize inefficient uses. B: Reflection of all of the present and future private and social costs and benefits ONBRIGHT occasioned by a service’s provision. (i.e., all internalities and externalities). R: The rate should reflect all of the utility’s present and future internal costs, along ESTATED with the external private and social costs/benefits. D: The rate structure should reflect all traditional internal costs (direct and EFINITION indirect) that the city incurs, and, under appropriate situations and conditions (e.g. severe drought) may also include externalities of present and future costs and benefits (i.e. marginal cost and/or value of water). B: Fairness of the specific rates in apportionment of total costs of service among ONBRIGHT the different ratepayers so as to avoid arbitrariness and capriciousness and to attain equity in three dimensions: (1) horizontal (i.e., equals treated equally); (2) vertical (i.e., unequals treated unequally); and (3) anonymous (i.e. no ratepayer’s demands can be diverted away uneconomically from an incumbent by a potential entrant). R Fairness of the rates in the allocation of total costs of service among the different ESTATED ratepayers so as to avoid arbitrariness, capriciousness and to attain equity. D: The rates and the rate structure shall be based upon a fair allocation of total EFINITION cost of service among the customer classes of service by use of a “generally accepted” cost of service methodology such as defined in the AWWA- M1 manual. Review of the City of Boulder’s Goals 2-6  and Objectives for Setting Water Rate Structures City of Boulder—Volume 1 – Evaluation of Water Rate Structures B: Avoidance of undue discrimination in rate relationships so as to be, if possible, ONBRIGHT compensatory (i.e. subsidy free with no inter-customer burdens). R : The rates should be, as practically possible, non-discriminatory, between ESTATED customer groups, and within each customer group. D: The rate structures should avoid interclass subsidies whenever possible to EFINITION ensure each class pays its full cost of service. B: Dynamic efficiency in promoting innovation and responding economically to ONBRIGHT changing demand and supply patterns. R: The ability and efficiency of the rate to respond to changing demand and supply ESTATED patterns. D: The rate structure should be developed such that it either responds EFINITION appropriately and directly to changes in supply, demand, etc, or alternatively, contains the flexibility to allow the utility to respond to the changing needs as a result of supply, demand, and/or environmental concerns (e.g. drought conditions). 4VEGXMGEPVIPEXIH%XXVMFYXIW B: The related, practical attributes of simplicity, certainty, convenience of ONBRIGHT payment, economy in collection, understandability, public acceptability and feasibility of application. R: The attributes of simplicity, certainty, convenience of payment, economy in ESTATED collection, understandability, public acceptability and feasibility of administration. D: From the customer’s perspective, the rate structure should be simple to EFINITION understand, such that the customer can easily understand the bill. From the utility’s perspective, the rate structure should be easy to administer and collect. Finally, the rate structure should have acceptance by the majority of the customers that the rate structure and resulting bills are “fair and equitable.” B: Freedom from controversies as to proper interpretation. ONBRIGHT R: Freedom from controversies as to the application of the rate schedule to the ESTATED customer and calculation of the customer’s bill. D: The rate structure should not be ambiguous in its terminology and structure. It EFINITION should be simple to explain and understand by the average customer to minimize any misinterpretation regarding the customer’s bill and the overall goals that the rate structure has been developed to meet. Given clearer definitions of Bonbright’s attributes of a sound rate structure, these definitions can be used to review and evaluate the city’s existing rate structure and identify those attributes which are being fully or partially met, and those attributes that are not being met. Review of the City of Boulder’s Goals 2-7  and Objectives for Setting Water Rate Structures City of Boulder—Volume 1 – Evaluation of Water Rate Structures 2.5 Review of the City’s Current Rate Design Structure An important starting point for reviewing the attributes of the city’s existing rate structure is having a good understanding of the city’s current rate design and its structure. In reviewing water rate designs, consideration is given to both the level of the rates and the structure of the rates. Level refers to the amount of revenue to be collected from a specific rate design (i.e., the rate design is intended to collect $2.0 million over a 12 month period). In contrast, structure refers to the way in which the $2.0 million is collected from the customers. At this point, we are focused on reviewing structure, as opposed to the level of the rates. The current rate design of the city consists of a fixed monthly service charge based on the size of meter service and a three block inverted (increasing) rate structure. The monthly meter service charge has a differential for outside city customers. The consumption charge increases as the amount of consumption increases. The size of each block is specific to a customer. The initial block is generally determined based upon the user’s average winter consumption (December to March bills). From the average winter consumption (AWC), the remaining two blocks are related to the size of the initial block. Most recently, the city added drought surcharges to the rate structure for residential and irrigation customers. Drought surcharges only apply when droughts are declared, and the rates adjust according to the various stages of drought. It should also be noted that the single-family residence AWC is capped at a maximum of 8,000 gallons a month to determine the appropriate water billing block. A summary of the current water rate structure is presented in Table 2-1. Review of the City of Boulder’s Goals 2-8  and Objectives for Setting Water Rate Structures City of Boulder—Volume 1 – Evaluation of Water Rate Structures  Table 2-1 Overview of the City of Boulder’s Present Rates Typical Drought Drought Drought Drought Conditions Stage I Stage II Stage III Stage IV Service Charges – $/Month [1] 3/4” $8.12 Service Charges Apply to All Customer and All Water Conditions 1” 13.88 1–1/4” 21.28 1–1/2” 30.30 2” 53.32 3” 119.02 4” 211.00 6” 473.93 8” 841.99 Residential/Irrigation Consumption Charges – $/1,000 gallons Per Unit Rate + Drought Surcharges Block 1 [2] $1.65 $0.00 $0.00 $0.00 $0.00 Block 2 [3] $3.30 $0.50 $1.00 $2.00 $4.00 Block 3 [4] $6.60 $1.00 $2.00 $4.00 $8.00 Per Unit Effective Price - Block 1 [2] $1.65 $1.65 $1.65 $1.65 $1.65 Block 2 [3] $3.30 $3.80 $4.30 $5.30 $7.30 Block 3 [4] $6.60 $7.60 $8.60 $10.60 $14.60 Commercial/Industrial Consumption Charges – $/1,000 gallons Per Unit Rate Block 1 [2] $1.65 Drought surcharges currently do not apply to Block 2 [3] $3.00 Commercial/Industrial customers Block 3 [4] $4.40 Per Unit Effective Price - Block 1 [2] $1.65 Block 2 [3] $3.00 Block 3 [4] $4.40 [1] – There is a 50% differential on outside City customers for the service charge portion only [2] – Block 1 is determined based upon average winter water use of the customer (December to March bills) [3] – Block 2 is 350% of Block 1 [4] – Block 3 is over 350% of Block 1 2.6 Review of the Attributes of the City’s Current Rates A comparison was undertaken of the city’s current rate design structure to the attributes of a sound rate structure listed by Bonbright. The objective of this comparison is to better understand the strengths and weaknesses of the city’s current rate design. Our review of the attributes are shown below in Table 2-2. Review of the City of Boulder’s Goals 2-9  and Objectives for Setting Water Rate Structures City of Boulder—Volume 1 – Evaluation of Water Rate Structures Table 2-2 Comparison of the City’s Current Rate Structure to Bonbright’s Attributes of a Sound Rate Structure Rate Design Attribute Partially Meets MeetsDoes not Meet 1.Effectiveness in yielding Under mild drought Under typical conditions rates Under severe drought total revenue requirements. conditions, or wet are designed to meet O&M conditions, or extreme wet conditions, there may be and capital needs. conditions, unclear as to a slight shortfall in whether the rates would covering operating and yield the total revenue capital needs. requirements. 2.Revenue stability and Inverted block rate The fixed monthly service Current rate structure may predictability. structure creates some charge provides for revenue have revenue swings instability, even under stability, regardless of water during drought conditions typical water conditions. conditions. due to the uncertainty of water use and restriction levels. 3.Stability and predictability Steepness of the The current rate structure Implementation of severe of the rates themselves. inverted block rates may continues the City’s drought surcharges (Stage create bills that are philosophy of inverted block II and above) may have a unusually large and rates.very large impact on unexpected for the certain customers. customer. 4.Discourage wasteful use, Focus of the City’s rates The current inverted block AWC may encourage while promoting all justified appears to be on rate and drought rates clearly “inefficient” use. types and amounts. discouraging wasteful promote efficient use and use. May not achieve conservation. all justified uses, while avoiding block 3 rate. 5.Reflect all present and Rates reflect internal The current rate structure The City’s rates will never future costs (internalities accounting costs. attempts to include all utility fully reflect the full and externalities) and Severe drought rates costs through the use of an “social” costs and benefits benefits of providing utility may reflect internal and annual budget process that of the water. service. external costs. defines cost requirements. Fair allocation of total cost Rate blocks may not be Cost allocation method used Under severe drought 6. of service among the cost-of-service based to develop the current rates conditions, the rates may customer classes of service under certain water utilizes a “generally accepted” be inequitable by class of to attain equity. conditions and levels of methodology as defined in the service. use.AWWA M-1 Manual. 7.Avoidance of undue Level of rates and lack Use of a cost of service No clear or obvious signs discrimination in rate of drought surcharges methodology establishes of rate discrimination relationships. for C/I customers may average unit costs by class of (legal perspective). appear to other service. customers as being inequitable. 8.Dynamic in its ability to Clearly responds to Clearly contemplates drought Does not respond to years respond to changing supply drought conditions, but conditions and is sufficiently with plentiful water and demand conditions may not reflect surplus flexible to allow different supply conditions. and/or environmental (run-off) conditions. rates depending upon supply concerns. levels (drought only). Review of the City of Boulder’s Goals 2-10  and Objectives for Setting Water Rate Structures City of Boulder—Volume 1 – Evaluation of Water Rate Structures Table 2-2 (continued) Comparison of the City’s Current Rate Structure to Bonbright’s Attributes of a Sound Rate Structure (continued) Rate Design Attribute Partially Meets MeetsDoes not Meet 9.Simple and easy to Simple in the structure, City has successfully carried Customers may not fully understand; easy to but somewhat complex out the administration and understand the rate administer. in the establishment of collection of the existing rate structure, and only the block sizes and the design. City’s billing system understand the amount of AWC. The City’s is capable of handling the the bill. billing system does not current rate structure. segregate and differentiate surcharges. 10.Freedom from controversy Questions by individual City has used this rate Does not appear to be any as to interpretation. customers concerning structure for many years and community wide concerns the establishment of emphasized customer as to the administration of their block sizes based education, including during the rate structure. upon average winter the implementation of the consumption (AWC), drought surcharges in 2003. and the differential between residential/irrigation and the C/I rate levels. In summary, it appears that the city’s existing rate structure partially or fully meets most of Bonbright’s attributes of a sound rate structure. Given the complexity and conservation-oriented goals of the city’s current rate structure, it appears that the trade-offs in the attributes of the city’s rate structure have been in the areas of simplicity, understandability and under certain conditions, rate stability. The city’s present rate structure is attempting to communicate and send a proper price signal as to the value of water, thereby providing the customer the ability to make an informed decision whether to consume or not consume. As the city strives to develop rate structures that target specific uses (e.g. outdoor irrigation), any changes must be evaluated against the city’s overall goals and objectives for rate design. 2.7 Summary The rate structure review undertaken has identified the evolution of the City’s first rate structure to the current multi-block, conservation-oriented rate structure. The review has also identified the attributes the city currently uses in developing rate structures and what attributes are and are not meeting the “generally accepted” attributes of a sound rate structure. The summary and findings should provide the city with the knowledge of how rates have historically and currently met the goals and objectives of the city and provide the information necessary to define which attributes are important to carry forward with any future rate structure options. Review of the City of Boulder’s Goals 2-11  and Objectives for Setting Water Rate Structures City of Boulder—Volume 1 – Evaluation of Water Rate Structures Section 3 Overview of Water Rate Structure Terminology and the Rate Structure Alternatives To Be Evaluated 3.1 Introduction An important aspect of reviewing and evaluating alternative water rate structures is understanding the terminology of rate structures, the basic concepts of rate structures, and the various alternative structures that may be developed from these basic concepts. Provided within this section of the report is a discussion of the basic rate structure terminology, and the alternative structures that were used as a starting point for the evaluation of the water rate structures. 3.2 Rate Structure Terminology A review of the rate structures from other water utilities across the U.S. reveals a wide variety of structures and approaches in use today. While it may seem that there is an endless number of different rate structures to be found, the reality is that they are all “While it may seem based upon a few basic rate design concepts. It is how these basic that there is an endless concepts are applied, modified and combined that create what number of different appears to be endless possibilities. Provided below is a brief rate structures to be discussion of these basic rate design concepts. found, the reality is that they are all based The initial starting point in considering a rate structure is the upon a few basic rate relationship between fixed costs and variable costs. Fixed costs do design concepts.” not vary with the production or flow of water. Debt service is an example of a fixed cost. In contrast, variable costs tend to change with the quantity of water produced. Examples of variable costs are the cost of chemicals and electricity. Most rate structures contain a fixed or minimum charge, and a volumetric consumption (commodity) charge. Fixed costs are generally collected as a fixed charge on a monthly basis (e.g. $5.00 per month/meter). This charge may be called by various names (e.g. customer charge, meter charge, readiness to serve charge, etc.), but in all cases, it is intended to collect the fixed costs that the utility incurs, regardless of the customer’s level of consumption. The most basic form of a fixed customer charge is a meter charge. While the charge is a fixed amount, regardless of consumption, it typically varies (increases) by meter size. Overview of Water Rate Structure Terminology 3-1  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures The rate at which the meter charge increases is typically a function of either meter investment (cost) or meter capacity. Provided in Table 3-1 is the “generally accepted” approach used to establish fixed meter charges based upon the safe operating capacity of the meter for 5/8” meter through a 12” meter. In this example, it assumes a $5.00/month charge for a 5/8” meter. Table 3-1 Example of the Development of Fixed Meter Charges Based Upon Meter Capacity Safe Maximum Oper. Equivalent Meter Charges at Meter Size Capacity GPM [1] Meter Ratio Equivalent Ratios 3/4” 30 1.00 $5.00/month 1” 50 1.66 8.30 1-1/2” 100 3.33 16.65 2” 160 5.33 26.65 3” 300 10.00 50.00 4” 500 16.66 83.30 6” 1,000 33.33 166.65 8” 1,600 53.33 266.65 10” 2,300 76.66 383.30 12” 3,375 112.50 562.50 [1] AWWA C-700-77 Cold Water Meters - Displacement Type As Table 3-1 indicates, the fixed meter charge increases in relationship to the safe operating capacity of the various meter sizes. Meter capacity is an important concept in that a customer that has a 3” meter is regarded, from a capacity perspective, as the equivalent of ten (10) 3/4” customers. Another way of saying this is the customer with a 3” meter is, from a capacity perspective, the equivalent of ten (10) customers with 3/4” meters. Knowing that a large portion of a typical utility’s costs are related to meeting capacity requirements, one can see the importance of taking into account capacity in establishing rates for customers. Fixed charges are typically used to collect, at a minimum, the costs associated with meter reading, billing, customer service and accounting. It often includes a portion of the cost of maintenance of the distribution system and capital/debt service costs. In the city’s case, the fixed charges are designed to collect the customer related costs, plus 30% of the cost of the city’s improvement program. While it was noted that there are different approaches that can be used to collect fixed charges, the same can be said for variable or volumetric charges. Volumetric consumption charges are generally based upon metered consumption and charged on a $/unit cost. Although the unit of measurement may vary, (e.g. gallons, thousands of gallons, cubic feet, hundreds of cubic feet, acre feet, etc.) this is not a critical element in the development of the rates. This is because the charge per unit is simply adjusted to reflect the units of measurement being used. In other words, if you are charging $2.00 per 1,000 gallons, and wanted to charge on a per gallon basis, the rate would be $0.002/gallon. It is the structure of the variable charges where numerous options exist. Overview of Water Rate Structure Terminology 3-2  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures There are four basic rate structures for variable charges; a uniform charge, a declining block charge, inverted (increasing) block charge and seasonal. Figure 3-1 provides an overview of each of these variable charge rate structures. Figure 1 Overview of the Various Variable Charge Rate Structures URS Per NIFORMATE TRUCTURE Unit The cost per unit of consumption under a uniform rate Cost structure does not increase or decrease with additional units of consumption sage U Per DBRS ECLINING LOCK ATETRUCTURE Unit The cost per unit of consumption under a declining block Cost rate structure decreases with additional units of consumption sage U Per IBRS NVERTEDLOCK ATETRUCTURE Unit The cost per unit of consumption under an inverted block Cost rate structure increases with additional units of consumption sage U Per SRS EASONAL ATETRUCTURE Peak Season Unit The cost per unit of consumption under a seasonal rate Cost structure changes with time periods. The peak season is the most expensive time period. NonPea –k sage U Figure 3-1 illustrates that the basic philosophy of each of these variable charge rate structures varies significantly. Under a uniform rate structure, the cost per unit does not change with consumption. The uniform structure is a simple and straightforward approach from the perspective of customer understanding and rate administration/billing. In contrast, the declining block rate structure is a bit more complex. The number of blocks (e.g. 3 stepped blocks) and size Overview of Water Rate Structure Terminology 3-3  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures of the blocks (e.g. 0 – 10,000 gallons) may vary. However, the number of blocks should be  reasonable (i.e. 2 – 5 blocks) for reasons of simplicity and administration. Declining block rates may imply that there are certain economies of scale with additional consumption, or improved capacity use, and not necessarily a “volume discount.” Depending upon the utility, this may or may not be a true statement. An inverted (increasing or tiered) block rate structure attempts to send a price signal to consumers that their consumption costs more, as more water is consumed. This may or may not be the proper price signal regarding the utility’s water resource costs. As with the declining block rate structure, the number and size of each block may vary, but should be reasonable for purposes of customer understanding and rate administration. Finally, a seasonal rate structure is a form of a time-differentiated rate structure. That is, the price varies based upon the time of use. Under a seasonal rate structure, water consumed in the summer is priced at a higher level than winter water consumption. This rate structure attempts to reflect the difference in costs associated with consumption during a peak period when water supply resources may be constrained. The rate structure concepts noted above may be combined and used to form various different rate structures. As an example, a seasonal inverted block rate structure is developed by combining the seasonal rate structure concept with the inverted block rate structure. One of the rate forms that the city is interested in reviewing is the water budget rate structure. Simply stated, a water budget rate structure is a form of an inverted block rate structure. The main difference between the water budget rate structure and a “typical” inverted block rate structure is how the size of the blocks is determined within the water budget rate structure. Most inverted block rate structures have fixed thresholds for block sizes (e.g. 0 – 5,000 gallons, 5,000 gallons – 100,000 gallons, and all consumption over 100,000 gallons), which may be determined using various criteria. Some of these criteria include essential (lifeline) needs, average customer class usage (base usage), etc. In the water budget rate structure, the block sizes are individually established, and they may be established using a number of different criteria and methods (e.g. average winter water use, number of people in the home, lot size, type of plantings, evapotranspiration (ET), etc.). The water budget rate structure attempts to establish a rational basis for individually tailored “indoor” and “outdoor” consumption budgets (i.e. block sizes). In addition, water budgets may reward customers for beating their budget goal, or penalize them for going over their water budget. It is interesting to note that some people may view the city’s current rate as a simplified form of a water budget rate structure. The initial or first block of consumption is established based upon the customer’s average winter consumption. The second block is determined as a percentage of the first block, and the tail block is all consumption over and above the second block. Therefore, in essence, each customer has individualized block sizes. The second block is considered the “outdoor” amount, and the third or tail block is the “excess use” block. Where there is a disconnect from the more sophisticated examples of water budgets, is in the rational for the establishment of the block sizes (i.e. indoor, outdoor and excessive use).  23 “Blocks” or “Consumption Blocks” is used in a declining block or inverted block rate structure and refers to the amount of consumption allowed before the price changes to a succeeding price block. The initial block refers to the first price block (e.g. 0 to 5,000 gallons). The tail block refers to the last price block (e.g. all usage over 5,000 gallons). Overview of Water Rate Structure Terminology 3-4  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures Given this brief overview of rate design terminology, the focus shifts to the development of the rate structure alternatives to be evaluated in the city’s study. From this evaluation process, a limited set of rate structures will undergo further review and analysis. 3.3 Overview of the Rate Structure Alternatives to Be Evaluated Provided below is a listing of the rate structures to be evaluated using the evaluation criteria developed by EES and reviewed by city staff. As discussed above, a typical water rate design contains both a fixed and variable charge. The focus of the review at this point is on the structure of the rates, and not on the level of the rates, or the proportion of revenue to be collected from the fixed versus variable charges. After the rate structures are evaluated and reduced in number to a more manageable total, the focus will shift to consideration of the appropriate cost-based level of the rates, and specifically the fixed and variable charges. Four additional items should be noted before reviewing the descriptions below. First, the descriptions below discuss the consumption charge portion of the rate. It is presumed that regardless of the structure selected, it will contain a fixed monthly service (meter) charge that is based upon meter size. Therefore, in the descriptions below, no mention is made of the fixed charge portion of the overall rate structure, but all final rate designs will include both a fixed monthly meter charge and a consumption charge. Next, the other important item to note is that there could be endless permutations of these rate structures (e.g. 2 blocks, 3 blocks, 4 blocks, 5 blocks, etc.) For this evaluation process, we have attempted to list a variety of structures that provide a reasonable array of the choices available to the city. Based upon this evaluation process, the city may discover that it likes portions of two or three different rate structures being reviewed, which, when taken together, may create a whole new structure. Any new rate structure developed during the evaluation process will be included and reviewed further. Third, it is also presumed that any final rate structures will incorporate drought surcharges or another mechanism to reflect drought situations. That is, the rates will be segregated between typical periods and drought stages 1-4. The rate structures shown below are for “non-drought” periods, and will in the final development of the rates be modified to deal with the city’s various drought stages. Finally, the rate structures discussed below do not make any distinction between class of service (e.g. single-family, commercial, etc.). As the rate structures are narrowed down and eliminated via this screening process, the final 3-5 rate structures will then be analyzed as to their applicability to the specific customer classes of services. Provided below are the descriptions of the rate structures to be reviewed and evaluated using the rate structure evaluation criteria. Overview of Water Rate Structure Terminology 3-5  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures RS1–CRS ATETRUCTURE URRENT ATE TRUCTURE The current rate structure is individually tailored to the customer’s indoor usage pattern and uses average winter consumption (AWC) to establish the first block of consumption. The second block is a fixed percentage in relation to the first block, and the third or tail block is all remaining consumption. Basis for Block Determining Block Size Pricing of the Block Block 1 Based on AWC Inverted Block Price Block 2 Set % of Block 1 Inverted Block Price Block 3 All Usage Over Block 2 Inverted Block Price RS2–MCRSWSR ATETRUCTURE ODIFIEDURRENT ATETRUCTURE ITH EASONAL ATES AND A UWR NIFORM INTER ATE Under this rate structure, the pricing is split between the winter and summer period. Pricing of water in the wintertime is uniform, and not subject to inverted block pricing. Usage in the summer is an inverted block rate structure, and priced based upon summer period costs. The first block is established based upon AWC. Basis for Block Pricing of the Block Determining Block Size Winter Period - Block 1 All consumption Uniform Price for Winter Summer Period - Block 1 Based on AWC Same Price as Winter Block 2 Set % of Block 1 Inverted Block Price Block 3 All Usage Over Block 2 Inverted Block Price Overview of Water Rate Structure Terminology 3-6  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures RS3–MCRSWSR ATETRUCTURE ODIFIEDURRENT ATETRUCTURE ITH EASONAL ATES AND A 2-BWR LOCKINTER ATE Under this rate structure, the pricing is again split between the winter and summer period. Pricing of water in the winter period has two blocks. The first block is based upon AWC, with the second block being all usage over and above the first block. In this pricing scheme, it is presumed that summer usage in the second block is higher than the wintertime price. Basis for Block Determining Block Size Pricing of the Block Winter Period - Block 1 Based on AWC Inverted Block Winter Price Block 2 All Usage Over Block 1 Inverted Block Winter Price Summer Period - Block 1 Based on AWC Same Price as Winter Block 2 Set % of Block 1 Inverted Block Summer Price Block 3 All Usage Over Block 2 Inverted Block Summer Price RS4–SRWFTUW ATETRUCTURE EASONAL ATESITH IXED HRESHOLDS AND A NIFORM INTER R ATE Under this rate structure, the pricing is split between the winter and summer period. Pricing of water in the winter is uniform, and not subject to inverted block pricing. Usage in the summer is an inverted block rate structure, and priced based upon summer period costs. The first block in the summer period is a fixed threshold. This threshold can be determined in a number of different ways (e.g. class averages, fixture counts, etc.). Basis for Block Determining Block Size Pricing of the Block Winter Period - Block 1 All consumption Uniform Price for Winter Summer Period - Block 1 Fixed Threshold Same Price as Winter Block 2 Set % of Block 1 Inverted Block Price Block 3 All Usage Over Block 2 Inverted Block Price Overview of Water Rate Structure Terminology 3-7  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures RS5–SRWFT2-BW ATETRUCTURE EASONAL ATESITHIXED HRESHOLDS AND A LOCKINTER R ATE Under this rate structure, the pricing is again split between the winter and summer period. Pricing of water in the winter period has two blocks. The first block is based upon a fixed threshold, with the second block being all usage over and above the first block. In this pricing scheme, it is presumed that summer usage in the second block is higher than the wintertime price. Basis for Block Determining Block Size Pricing of the Block Winter Period - Block 1 Fixed Threshold Inverted Block Winter Price Block 2 All Usage Over Block 1 Inverted Block Winter Price Summer Period - st Block 1 Fixed Threshold Same Price as 1 Block Winter Block 2 Set % of Block 1 Inverted Block Summer Price Block 3 All Usage Over Block 2 Inverted Block Summer Price RS6–SRWAAWCTBUW ATETRUCTURE EASONAL ATEITH NHRESHOLD ASED PONATER SA2-BWR UPPLY VAILABILITY AND A LOCKINTER ATE Under this rate structure, the pricing is again split between the winter and summer period. Pricing of water in the winter period has two blocks. The first block is a block size based upon AWC, but the block size adjusts based upon water supply conditions. Under drier or drought conditions, the size of the first block would be reduced based upon a pre-determined sliding scale. By reducing the first block size, all succeeding blocks are also reduced accordingly. In this pricing scheme, it is presumed that summer usage in the second block is higher than the wintertime price. Basis for Block Determining Block Size Pricing of the Block Winter Period - [1] Block 1 Based on Adj. AWC Inverted Block Winter Price Block 2 All Usage Over Block 1 Inverted Block Winter Price Summer Period - [1]st Block 1 Based on Adj. AWC Same Price as 1 Block Winter Block 2 Set % of Block 1 Inverted Block Summer Price Block 3 All Usage Over Block 2 Inverted Block Summer Price [1] AWC block size established annually, on the basis of supply availability, using a predetermined and fixed sliding scale Overview of Water Rate Structure Terminology 3-8  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures RS7–SRWAFTABU ATETRUCTURE EASONAL ATESITH IXED HRESHOLD DJUSTEDASED PON WSA2-BWR ATERUPPLY VAILABILITY AND A LOCKINTER ATE This rate structure uses a fixed threshold to establish the first block, and similar to the previous alternative, is adjusted based upon water supply conditions. Basis for Block Determining Block Size Pricing of the Block Winter Period - [1] Block 1 Fixed Threshold Inverted Block Winter Price Block 2 All Usage Over Block 1 Inverted Block Winter Price Summer Period - [1]st Block 1 Fixed Threshold Same Price as 1 Block Winter Block 2 Set % of Block 1 Inverted Block Summer Price Block 3 All Usage Over Block 2 Inverted Block Summer Price [1] Threshold size established annually, on the basis of supply availability, using a predetermined and fixed sliding scale RS8–SRFSPB,UAWC ATETRUCTURE EASONAL ATE WITH OURUMMER ERIOD LOCKSSING UWR AND A NIFORM INTER ATE This rate structure is similar to Rate Structure 2, but has added a fourth block to the summer rd period. The additional block is intended to provide two benefits. The first benefit is that the 3 th block consumption is penalized, but not at an overly “punitive” rate. The 4 or tail block is intended for those users who are clearly being excessive and should pay a punitive rate. The additional block allows for a clearer and broader definition of excessive or wasteful use. An example of how the blocks would be established is Block 2 is 200% of Block 1, and Block 3 is 201% through 400% of Block 1, and Block 4 is all consumption over Block 3. Basis Block Determining Block Size Pricing of the Block Winter Period - Block 1 All consumption Uniform Price for Winter Summer Period - Block 1 Based on AWC Same Price as Winter Block 2 Set % of Block 1 Inverted Block Price Block 3 % Range of Block 1 Inverted Block Price Block 4 All Usage Over Block 3 Inverted Block Price Overview of Water Rate Structure Terminology 3-9  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures RS9–SRFSPB,UF ATETRUCTURE EASONAL ATE WITH OURUMMER ERIOD LOCKSSING A IXED TUWR HRESHOLD AND A NIFORM INTER ATE This is similar to the prior rate structure, but uses a fixed threshold to establish the first block of the summer period. Each of the following blocks in the summer period is derived from size of the first block. Basis for Block Determining Block Size Pricing of the Block Winter Period - Block 1 All consumption Uniform Price for Winter Summer Period - Block 1 Fixed Threshold Same Price as Winter Block 2 Set % of Block 1 Inverted Block Price Block 3 % Range of Block 1 Inverted Block Price Block 4 All Usage Over Block 3 Inverted Block Price RS10–TSRS1–9,PGB ATETRUCTURE OPCORER OF ATE TRUCTURES LUSOALASED I NCENTIVES This alternative will take the top scorer from the first nine (9) rate structures and add a goal- based incentive. That is, if the customer uses less than the block size, a discount will be provided. The size of the discount is dependent upon their variance from the stated goal. The discount would only apply in the summer time period. RS11–IWUBUI’AWC,W ATETRUCTURE NDOORATERSE ASEDPON THE NDIVIDUALSITH OUDBUCSLS/IA. UTDOOR SEETERMINED ASED PONUSTOMER PECIFIC OT IZERRIGABLE REA BPGAAWET.F ILLING ERIOD OALS ARE DJUSTED FOR CTUAL EATHER AND ORWARD LGACVMBS. OOKINGOALSRE OMMUNICATED IA THE ONTHLY ILLING TATEMENT This rate structure allocates an amount of water for indoor and outdoor use. The indoor allocation is based upon the individual’s AWC. The outdoor allocation is determined based upon customer specific lot size and irrigable area. The irrigable area is assumed to be the highest water using type of irrigable turf. As with the previous rate structure, outdoor use is based upon assumed “typical” weather and water supply conditions. At billing, the outdoor block sizes are adjusted based upon actual weather conditions and ET. Performance against the previous month’s goals, and the goals for the coming month are communicated via the billing statement. Basis for Block Determining Block Size Pricing of the Block Block 1 Individualized AWC Inverted Block Price Block 2 Based on Specific Lot Size, and Adjusted for ET Inverted Block Price Block 3 All Usage Over Block 2 Inverted Block Price Overview of Water Rate Structure Terminology 3-10  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures RS12–IWUBUNO, ATETRUCTURE NDOOR ATERSEASEDPONUMBER OF CCUPANTS WITH OUDBUCSLS/IA UTDOORSEETERMINED ASED PONUSTOMER PECIFIC OT IZERRIGABLE REA TTP.BPGAA YPE OF URFLANTINGILLING ERIOD OALS ARE DJUSTED FOR CTUAL AND WET.FLGACVM EATHER AND ORWARD OOKING OALSRE OMMUNICATED IA THE ONTHLY BS. ILLING TATEMENT Under this rate structure, the customer is also allocated an amount of water for indoor and outdoor use. The indoor allocation is based upon the number of occupants and multiplied by an assumed per capita usage level. The outdoor allocation is determined based upon customer specific lot size and irrigable area. In addition, the type of turf planting is taken into account (e.g. buffalograss vs. bluegrass). Finally, outdoor use is based upon assumed “typical” weather and water supply conditions. At billing, the outdoor block sizes (block 2 and 3) are adjusted based upon actual weather conditions for the month and ET. Performance against the previous month’s goals, and the goals for the coming month are communicated via the billing statement. Basis for Block Determining Block Size Pricing of the Block Block 1 Based on # of Occupants Inverted Block Price Block 2 Based on Specific Lot Size, Turf Type & Adjusted for ET Inverted Block Price Block 3 All Usage Over Block 2 Inverted Block Price RS13–IWUBUI’AWC,W ATETRUCTURE NDOORATERSE ASEDPON THE NDIVIDUALSITH OUDBUCSLS/IA. UTDOOR SEETERMINED ASED PONUSTOMER PECIFIC OT IZERRIGABLE REA SBBUROG.BP UCCEEDING LOCKS ASEDPONELATIONSHIP TO UTDOOROALILLING ERIOD GAAWET.FLGA OALS ARE DJUSTED FOR CTUAL EATHER AND ORWARD OOKINGOALSRE CVMBS. OMMUNICATED IA THE ONTHLY ILLING TATEMENT This rate structure is another variation of allocating an amount of water for indoor and outdoor use. The indoor allocation is based upon the individual’s AWC. The outdoor allocation is determined based upon customer specific lot size and irrigable area. The irrigable area is assumed to be the highest water using type of irrigable turf. Usage over and above the customer’s goal is penalized with a higher rate. The third block is considered “inefficient” use, and the fourth block is considered “Excessive or Wasteful.” As with the previous rate structure, outdoor use is based upon assumed “typical” weather and water supply conditions. At billing, the outdoor block sizes are adjusted based upon actual weather conditions and ET. Performance against the previous month’s goals, and the goals for the coming month are communicated via the billing statement. Basis for Block Determining Block Size Pricing of the Block Block 1 Individualized AWC Inverted Block Price Block 2 Based on Specific Lot Size and Adjusted for ET Inverted Block Price Block 3 101% to 150% of Goal Inverted Block Price Block 4 Over 150% of Goal Inverted Block Price Overview of Water Rate Structure Terminology 3-11  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures RS14–IWUBUFT,W ATETRUCTURE NDOORATERSE ASED PON A IXED HRESHOLDITH OUDBUCSLS/IA. UTDOOR SEETERMINED ASED PONUSTOMER PECIFIC OT IZERRIGABLE REA SBBUROG.BP UCCEEDING LOCKS ASEDPONELATIONSHIP TO UTDOOROALILLING ERIOD GAAWET.FLGA OALS ARE DJUSTED FOR CTUAL EATHER AND ORWARD OOKINGOALSRE CVMBS. OMMUNICATED IA THE ONTHLY ILLING TATEMENT For this rate structure, indoor allocation is a fixed threshold. This is typically developed based upon an assumed average number of occupants, multiplied by an assumed per capita use. The outdoor allocation and blocks are the same as the previous rate structure. Outdoor use is based upon assumed “typical” weather and water supply conditions. At billing, the outdoor block sizes are adjusted based upon actual weather conditions and ET. Performance against the previous month’s goals, and the goals for the coming month are communicated via the billing statement. Basis for Block Determining Block Size Pricing of the Block Block 1 Fixed Threshold Inverted Block Price Block 2 Based on Specific Lot Size and Adjusted for ET Inverted Block Price Block 3 101% to 150% of Goal Inverted Block Price Block 4 Over 150% of Goal Inverted Block Price RS15–IWUBUI’AWC,W ATETRUCTURE NDOORATERSE ASEDPON THE NDIVIDUALSITH OUDBUAA“T”LS UTDOOR SEETERMINEDASED PONNSSUMED YPICALOT IZE AND IR.SBBUR RRIGATION EQUIREMENTSUCCEEDING LOCKSASEDPON ELATIONSHIP TO OG.BPGAAWET. UTDOOROALILLING ERIOD OALS ARE DJUSTED FOR CTUAL EATHER AND FLGACVMBS. ORWARD OOKINGOALSRE OMMUNICATED IA THE ONTHLY ILLING TATEMENT The indoor allocation for this rate structure is based upon the individual’s AWC. The outdoor allocation is determined based upon an assumed “typical” lot size for the type of customer (e.g., single family, etc.), and assumes the highest water using type of irrigable turf. Succeeding nd blocks 3 and 4 are similar to the previous rate structure. The 2 Block for outdoor use is based upon assumed “typical” weather and water supply conditions. At billing, the outdoor block sizes are adjusted based upon actual weather conditions and ET. Performance against the previous month’s goals, and the goals for the coming month are communicated via the billing statement. Basis for Block Determining Block Size Pricing of the Block Block 1 Individualized AWC Inverted Block Price Block 2 Based on “Typical” Lot Size/ Typical Weather/Water Supply and Adjusted for ET Inverted Block Price Block 3 101% to 150% of Goal Inverted Block Price Block 4 Over 150% of Goal Inverted Block Price Overview of Water Rate Structure Terminology 3-12  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures RS16–FBWUBUCC ATETRUCTURE IRST LOCKATER SE ASED PON THE USTOMER LASS AWU,WOUDBUAA VERAGE ATERSEITH UTDOOR SEETERMINED ASED PONNSSUMED “T”LSIR.SBBU YPICALOTIZE AND RRIGATION EQUIREMENTSUCCEEDING LOCKSASEDPON ROG.BPGAA ELATIONSHIP TO UTDOOR OALILLING ERIOD OALS ARE DJUSTED FOR CTUAL WET.FLGACVM EATHER AND ORWARD OOKING OALSRE OMMUNICATED IA THE ONTHLY BS. ILLING TATEMENT The first block is determined based upon the class average water use. Note that this is a different value than the class average winter water consumption. The outdoor allocation is determined based upon an assumed “typical” lot size for the type of customer (e.g. single family, etc.), and assumes the highest water using type of irrigable turf. This is similar to previous rate structures. At billing, the outdoor block sizes are adjusted based upon actual weather conditions and ET. Performance against the previous month’s goals, and the goals for the coming month are communicated via the billing statement. Basis for Block Determining Block Size Pricing of the Block Block 1 Class Average Water Use Inverted Block Price Block 2 Based on “Typical” Lot Size and Adjusted for ET Inverted Block Price Block 3 101% to 150% of Goal Inverted Block Price Block 4 Over 150% of Goal Inverted Block Price RS17–IWUBUFT,W ATETRUCTURE NDOORATERSE ASED PON A IXED HRESHOLDITH OUDBUAA“T”LS UTDOOR SEETERMINEDASED PONNSSUMED YPICALOT IZE AND IR.SBBUR RRIGATION EQUIREMENTSUCCEEDING LOCKSASEDPON ELATIONSHIP TO OG.BPGAAWET. UTDOOROALILLING ERIOD OALS ARE DJUSTED FOR CTUAL EATHER AND FLGACVMBS. ORWARD OOKINGOALSRE OMMUNICATED IA THE ONTHLY ILLING TATEMENT This rate structure simplifies the city’s data requirements by establishing a fixed indoor threshold, and the outdoor block size is based upon an assumed “typical” lot size for the type of customer (e.g. single family, etc.). It assumes the highest water using type of irrigable turf. nd Succeeding blocks 3 and 4 are similar to the previous rate structure. The 2 Block for outdoor use is based upon assumed “typical” weather and water supply conditions. At billing, the outdoor block sizes are adjusted based upon actual weather conditions and ET. Performance against the previous month’s goals, and the goals for the coming month are communicated via the billing statement. It should be noted that this rate structure most closely matches the rate structure and approach used by Irvine Ranch Water District. Basis for Block Determining Block Size Pricing of the Block Block 1 Fixed Threshold Inverted Block Price Block 2 Based on “Typical” Lot Size/ Typical Weather/Water Supply and Adjusted for ET Inverted Block Price Block 3 101% to 150% of Goal Inverted Block Price Block 4 Over 150% of Goal Inverted Block Price Overview of Water Rate Structure Terminology 3-13  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures RS18–FBSIOA, ATETRUCTURE IRST LOCK IS THE UM OF NDOOR AND UTDOOR LLOCATION SBBURFBG.B ANDUCCEEDING LOCKS ASED PONELATIONSHIP TO IRST LOCKOALILLING PGAAWET.FLG ERIOD OALS ARE DJUSTED FOR CTUAL EATHER AND ORWARD OOKING OALS ACVMBS. REOMMUNICATED IA THE ONTHLY ILLING TATEMENT This rate structure simplifies the city’s data requirements by establishing a fixed indoor threshold, and the outdoor block size is based on an assumed “typical” lot size for the type of customer (e.g. single family, etc.), and assumes the highest water using type of irrigable turf. nd The 2 block size is adjusted for ET. Performance against the previous month’s goals, and the goals for the coming month are communicated via the billing statement. Basis for Block Determining Block Size Pricing of the Block Block 1 Sum of Indoor & Outdoor Inverted Block Price Block 2 101% to 150% of Goal Inverted Block Price Block 3 Over 150% of Goal Inverted Block Price RS19–TS11–18,TF ATETRUCTURE OPCORER OF WITH THE ARGET SET AND IXED EACH Y.NAWET. EARO MONTHLY DJUSTMENTS FOR EATHER AND This rate structure uses the top scorer of rate structure alternatives 11 – 18, and makes a simplifying assumption. That is, the targets are set and fixed at the start of the year (based upon the criteria selected), and they are not adjusted through the year for actual weather conditions and ET. RS20–TS11–19,DC ATETRUCTURE OPCORER OF WITH A ISCOUNT FOR ITY APPROVED IRSW-BC. RRIGATION SYSTEMS WITH AINENSORS AND EATHERASEDONTROLLERS This rate structure uses the top scorer of rate structure alternatives 11 – 19, and adds a discount, or eliminates penalties for customers with a city-approved state-of-the-art irrigation system that includes rain sensors and weather-based controllers. Under this rate structure, those customers that do not have approved systems will pay the “standard” rate (top scorer of 11 – 19), but customers with approved irrigation systems will pay no penalties for usage over and above the outdoor goal. The presumption is that these customers, by using efficient irrigation systems, should meet or exceed their outdoor goal, and on those few occasions when they do not, they should not be penalized since they have made a significant capital investment to attempt to be as efficient as possible. The twenty (20) rate structures discussed above were developed by EES, with input and suggestions from city staff. In presenting the above rate structures to the WRAB and the public, two additional rate structures were suggested for inclusion in the evaluation process. These two additional rate structures are noted below. Overview of Water Rate Structure Terminology 3-14  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures RS21–FBBULO,A ATETRUCTURE IRST LOCK IS ASED PON THE EGAL CCUPANCY AND SSUMED PCU.TSBIDBUCS ERAPITASEHEECOND LOCKSETERMINED ASEDPONUSTOMER PECIFIC LS/IA.BPGUHME. OTIZERRIGABLE REAILLING ERIOD OALSSESISTORICAL ONTHLY T FLGACVTMBS. ORWARD OOKINGOALSRE OMMUNICATED IAHE ONTHLY ILLING TATEMENT Basis for Block Determining Block Size Pricing of the Block Block 1 Based on Legal Occupancy Inverted Block Price Block 2 Based on Specific Lot Size Inverted Block Price and Uses Historical Average Monthly ET Block 3 All Usage over Block 2 Inverted Block Price RS22–FBFTBU“AD” ATETRUCTURE IRST LOCK IS A IXED HRESHOLD ASED PONVERAGE AY CUWC’PIF(PIF),S ONDITIONS SEDITHIN THE ITYSLANT NVESTMENT EES AND FOR THE IZE OF MC.TSBBU“PD” THE ETER OF THE USTOMERHE ECOND LOCK IS ASED PON THE EAK AY ACC’PIF.U(BGU)C SSUMPTIONS ONTAINED IN THE ITYSNUSED WATER ELOWOALSAGEAN “”“U. BELOANED OR RENTED TO OTHER WATER SERS Basis for Block Determining Block Size Pricing of the Block Block 1 Fixed Threshold – Ave. Day Inverted Block Price Block 2 Fixed Threshold – Peak Day Inverted Block Price Block 3 All Usage over Block 2 Inverted Block Price 3.4 Summary This section of the report has provided a brief overview of the terminology and elements of rate designs. In addition, twenty-two (22) rate structures have been identified for the evaluation process. From these twenty-two rate structures, three (3) to five (5) will be considered for further evaluation and analysis by the city. This aspect of the study is discussed in the next section of this report. Overview of Water Rate Structure Terminology 3-15  and the Rate Structure Alternatives To Be Evaluated City of Boulder—Volume 1 – Evaluation of Water Rate Structures Section 4 Evaluation of the Alternative Rate Structures 4.1 Introduction In order to evaluate the various alternative rate structures, the previously defined rate design attributes must be prioritized, the evaluation criteria developed and weighted based upon those prioritized attributes, and each rate structure must be evaluated and scored against those criteria. This section of the report will review each of these elements in the evaluation process. At the end of the evaluation process, the city should have narrowed down the possible rate structure alternatives from 22, to 3 to 5 that will be analyzed further.  4.2 Prioritization of the Rate Design Attributes The first step of the evaluation process was to prioritize the previously defined rate structure attributes. As will be recalled in Section 2 of this report, these attributes, also referred to as goals, were defined using James C. Bonbright’s Attributes of a Sound Rate Structure. These attributes can be found in Bonbright’s Principles of Public Utility Rates. For purposes of this  study, the ten attributes needed to be prioritized. To accomplish this, city staff members and the individual members of the Water Resources Advisory Board (WRAB) were asked to list their top 5 goals. Each individual was provided with a written list of the ten attributes and asked to place a “1” by their top goal, a “2” by their second goal, and so on, until they had selected their top 5 attributes. From each of the individual tallies, a final prioritization list was created based upon st the weighted number of “votes” each attribute received. For a goal that received a top (1) st priority, it received 5 points for each 1 place vote. For a second place vote, the attribute received four points, and so on. The points received for each attribute was summed and the attributes were then placed in a top to bottom order. Each of the rate attributes received at least one vote. However, it is interesting to note that both the WRAB and city staff selected the same top five priorities, but not in the same order. For purposes of summarizing the prioritized attributes, the results are summarized between WRAB and city staff. Each party has a different and relevant perspective of the goals and objectives in setting the rates, and it was concluded by EES that neither party’s viewpoint should take precedence over the other. Provided below is a summary of prioritized attributes separated between WRAB and city staff.  24 James C. Bonbright; Albert L. Danielsen and David R. Kamerschen, Principles of Public Utility Rates, (Arlington, VA: Public Utilities Report, Inc., Second Edition, 1988), p. 383-384. Evaluation of the Alternative Rate Structures 4-1  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Table 4-1 Prioritization of the Rate Structure Attributes By The Water Resources Advisory Board (WRAB) and City Staff WRAB Prioritization RankCity Staff Prioritization 1 Discourage Wasteful Use Yields Total Revenue Requirements 2 Dynamic Ability to Respond To Changing Revenue Stability and Predictability Supply & Demand Conditions 3 Fair Allocation of Costs to Attain Equity Discourage Wasteful Use 4 Revenue Stability and Predictability Fair Allocation of Costs to Attain Equity 5 Yields Total Revenue Requirements Dynamic Ability to Respond to Changing Supply and Demand Conditions In developing the evaluation criteria, the top priority of both WRAB and city staff will be weighted equally and given 20 percent each of the final weighting. Each of the other eight remaining attributes will be given a lesser weighting in the evaluation process. Given this prioritized list of attributes, the focus can shift to the development of the evaluation criteria that will be used to evaluate the various rate structures.  4.3 Development of the Rate Structure Evaluation Criteria The next step in the rate structure evaluation process is to develop the evaluation criteria. The evaluation criteria will be used to “judge” each of the various rate structures. The top scoring rate structures, using these evaluation criteria, will be considered for further review and analysis. In developing the evaluation criteria, the first step was to list the relevant criteria for each of the ten rate structure attributes. In some cases, this process created multiple sub-criteria for a single rate structure attribute. For each criteria, a range of relationships was created as to how well the rate structure met that criteria. An example of the development of a criteria is shown below in Figure 4-1. Evaluation of the Alternative Rate Structures 4-2  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Figure 4-1 Example of the Overall Approach Used to Develop Evaluation Criteria LowHigh 12345 REVENUE RELATED ATTRIBUTES 1Effectiveness in yielding total revenue requirements Definition: The rate structure will be developed to cover the total costs of utility operations, under a “cash needs” approach - operating, capital, debt service coverage and reserves. Evaluation Criteria: Rate structure is designed to equal (target) the city's Little or No Relationship Some GoodVery Strong100% Relationship revenue requirements (i.e. the total revenue requirementsRelationshipRelationshipRelationshipto the Rev. Requir. to the City's Rev. Requir. are divided by the billing units - customers and usage to equal the rate). Comments/Basis for Rating: For each of the attributes, the criteria were listed and the basis for a low to high score defined. In some cases, the criteria are subjective and will require judgment on the part of the evaluators to determine a fair score. However, by creating a broad range to evaluate and score each rate structure, the subjective measures should be relative to each of the structures evaluated. The evaluation criteria was reviewed by city staff and presented to the WRAB prior to undertaking the evaluation process. Given the above framework, the evaluation criteria were developed for each of the rate structure attributes. Provided below in Table 4-2 is a summary of the evaluation criteria. Evaluation of the Alternative Rate Structures 4-3  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Table 4-2 Overview of the Rate Structure Evaluation Criteria by the Ten Attributes 1 Effectiveness in yielding total revenue requirements 2 Revenue stability and predictability Revenue within the range of 5% to +10% of target revenue From the city’s perspective, rates are predictable Rate revenues can be projected with reasonable accuracy 3 Stability and predictability of the rates themselves Compared to existing rates: Potential impacts to “conserving” customers Potential impacts to “non-conserving” customers From the customer’s perspective: Stability (predictability) of customer’s bill in the winter period Stability (predictability) of customer’s bill in the summer period Stability (predictability) of customer’s bill from year-to-year 4 Discourage wasteful use, while promoting all justified types and amounts of use Targets and encourages indoor water conservation Targets and encourages outdoor water conservation Encourages peak use reduction Uses positive incentives to encourage conservation Uses penalties or punitive measures to discourage waste 5 Reflects all present and future costs (internalities and externalities) and benefits of providing utility service Reflects, under all conditions, direct and indirect costs Reflects, in some manner, marginal costs or externalities 6 Fair allocation of total cost of service among the customer classes of service to attain equity 7 Avoidance of undue discrimination in rate relationships Equitable and cost-based across all classes of service Legal and defendable 8 Dynamic in its ability to respond to changing supply and demand conditions and/or environmental concerns 9 Simple and easy to understand; easy to administer Billing method is easy for customer to understand and customer will respond accordingly Technical complexity of developing the rate Ease of implementation (billing system constraints; implementation issues and customer education) On-going administrative costs/issues Provide for on-going communication/feedback Anticipated public acceptance (fair and reasonable?) 10 Freedom from controversy as to interpretation Evaluation of the Alternative Rate Structures 4-4  City of Boulder—Volume 1 – Evaluation of Water Rate Structures The final step of creating the evaluation criteria was to determine the relative weighting that should be applied to each attribute. Table 4-3 provides a summary of the weighting by major attribute, placed in the order of importance (priority/weighting).  Table 4-3 Summary of the Weighting of the Evaluation Criteria By the Ten Attributes Attribute No. Attribute Description Weighting 1 Effectiveness in yielding total revenue requirements..................................20% 4 Discourage wasteful use, while promoting all justified types and amounts of use..........................................................................20% 3 Revenue stability and predictability.............................................................15% 6 Fair allocation of total cost of service among the customer classes of service to attain equity...............................................15% 8 Dynamic in its ability to respond to changing supply and demand conditions and/or environmental concerns...........................10% 9 Simple and easy to understand; easy to administer........................................8% 2 Stability and predictability of the rates themselves.......................................6% 7 Avoidance of undue discrimination in rate relationships...............................3% 5 Reflects all present and future costs (internalities and externalities) and benefits of providing utility service................................2% 10 Freedom from controversy as to interpretation......................................... 1% Total Weighting ...........100%  In viewing the above weightings, it should be noted that the “bottom 5” attributes were also prioritized and given different weightings. In prior discussions with WRAB, it was initially proposed that the “bottom 5” attributes would be weighted equally. After further thought, it was concluded that these attributes should also be prioritized and given different weighting based upon the votes received in the prioritization process. By doing so, the “bottom 5” was prioritized and weighted using the same methodology as was used for the “top 5.” Using the above percentage weighting, maximum scores for each attribute were developed. The sum of the total points for a “perfect” rate structure was set equal to 400 points. The total of 400 points was then divided between the ten attributes based upon the weighting shown in Table 4-3. Therefore, as an example, a high score on the first attribute; effectiveness in yielding total revenue requirements, was set equal to 80 points (20% x 400 points = 80 points). Scoring the lowest rating would have the opposite impact and score; a 80 points. A score in the middle was considered to be neutral and set equal to 0 (zero) points. Using this approach to scoring, a rate design may have very strong attributes in one area, but that positive attribute may be counter- balanced or outweighed by a negative attribute. All rate structures, and their effectiveness, are the sum or net of their positive and negative attributes. By using negative scores for low attributes, it provides the appropriate counter-balance within the scoring to properly reflect the lower or negative attributes. Evaluation of the Alternative Rate Structures 4-5  City of Boulder—Volume 1 – Evaluation of Water Rate Structures 4.4 Process Used to Score and Evaluate the Rate Structures It was determined that it would be most appropriate for EES to evaluate and score each of the rate structures using the evaluation criteria discussed above. To aid in this process and help assure a fair and balanced evaluation process, EES retained Mr. Tom Chesnutt of A&N Technical Services, Inc. to participate in the evaluation process. Mr. Chesnutt is nationally recognized for his work in the area of conservation-based water rates and his research and work with utilities in California using water budgets.  The evaluation panel consisted of Tom Gould, EES Project Manager, Shawn Koorn, EES project rate analyst and Tom Chesnutt, A&N Technical Services. The process used to evaluate the rate structures was a “round table” discussion of each rate structure and the group’s consensus on the scoring of each rate structure. In other words, the rate structures were not scored by each individual evaluator, and the final results reflect the average evaluation. Rather, each rate structure was evaluated and scored based upon the discussion and general consensus of the evaluators. While different individuals may score the rate structures differently than shown within this study, EES believes that the process used to score and evaluate the rate structures was consistent in both its application and the scores provided. 4.5 Summary of the Rate Structure Evaluation and Scoring The twenty-two (22) rate structures previously discussed in Section 3 of this report were evaluated in this study. As discussed previously, the original list of rate structures for evaluation purposes, presented by EES to the WRAB, was twenty (20). The WRAB identified two additional rate structures to be evaluated, and those two additional rate structures were included within the evaluation process. Shown below in Table 4-4 is a summary of the “Top 5” rate structures, as scored, using the evaluation criteria.  25 David M. Pekelney and Thomas W. Chesnutt, Landscape Water Conservation Programs: Evaluation of Water Budget Based Rate Structures, Prepared for the Metropolitan Water District of Southern California, (A&N Technical Services, Inc., September 1997). Evaluation of the Alternative Rate Structures 4-6  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Table 4-4 Summary of the “Top 5” Rate Structures Rate Structure Final Score NumberRate Structure Description (Out of 400) 10 Top scorer of rate structures 1 – 9 (#5 Seasonal rates with fixed thresholds and a 2-block winter rate), plus goal based incentives. 213 5 Seasonal rates with fixed thresholds and a 2-block winter rate. 195 19Top scorer of 11 – 18 (#17 4-block water budget; block 1 – fixed threshold, block 2 – “typical” lot size and irrigation requirements, succeeding blocks based on relationship to outdoor goal), with the target set and fixed each year. No monthly adjustments for weather and ET. 187 20Top Scorer of 11 – 19 (#19 4-block water budget; block 1 – fixed threshold, block 2 – “typical” lot size and irrigation requirements, succeeding blocks based upon relationship to outdoor goal. Target is set and fixed each year. No monthly adjustment for weather and ET.), plus a discount for city approved irrigation systems with rain sensors and weather-based controllers. 181 17 Indoor water use based upon a fixed threshold, with outdoor use determined based upon an assumed “typical” lot size and irrigation requirements. Succeeding blocks based upon relationship to outdoor goal. Billing period goals are adjusted for actual weather and ET. Forward looking goals are communicated via the monthly billing statement. 175 7 Seasonal rates with a fixed threshold adjusted based upon water supply availability and a 2-block winter rate. 175 As can be seen from the above table, there are actually six rate structures in the “Top 5.” There was a tie for the fifth highest score, so both rate structures have been included within the “Top 5.” In viewing Table 4-4, three of the rate structures are variations of “water budget” rate structures and three are variations of seasonal rate structures. It is the recommendation of EES that the rate structures shown above in Table 4-4 be further analyzed for their appropriateness for the city. In viewing Table 4-4 and the results, it is important to understand and recognize that the top scorer does not imply the “best” rate structure, nor does the lowest score imply the “worst” rate structure. Each rate structure must be further analyzed, evaluated and judged based upon the city-specific application or use of that rate structure. Simply stated, one rate structure that may work well for single-family residential customers may not work well or be appropriate for multi- family or commercial/industrial customers. At the same time, as these rate structures are being further evaluated, elements of those rate structures that are not included in the “Top 5” may be utilized and incorporated into the “Top 5” to further enhance and improve a rate structure (e.g. legal occupancy as a method of establishing first block consumption for multi-family customers). Evaluation of the Alternative Rate Structures 4-7  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Provided below in Table 4-5 is a summary of the scoring for all twenty-two rate structures. Table 4-5 Summary of the Scoring of the 22 Rate Structure Alternatives Rate Structure Final Score NumberRate Structure Description (Out of 400) 1 Current rate structure.......................................................................................139 2 Current rate structure modified for seasonal rates; 1-block winter..................146 3 Current rate structure modified for seasonal rates; 2-block winter..................143 4 Seasonal rates, fixed threshold; 1-block winter...............................................156 5 Seasonal rates, fixed threshold; 2-block winter...............................................195 6 Seasonal rates, AWC threshold based upon water supply, with 2-block winter..............................................................................................170 7 Seasonal rates, fixed threshold based upon water supply, with 2-block winter..............................................................................................175 8 Seasonal rates, 4-block summer, 1-block winter, uses AWC..........................146 9 Seasonal rates, 4-block summer, 1-block winter, uses fixed threshold...........156 10 Top scorer of rate structures 1 – 9 (#5), plus goal based incentives................213 11 3-block water budget; block 1 – AWC, block 2 – customer specific lot size, adjusted for weather and ET...........................................................154 12 Same as 11, with addition of customer specific turf type................................139 13 4-block water budget, block 1 – AWC, block 2 – customer specific lot size, succeeding blocks based upon relationship to outdoor goal..........158 14 Same as 13, but uses a fixed threshold for block 1..........................................161 15 4-block water budget; block 1 – AWC, block 2 – “typical” lot size, succeeding blocks based upon relationship to outdoor goal........................165 16 Same as 15, but uses class average usage to establish block 1........................170 17 Same as 15, but uses a fixed threshold to establish block 1............................175 18 3-block water budget; indoor and outdoor is summed as block 1...................123 19 Top scorer of 11 – 18 (#17), with the target set and fixed each year, no monthly adjustments for weather or ET......................................................187 20 Top scorer of 11 – 19 (#19), with a discount for city approved irrigation systems with rain sensors and weather-based controllers............................181 21 3-block water budget; block 1 based upon legal occupancy, block 2 – specific lot size and uses historical average monthly ET.............................163 22 3 block; blocks based upon PIF and meter size, water can be “loaned”..........142  Evaluation of the Alternative Rate Structures 4-8  City of Boulder—Volume 1 – Evaluation of Water Rate Structures As can be seen from Table 4-5, the scores ranged from a low of 123 to a high of 213. The city’s current rate structure was scored as 139. It received this low score not necessarily because of the structure, but rather because of the way in which it is being administered between classes of service and the questions surrounding the equity of that application. In our opinion, the city’s current rate structure is still a valid rate structure that can be improved via changes to the way it is applied. 4.6 Summary This section of the report has described the evaluation process used to review the twenty-two rate structure alternatives. From this process, six rate structures have been identified for further analysis, review and consideration. The next section of the report will begin the process of better defining these rate structures and evaluating them for potential use by the city. Evaluation of the Alternative Rate Structures 4-9  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Section 5 Selection of Final Rate Design Alternatives and Development of Block Thresholds 5.1 Introduction The previous section of the report evaluated twenty-two (22) water rate structures, and provided a list of six rate structures for further evaluation. While this screening process helped to narrow the numerous alternatives to a more manageable level, it did not begin the process of more clearly defining the specifics of the rate structure (e.g. size of the blocks, definition of seasons, etc.). The objective of this section of the report is to provide clarity and a detailed discussion of the approach and methodology that will be used to establish the various components of the rate structures for different customer classes. These structures were reviewed by the WRAB and approved as to form, prior to EES conducting any technical analysis related to pricing. This section of the report will not discuss or focus on price. The next step of the technical analysis is to use the findings and conclusion from this section of the report to then be able to begin the process of determining the pricing within each rate structure. 5.2 Review of the Top Scoring Rate Structures As noted in the previous section of the report, from the evaluation process, six rate structures were selected for further review. The rate structures were all inverted block rate structures. There were two basic rate structures – a seasonal rate structure and the water budget rate structure. Certain elements of the top scoring rate structures could be common to all (e.g. goal based incentives). In the screening process, the objective was to determine whether these additional elements “enhanced” or “detracted” from the overall rate structure. At the same time, it was recognized that these rate structures would need to be further refined to better reflect the specific customers being served. Therefore, the six “screened” rate structures provided the starting point for further refining and enhancing the structures to match the specific objectives of the city. Provided below in Table 5-1 is a summary of the six rate structures that were selected for further review and development. Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-1  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Table 5-1 Summary of the “Top Scoring” Rate Structures Rate Structure Final Score NumberRate Structure Description (Out of 400) 10 Top scorer of rate structures 1 – 9 (#5 Seasonal rates with fixed thresholds and a 2-block winter rate), plus goal based incentives. 213 5 Seasonal rates with fixed thresholds and a 2-block winter rate. 195 21Top scorer of 11 – 18 (#17 4-block water budget; block 1 – fixed threshold, block 2 – “typical” lot size and irrigation requirements, succeeding blocks based on relationship to outdoor goal), with the target set and fixed each year. No monthly adjustments for weather and ET. 187 22Top Scorer of 11 – 19 (#19 4-block water budget; block 1 – fixed threshold, block 2 – “typical” lot size and irrigation requirements, succeeding blocks based upon relationship to outdoor goal. Target is set and fixed each year. No monthly adjustment for weather and ET.), plus a discount for city approved irrigation systems with rain sensors and weather-based controllers. 181 17 Indoor water use based upon a fixed threshold, with outdoor use determined based upon an assumed “typical” lot size and irrigation requirements. Succeeding blocks based upon relationship to outdoor goal. Billing period goals are adjusted for actual weather and ET. Forward looking goals are communicated via the monthly billing statement. 175 7 Seasonal rates with a fixed threshold adjusted based upon water supply availability and a 2-block winter rate. 175 From the above list, individual WRAB members provided comments and suggestions to the city for enhancing the rate structures noted above. Given these additional comments and suggestions, it was determined that for purposes of this study, the number of rate structures to be reviewed should remain at a maximum of 5 to 7, and that the final 5 to 7 rate structures should attempt to incorporate, as best as possible, the various comments and suggestions that were received from the various parties. Provided below is a detailed discussion of the approach used to establish the final set of rate structures that will be further evaluated for each customer class of service. 5.3 Establishment of Customer Classes of Service Each class of service places different demands upon the system, while at the same time, the city may have different objectives (e.g. conservation) for the various types of customers served on the Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-2  City of Boulder—Volume 1 – Evaluation of Water Rate Structures system. Given this challenge, it is often advisable and prudent to establish water rates by customer class of service. In establishing customer classes of service, two criteria are often used. Customer classes of service are often established around facility requirements and usage characteristics. As an example, a single-family residential customer has significantly different facility requirements and usage patterns, when compared to a large industrial customer. A single-family customer may be served via a ¾” meter, while the industrial customer is served via a 6” meter. Their usage patterns may also vary significantly. The industrial customer may be fairly even in their use from day-to-day and from month-to-month. In contrast, a single-family residential customer may have large swings in their consumption from season-to-season, with their highest peak use a function of lawn sprinkling (irrigation). In the case of the city, it is proposed that for each customer class of service, rate structures be utilized that reflect the specific characteristics of the class of service, along with any administrative/billing considerations. For the city, it is recommended that five distinct customer classes of service be considered for purposes of designing water rates. These five customer classes of service are as follows: Single-Family Residential Large Users Multi-Family Residential Metered Irrigation Commercial One of the concepts suggested by some individual members of WRAB for commercial and large users is establishing numerous sub-categories of classes of service (e.g. grocery stores, office buildings, restaurants, etc.) and ultimately individual rates for each subcategory. EES agrees that any new billing system selected by the city should have the capability to collect and report data by selected subcategories. This information can be very useful for identifying consumption trends and usage characteristics of subcategory customers, and in developing and implementing conservation programs.  For rate setting purposes, our understanding of the subcategory rate concept is that each subcategory rate has a first block of consumption that is based upon either the subcategory average use, or “best of class.” It may also be based upon a standard of “gallons/unit/day” where the “unit” is defined for each type of subcategory. Examples of the units may be the square footage of the building, number of students in a school, seats in a restaurant, beds in a hospital, members of a church or country club, etc. While these standards can be established, it does create various issues from a rate setting perspective. It appears that the main objective in proposing a subcategory rate setting approach is to segregate customers by business type and to identify those customers that have “inefficient” consumption. While this approach may appear logical from a conceptual standpoint, EES believes that there are significant drawbacks and equity issues associated with this approach. Most significantly, to  26 AWWA Research Foundation and the American Water Works Association, Commercial and Institutional End Uses of Water, AWWARF, 2000. Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-3  City of Boulder—Volume 1 – Evaluation of Water Rate Structures assume that any consumption over and above the “subcategory” average or per unit volume is “inefficient” use is, in our opinion, flawed and inappropriate as a method to establish rates. If the city’s main objective is to identify and work with “inefficient” commercial users, then the city should focus on collecting commercial/large user data by subcategory, identify those users that may appear to have high/inefficient use, and provide conservation audits to that customer. Given the above noted issues and discussion on subcategories, EES would recommend that the city establish and collect consumption data by subcategory, but establish rates at the current time using two customer classes of service – commercial and large user. In order to classify the city’s customers to a class of service, each customer class of service must be defined. Provided below is a set of definitions for each of the five customer classes of service. These definitions may be refined over time to help clarify any unique customer class characteristics. S-FR INGLEAMILY ESIDENTIAL Single-family residential shall include: one single-family dwelling, one single-family dwelling which includes an accessory dwelling unit within the dwelling, or one common wall single- family unit all served by a single meter. M-FR ULTIAMILY ESIDENTIAL A multi-family structure or facility shall mean any residential structure or facility containing two (2) or more dwelling units, including, but not limited to, duplexes, triplexes, apartment buildings, condominiums, trailer parks and parcels containing two (2) or more separate dwelling units served through common meter(s), but shall not include hotels or motels. C OMMERCIAL Commercial shall include all uses not classified as single-family residential, multi-family residential, large user, or irrigation, and shall include, but not be limited to, structures used for retail sales, offices, manufacturing, schools, convalescent centers and nursing homes, and each such business shall be considered as a separate unit even though two or more may be in the same building. In the event there is more than one type of operation in the same building, and the operations are seperately metered, (i.e., a professional office, a retail store, a restaurant, or an apartment) then each separate category or type shall pay at the rate fixed under that particular category or type. LU ARGE SER Large users are defined as customers whose individually metered average annual monthly potable water consumption is in excess of 2,500,000 gallons per month. This breakpoint was determined by reviewing consumption data for the city’s commercial and industrial customers and represents the highest level of usage on a monthly basis. The majority of the commercial and industrial customers fall below this breakpoint of 2.5 million gallons a month. Those customers that use in excess of 2.5 million gallons a month would then be classified as the large user customer class of service. The average annual monthly consumption shall be calculated on the average of the most recent three-year period. The three-year period shall be based upon the three most-recent calendar years. An exception and modification shall be made to adjust for those years that are designated as drought years or contain extraordinary consumption. Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-4  City of Boulder—Volume 1 – Evaluation of Water Rate Structures MI ETERED RRIGATION This rate schedule applies to customers for purposes of irrigation. Irrigation shall include meters installed which serve primarily landscape irrigation systems and include meters which serve municipal park properties, except for those meters which serve only non-irrigation uses. Given the above customer classes of service, rate structures can be selected that best fit the characteristics of the various customer classes of service. 5.4 Definition of Seasons In the evaluation of the rate structures, the seasonal rate structures contained a “winter” and “summer” time period. In order to move forward and develop these alternatives, a clear definition of these two time periods is needed. For purposes of developing any rate structure that contains seasonality, the seasons shall be defined as follows: Winter Period – October through April Summer Period – May through September These seasonal definitions were selected since the summer time period closely matches the seasonal usage patterns of the city. The importance of defining seasonal time periods is to allow for different pricing of water during different periods of demand and supply. 5.5 Defining the First (Initial) Block Size As mentioned previously, all of the proposed rate structures are inverted block rate structures. Regardless of the total number of blocks, all of the rate structures have an initial or first block of consumption. The purpose of this discussion is to define the intended consumption that should occur within the first block, and the methodology or basis for quantifying the block size. One of the weaknesses of many rate structures is the lack of rationale around which block sizes are established. One of the criticisms of the city’s existing water rate structure was the lack of a clear and rational basis for the establishment of the block sizes. The approach to be used herein attempts to eliminate that concern. Philosophically, for each rate structure, the first block should be established based upon some rational and reasonable amount. For single-family residential and multi-family residential customers, the philosophical basis to be used is “indoor” use. For commercial, large user and irrigation customers, a slightly different approach is used, whereby the average class consumption is used as the starting point for establishing the block size. Provided below is a detailed discussion of the approach used to establish the initial block size for each class of service. Single-Family Residential Initial Block Size – A number of different methods were examined to establish the first block for single-family residential customers. The basis for establishing the Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-5  City of Boulder—Volume 1 – Evaluation of Water Rate Structures block size is that it should reflect “indoor” use. While the city’s current use of AWC could be viewed as a method to establish “indoor” use for single-family residential customers, there appears to be a number of concerns with the AWC. The recent capping of the AWC at 8,000 gallons reflected one of the concerns related to “cheating” the system by inflating the AWC and corresponding block thresholds or by not encouraging efficient water use. Given that, AWC was not strongly considered as a method to establish the first block size for single-family residential customers. However, AWC will be used as a basis for establishing the initial block size for any rate alternatives that modify the existing (current) rate structure. The first method that was examined as a method to establish the first block size was based upon the single-family class average use in the winter period. Based upon a three-year average, this produced a block size of 5,200 gallons/month. The next method examined was suggested by individual members of WRAB. Under this approach, the first block would be established based upon an assumed 150 gallons/day/household. Assuming 30 days in a month, this equates to a first block size of 4,500 gallons/month. The third method reviewed was using the city’s planning criteria. Based on preliminary information used by the Planning Department, the city assumes that single-family homes have 2.2 occupants, and a reasonable amount of water for indoor use is 66 gallons/capita/day. Using these assumptions, this is the equivalent of 143  gallons/day/household or 4,356 gallons/month. Another potential method that was considered for establishing the initial block size was fixture counts. Each type of fixture has an assumed use, and when added together, each individual household would have an individual block size. The use of fixture counts was deemed to be too administratively complex and was eliminated for that reason. The three basic methods discussed above all appear to provide comparable results. In discussions with the city, it was determined that the final selected block size should be rounded to thousands of gallons. This rounding was suggested to simplify the administration of the rate. The city and EES believe that the methodology using the average number of occupants (2.2) and a per capita usage provided the most rational basis for the establishment of the block size. With rounding to thousands of gallons, this method would imply an initial block size of 5,000 gallons per month. The initial block size should be consistent, season-to-season and month-to-month. That is, the initial block size should be the same each month, which in this case, for single-family residential, is 5,000 gallons per month. M-FRIBS ULTIAMILY ESIDENTIAL NITIALLOCK IZE The establishment of the first block size for multi-family residential considered three different approaches. The first approach considered a class average AWC per unit, multiplied by the number of units, to establish the total block size. This method was not pursued since there were concerns about using the class average AWC. Given that AWC changes from year-to-year, by definition, the initial block size may also change from year-to-year. The next method reviewed used a value of 100 – 125 gallons/day/unit to establish the block size. This amount per unit was  27 City of Boulder Water Conservation Futures Study (Hydrosphere and Aquacraft, 2000). Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-6  City of Boulder—Volume 1 – Evaluation of Water Rate Structures suggested by an individual WRAB member and is comparable to multi-family per unit volumes assumed within the industry. Under this approach, the block size may be in the range of 3,000 – 3,750 gallons/unit/month. The final approach considered was to develop the consumption per unit, in relationship to the single-family residential block size. Under this approach, a multi- family residential customer would be provided, on a per unit basis, the equivalent of 80% of the block size established for the single-family residential class of service. Using this method, this would equate to 4,000 gallons/unit/month (5,000 gallons x 80% = 4,000 gallons). This last approach was deemed to be the most appropriate since it had a clear relationship to the single- family residential block size, and would be stable from year-to-year. The use of 80% is a common and reasonable factor for establishing the relationship between single-family residential consumption and multi-family residential per unit consumption, and has been used in the past by the city as a reasonable measure of multi-family residential per unit “indoor” consumption in Plant Investment Fee (PIF) calculations. As with the single-family residential class of service, the initial block size for multi-family residential will be consistent month-to-month. CLUIBS OMMERCIAL AND ARGE SERNITIAL LOCK IZE For these two customer classes of service, a consistent methodology needs to be established to determine the initial block size. Up to this point, the focus has been on “indoor” use when reviewing single-family and multi-family residential. Many of the commercial and large user customers certainly have an “indoor” and “outdoor” component to their consumption. However, the approach used to establish the single-family and multi-family initial block sizes does not work well for these two customer classes of service.Therefore, two alternative methodologies to establish the initial block sizes were reviewed. The first method considered each individual customer’s AWC to establish the initial block size. One of the issues that the city is aware of concerning the use of AWC for commercial customers is the seasonal nature of some businesses, and the fact that the AWC may not account for the seasonality aspect. Therefore, the alternative methodology would be very similar to the previous approach, but the first block would be established based upon the annual average monthly use. Under this approach, the average reflects both winter and summer usage, and not just winter period use. The city believes that this approach is fairly comparable to using the AWC, but has the potential to address some of the concerns the commercial customers have raised. Therefore, it is recommended that annual average monthly consumption be used to establish the initial block size for commercial and large user customers. Individual WRAB members have suggested another alternative approach that may be considered and implemented by the city at a later date. Under this approach, commercial customers would be categorized into separate sub-categories or classes (e.g. restaurants, supermarkets, etc), and block sizes be developed based upon the sub-class average. It has also been suggested that water budgets may be established on a gallons per square foot basis of the establishment. As discussed previously, the city, at this point in time, believes that the most effective method to encourage conservation from these customers is to work directly with them, conduct conservation audits, and use other methods (e.g. equipment rebates) to encourage efficient use. Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-7  City of Boulder—Volume 1 – Evaluation of Water Rate Structures MIIBS ETERED RRIGATION NITIAL LOCKIZE Obviously, metered irrigation customers do not have “indoor” use. Therefore, the initial block size should be based upon the irrigation needs of the specific customer, and any succeeding blocks should reflect “inefficient” use. Under this approach, the specific area needing irrigation is measured to determine the initial block size and then multiplied by an assumed per square foot application rate, to determine the total volume of water within the initial block. In measuring irrigable area, the area will be rounded to the nearest 100 square feet, to simplify the administrative aspects of determining the initial block size. The irrigable lot area will be multiplied by 15 gallons/square foot to determine the annual volume of water. This volume of water per square foot assumes a turf grass irrigation need. Finally, the annual requirement will be shaped to the monthly requirements using evapotranspiration (ET). This aspect of developing the block size is discussed in more detail under the second (outdoor) block size determination. The other approach that was reviewed for determining initial block size was to use 90% of the customer’s average summer consumption. 5.6 Defining the Second Block Size Each of the rate structures has a second block component within the rate structure. The second block size is critical in those instances where there are at least three blocks to the rate structure. For example, the seasonal rate structure in the winter time only has two blocks, but in the summer time it has three blocks. Therefore, in the winter time, the second block is all consumption over and above the first block. In contrast to this, the summer time period must define a second block size. How the second block size is determined will be the focus of this discussion. The primary or philosophical basis for establishing the second block size is outdoor watering needs. This is particularly true for single-family and multi-family residential customers. Therefore, for the single-family and multi-family customers, irrigable requirements will be factored into the determination. At the same time, the irrigable requirements may be “shaped” to reflect evapotranspiration (ET) and differing irrigation needs. Provided below is a discussion of the development of the second block size for the various customer classes of service. S-FRSBS INGLEAMILY ESIDENTIAL ECONDLOCKIZE The second block for single-family residential customers should reflect the irrigation requirements of these customers. The general approach is to consider the amount of area to be irrigated and multiply that area by the assumed irrigation requirements on a per square foot basis. Three different approaches were reviewed to determine irrigation needs and the area to be irrigated. The first approach would require the city to measure each individual customer’s irrigable area. Alternatively, the city can work from existing data that may group single-family lots into various size categories. From these lot size categories, average irrigation requirements could be determined. Finally, the city can assume an “average” size lot and irrigation needs. In reviewing each of these methods, the city was concerned with the level of effort and cost associated with measuring individual customer properties and irrigable areas. Using the first approach could also potentially create a large number of appeals by customers claiming that their property was incorrectly measured. Given those concerns, the first method of individually Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-8  City of Boulder—Volume 1 – Evaluation of Water Rate Structures measuring customer lots was not considered for use within this study. The next alternative is to group customers into various sized lots, by potentially using existing data and information. The city collects data for stormwater/flood management fees and groups single-family residential customers into lot sizes of 0 – 15,000 square feet, 15,001 – 30,000 square feet, and greater than 30,000 square feet. In reviewing the data, over 93% of the single-family residential lots (inside- city residents) fell into the first “bin” of 0 – 15,000 square feet. Given the magnitude of customers that fall into the first “bin” it was unclear as to the advantage of creating three “bins” or categories for single-family lot sizes, using the breakpoints from the flood data. From a geographical information system (GIS) analysis, property densities and building footprints were examined. Table 5-2 provides a summary of this analysis. Table 5-2 Summary of the GIS Analysis of Average Parcel (Lot) Sizes Lot Size Definition From Zoning Code Lot Size (Sq. Ft.)  Rural/Estates– Total Lot Size 19,311 Building Footprint 2,232 Low Density – Total Lot Size 9,940 Building Footprint 1,684 Medium Density – Total Lot Size 6,360 Building Footprint 2,234 Neither the stormwater/flood management fee information nor the GIS data appeared to provide obvious or easy groups to segregate the single-family residential customers. The final approach that was reviewed was to establish an assumed lot size and determine the irrigable needs of that lot size. From the information reviewed above, an average lot size of 9,000 square feet was established. This lot size should capture the vast majority of single-family lot sizes in the city. From this assumed lot size, assumed impervious areas were subtracted. For this analysis, it was assumed that the building footprint was 2,500 square feet, a patio was 200 square feet (10’ x 20’), a driveway is 600 square feet (20’ x 30’), and a garage is 500 square feet (20’ x 25’). Sidewalks were not included to recognize the numerous differences in individual property, and to keep the impervious area to a reasonable total. The total for the assumed impervious area is 3,800 square feet. This leaves an irrigable area of 5,200 square feet. Turf grass annually requires approximately 18 gallons/square foot (conservative requirement without any irrigation efficiencies) for irrigation purposes. However, the annual requirement of 18 gallons/square feet can be adjusted downward to reflect irrigation efficiencies which may still result in a healthy, sustainable lawn. After reviewing the initial block sizes, the city selected an adjustment factor of approximately 80% to reflect the efficiencies which result in an application rate of 15 gallons/square foot. Using these assumptions, the calculated irrigation requirement is approximately 78,000 gallons. An important objective of the city is to minimize the administrative requirements, along with the number of customer appeals for variances. For past planning purposes the city had assumed Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-9  City of Boulder—Volume 1 – Evaluation of Water Rate Structures 60,000 gallons of water use during the summer time irrigation period. Therefore, in order to help minimize the potential number of appeals, the typical lot size of 9,000 square feet will be used, with summer irrigation requirements of 78,000 gallons. Based upon these assumptions, the irrigation requirements per square foot, based upon total lot size (pervious and impervious), is 8.66 gallons/square foot. If a customer appeals for a variance, their total lot size would be measured and multiplied by 8.66 gallons to determine their irrigation needs. One of the concepts noted earlier was the establishment of groups of lot sizes (i.e. bins) to create a more equitable establishment of irrigation needs. The above approach can be modified to achieve this objective. Provided below in Table 5-3 is an example of this approach. Table 5-3 Establishing Irrigation Requirements For Varying Lot Sizes (Bins) Lot Sizes (Categories) Determination of Annual Water First 9,000 square feet of the total lot size 8.66 gallons/square foot (Assumes 5,200 sq. ft. irrigable area @15 gallons/s.f.) Next 9,000 square feet of the total lot size 12.00 gallons/square foot (Assumes 9,000 sq. ft. irrigable area @ 12 gallons/s.f.) All over 18,000 square feet of the total lot size 10.00 gallons/square foot Example: Assuming a 20,000 square foot lot: 9,000 square feet x 8.66 gallons/square foot = 78,000 gallons 9,000 square feet x 12.00 gallons/square foot = 108,000 gallons 2,000 square feet x 10.00 gallons/square foot = 20,000 gallons 20,000 square feet 206,000 gallons As can be seen in Table 5-3, the allocation per square foot is decreased as the lot size increases. It is presumed that the lot is planted with less turf grass, and instead contains plantings requiring lower irrigation needs. At the same time, the city desires to encourage owners of larger lots to landscape with grass and plantings that use less water per square foot, when compared to turf grass, or to use efficient irrigation techniques. If desired, the approach shown above in Table 5-3 could also be used to establish only two bin sizes. In that case, the third bin size would be eliminated and all square footage over the initial 9,000 square feet would be provided 12 gallons/square foot. Another approach that has been suggested for establishing “individualized” block sizes for single-family residential is to use the tax assessed lot size for each parcel. Under this approach, the tax assessed lot size would be multiplied by 8.66 gallons per square foot to determine the block size. An alternative to this, which is based upon the approach shown in Table 5-3, is to use 8.66 gallons per square foot for the first 9,000 square feet, and 12 gallons per square foot for all square footage over the initial 9,000 square feet allocation. Using the above approaches, block sizes can be established for any of the rate structure alternatives being reviewed by the city. The remaining issue concerning block 2, is how it is shaped for irrigation needs. Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-10  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Given a total amount of water needed for outdoor irrigation, the focus shifts to the potential shaping of the water to reflect the monthly irrigation requirements and ET. One method that can be used to accomplish this is to use the Boulder ET and shape the water into monthly allocations to create the block size for each month. In discussions with the city, it was noted that two items should be taken into account in establishing the annual shape of monthly water required for irri- gation purposes. First, from a water supply perspective, the city incurs three different periods. The first period is a “direct flow” period. This period is generally May and June. At the end of the “direct flow” period, the city relies primarily upon its supply storage for water supply. This period is generally July through September. The remaining months of October through April is considered the non-irrigation period from a supply perspective. The importance of distinguish- ing the supply periods is that the city wants to encourage irrigation in an efficient manner during the direct flow period of May and June. Therefore, the city has indicated that the second block size for the months of May and June should be sized to encourage irrigation use in an efficient manner. Given that, in establishing the block sizes for May and June, they will not be based upon ET, but rather, set equal to the block size for July, which is based upon ET. The second issue that needs to be taken into account in shaping the block sizes is that the city also wants to encourage irrigation of trees and shrubs during the winter period. 25,0000.60 Therefore, during the winter 0.50 20,000 period, the block size is pro- 0.40 vided with extra water to allow 15,000 Block 2 0.30 for irrigation of trees and Ave. ETo 10,000 shrubs. 0.20 5,000 0.10 The average ET for the city was 00.00 used as a starting point for shaping the annual water re- quirements. The single-family allowance of 78,000 gallons was allocated over the average monthly ET. At the same time, the allocation of water for May and June was increased to equal the allocation in July (12,000 gallons). This additional water in May and June is over and above the original 78,000 gallon allocation. This additional allocation of water in May and June adds approximately 8,000 gallons for irrigation purposes during this period. Finally, during the winter period, additional allocations of water have been added to allow for irrigation of trees. This additional allocation of water in the winter period adds approximately 25,000 gallons of water over the months of November through April. The chart above shows the relationship between the city’s average ET and the final block sizes established for block 2. Given this approach to establishing the shape and allocation of water for irrigation purposes, the final allocation of water for the 9,000 square foot single-family residential lot would be78,000 gallons. One concept that has been discussed previously is the “banking” of water. “Banking” of water would allow a customer to carry-forward any unused allocation of water in a particular month to another month. While “banking” of water may be useful from a customer perspective there are two drawbacks from the city’s perspective. First, the administrative complexity of “banking” could be significant and problematic. Secondly, and more importantly, is that the city does not want customer’s to “bank” their water from the “direct flow” period and shift their “banked” consumption to the peak irrigation periods. By doing so, it defeats the entire purpose of shaping Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-11  City of Boulder—Volume 1 – Evaluation of Water Rate Structures the water block size to the irrigation requirements. Therefore, our recommendation would be to disallow any “banking” of water by customers. M-FRSBS ULTIAMILY ESIDENTIAL ECONDLOCKIZE Establishing the second block size for multi-family customers is similar to the approach used for single-family residential. One of the issues surrounding multi-family residential customers was the fact that there are multi-family customers that have metered irrigation, and those that do not. Consideration was given to establishing two multi-family rate schedules, with and without metered irrigation. In discussing this issue further, the city believed that this was not necessary or desirable at this time. Most of the larger multi-family customers with significant irrigation requirements are already metered for irrigation. It was suggested that a three block rate structure could be established in which the second block is based upon the specific irrigable area of each multi-family customer. This irrigable area could be determined from the data collected and used to calculate the stormwater/flood management fee. Using the relationship determined in the single-family residential analysis, the irrigable area for each customer would be multiplied by 15 gallons per square foot to determine the annual volume for the second block size. As with the single-family residential customers, this annual volume of water, determined for each specific customer would be shaped based upon historical monthly ET. The above approach should be acceptable to both metered irrigation and non-metered irrigation multi-family customers. The assumption is that any multi-family customer that has metered irrigation should not use any significant amounts of block 2 water, and should never be billed for block 3 water. In contrast, the multi-family customer that does not have metered irrigation is provided an allocation of block 2 water that is based upon their specific irrigable area. C/LUSBS OMMERCIALARGE SERECOND LOCK IZE For the commercial/large user customers, it is proposed that a two block rate structure be utilized. Therefore, the second block will represent all consumption over and above the first block consumption. As discussed previously, each individual customer will have a first block established based upon their specific consumption characteristics (annual average monthly). Many of these customers have irrigation meters and as a result, the second block of consumption does not relate to outdoor usage. Furthermore, there are commercial customers that have minimal irrigation requirements, if any. Therefore, the focus of this class of service is not necessarily on outdoor consumption. As mentioned previously, the city believes that working directly with the customers and establishing “best management practices” is the most effective tool for achieving efficient water use with these customers. Given that, it did not appear reasonable or prudent to establish additional blocks, beyond the second block, for this group of customers. MISBS ETERED RRIGATION ECOND LOCKIZE Initially it was proposed that a maximum of a two-block rate structure be used for the metered irrigation customers and block 2 would be all usage over block 1. However, in discussion with the city it was determined that a three-block rate structure would be proposed at this time. Similar to block 2 for the other customer classes of service, the first block for metered irrigation is established based upon the customer’s specific irrigable area. Therefore, the second block for Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-12  City of Boulder—Volume 1 – Evaluation of Water Rate Structures metered irrigation will be calculated in the same manner as the third and fourth blocks for the other customer classes of service and will be set at 101% to 150% of block 1. For example, if block 1 is 10,000 gallons then block 2 will be 10,001 – 15,000 gallons, or 50% of block 1. All consumption over block 2 will then be charged at the block 3 rate. 5.7 Defining Third and Fourth Block Sizes There are certain rate structures that have third and fourth block sizes. In all cases, the block sizes are based upon the relationship to the “goal.” Previously, block 3 may have been described as “101% to 150% of Goal.” The question that arises is how the “goal” is defined. The “goal” may be defined as the outdoor goal only (i.e. block 2), or the sum of both the indoor and outdoor goals (i.e. the sum of block 1 and block 2). Essentially, how the “goal” is defined creates different block sizes. Provided below in Table 5-4 is a simple example of this issue. Table 5-4 Defining the “Goal” for Establishing Block 3 and 4 Rate Indoor + Outdoor ndstnd Block Outdoor (2 Block) = Goal (1 & 2 Block) = Goal Block 1 0 – 5,000 gallons 0 – 5,000 gallons Block 2 5,001 – 15,000 gallons 5,001 – 15,000 gallons Block 3 (101 – 150% of Goal) 15,001 – 20,000 gallons 15,001 – 22,500 gallons Block 4 (All Excess Use) All Use Over 20,000 gallons All Use Over 22,500 gallons As can be seen above in Table 5-4, how the “goal” is defined changes the block sizes. For nd purposes of this study, the “goal” shall be defined as outdoor use only (i.e. 2 block consumption). This definition was selected since many water budgets and traditional rate structures target outdoor use, and customers that are billed in block 3 or 4 are using water greater than their defined needs. Furthermore, the majority of customers that will be billed in block 3 or 4 will likely be during the summer irrigation period. They will have most likely encountered block 3 or 4 as a result of inefficient outdoor watering, and not inefficient indoor use. Using the above approach for establishing the size of the third block, the graph provides an example of the size of the blocks, the shaping of the second block, and the total consumption for the first three blocks. Using the example in Table 4, the third consumption block is set at 101% to 150% of the second, or outdoor use block size. In other words, the third block size is 50% of the second block. As shown in Table 4, if the second block size is 10,000 gallons then the third block size would be 5,000 gallons. In this particular example, all consumption over and above Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-13  City of Boulder—Volume 1 – Evaluation of Water Rate Structures block 3 would then be charged at the higher block 4 rate. Depending upon the specific rate structure and class of service, the various block sizes will change. However, the general shape of nd the curve should remain fairly consistent given the use of the city’s ET to shape the 2 block for each class of service. 5.8 Other Rate Design Features Within the original “top scoring” rate structures shown on Table 5-1, there are features which can be applied to any of the final rate structures developed (e.g. adjustment for water supply conditions, incentives for exceeding goals, etc.). In other cases, the feature may be administrative, and not necessarily structural (e.g. adjusting for actual ET for billing purposes). While developing the evaluation process, it was important to determine whether these “features” enhanced or detracted from the rate designs. Given that these features can be applied to any of the final rate designs, for purposes of developing further detailed evaluations of the rate structure, these features will be removed from the analysis. By doing so, it “collapses” certain “top scoring” rate structures into identical rate alternatives. For example, the only difference between the original rate structures #5 and #10 is the use of goal-based incentives on #10. In summary, the four features that will be taken out of the evaluation process at this point, and potentially added back in later, include the following: Adjustment of blocks and price for water supply availability Goal based incentives  Adjustment of block sizes for actual ET (weather) Discounts for city approved irrigation systems 5.9 Consideration of Modifications to the City’s Existing Rate Structure The city recognizes that many of the rate structures being discussed within this study cannot be immediately implemented due to the limitations of the city’s current billing system. Therefore, one of issues discussed is whether the city’s existing rate structure can be modified to address some of the concerns that have been raised in the past. These modifications may be a way to transition to a new rate structure, or may be of a level of acceptability that they would be used going forward. In reviewing the existing rate structure for each class of service, the city felt that the rate structure as it applied to multi-family residential, commercial and metered irrigation was acceptable for the time being, or that the constraints of the city’s billing system did not allow for meaningful modifications. Therefore, the focus was on the modifications that could be made to the existing single-family residential rate structure.  28 “Goal-based incentives” are related to block 2 usage, and rewards a customer for consuming less then their block 2 allotment in the peak use period. For example, if a customer has a block 2 size of 10,000 gallons, and uses only 8,000 gallons in the month, they would be given a credit for 2,000 gallons times a fixed incentive rate. The customer is still charged the standard rate for the 8,000 gallons consumed, but is given some level of credit (reward) for consuming below their allotted amount. Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-14  City of Boulder—Volume 1 – Evaluation of Water Rate Structures S-FRM INGLEAMILY ESIDENTIAL ODIFICATIONS For single-family residential, the existing rate could be modified to improve the assumptions concerning the second block size. The first block size would remain at its current structure; AWC capped at 8,000 gallons. The second block size would be established in a manner similar to that discussed earlier. That is, single-family residential customers would be provided with a nd 2 block size that is based upon the July requirements of 16,000 gallons of water. The third block would be all consumption over and above the second block. At this point, it is unclear whether the city’s existing billing system could bill for a shaped block based upon ET. If the nd city’s existing billing system can handle a shaped 2 block, then that is the approach that would be used. 5.10 Specific Rate Structures to Be Evaluated By Class of Service The above discussion has examined a number of areas of the potential rate structures for each class of service. Specifically, this technical memorandum has indicated the need for and defined the customer classes of service to be used for rate design purposes. At the same time, for each class of service, the methodology to be used to establish the first and second blocks of the various rate designs have been provided. Therefore, the final step in defining the rate structures to be further evaluated is to incorporate those findings into the various “top scoring” rate structures. In working with the “top scoring” rate structures, it was noted that these structures would need to be modified to better conform to the specific characteristics of each class of service. At the same time, the city’s existing rate structure could be modified for the single-family residential customers to better meet the goals and objectives of the city. Given that, specific rate structure alternatives have been developed for each class of service (see below). A main objective in developing these alternatives was to incorporate input from both city staff and the individual WRAB members who provided comments as well as to improve and tailor the rate structures for each class of service. Provided below is a summary of the specific rate structures to be developed and quantified for purposes of further evaluation by customer class. Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-15  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Single-Family Residential Rate Structures To Be Evaluated S-FRRS1–SDR INGLEAMILY ESIDENTIAL ATETRUCTURE EASONALLY IFFERENTIATED ATE SWA2-BWRAA3-BSR. TRUCTURE ITHLOCK INTER ATENDLOCK UMMER ATE Basis for Block Determining Block Size Pricing of the Block Winter Period - Block 1 First 5,000 gallons Inverted Block Winter Price Block 2 All Usage Over 5,000 gallons Inverted Block Winter Price Summer Period - st Block 1 First 5,000 gallons Same Price as 1 Block Winter Block 2 Next 16,000 gallons Inverted Block Summer Price Block 3 All Usage Over 21,000 gallons Inverted Block Summer Price S-FRRS2–WBWF(4) INGLEAMILY ESIDENTIAL ATETRUCTURE ATERUDGET ITHOUR CB.B1IFFIU,B2IBUT ONSUMPTION LOCKSLOCK SIXED ORNDOOR SELOCK SASED PONHE IROA9,000SFLS,AB3U150% RRIGATION EQUIREMENTS FQUAREOOT OTIZEND LOCK SES OB2TDS. FLOCKOETERMINE IZE Basis for Block Determining Block Size Pricing of the Block Block 1 First 5,000 gallons Inverted Block Price [1] Block 2 Varies by Month - Uses 9,000 sq. ft. Inverted Block Price Block 3 101% to 150% of Outdoor Goal Inverted Block Price Block 4 Over 150% of Outdoor Goal Inverted Block Price [1] Each month will have a set outdoor goal based on an average lot size of 9,000 square feet and an outdoor application rate of 8.66 gallons per square foot of lot size. The monthly irrigation requirements will be shaped by historical weather and ET. Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-16  City of Boulder—Volume 1 – Evaluation of Water Rate Structures S-FRRS3–WBWF(4) INGLEAMILY ESIDENTIAL ATETRUCTURE ATERUDGET ITHOUR CB.B1IFFIU,B2UT ONSUMPTION LOCKSLOCK SIXED ORNDOOR SELOCK SESHREE D“B”DIR,AB3U125% IFFERENT INS TO ETERMINE RRIGATION EQUIREMENTSND LOCKSES OB2TDS. FLOCKOETERMINE IZE Basis for Block Determining Block Size Pricing of the Block Block 1 First 5,000 gallons Inverted Block Price [1] Block 2 Varies By Month – Uses 3 “Bins” Inverted Block Price Block 3 101% to 125% of Outdoor Goal Inverted Block Price Block 4 Over 125% of Outdoor Goal Inverted Block Price [1] Each month will have a set outdoor goal based on three separate lot size “bins” (0- 9,000 sq. ft., 9,001 – 18,000 sq. ft., and greater than 18,000 sq. ft.) and an outdoor application rate of 8.66 gallons per square foot of “typical” lot size. The irrigable requirements for the 0 –9,000 sq. ft. bin will be allocated based upon 9,000 sq. ft. The 9,001 – 18,000 sq. ft. bin size will be based upon 15,000 sq. ft, and the third bin will be based upon irrigable requirements for 24,000 sq. ft. The monthly irrigation requirements will be shaped by historical weather and ET. S-FRRS4–WBWF(5) INGLEAMILY ESIDENTIAL ATETRUCTURE ATERUDGET ITHIVE CB.B1IFFIU,B2IBT ONSUMPTION LOCKSLOCK SIXED ORNDOOR SELOCKSASEDAX ALS,B3I125%OB2,AB4I150%OB2. SSESSED OTIZELOCKSFLOCK NDLOCKSFLOCK Basis for Block Determining Block Size Pricing of the Block Block 1 First 5,000 gallons Inverted Block Price [1] Block 2 Varies–Uses Tax Assessed Lot Size Inverted Block Price Block 3 101% to 125% of Outdoor Goal Inverted Block Price Block 4 125% to 150% of Outdoor Goal Inverted Block Price Block 5 Over 150% of Outdoor Goal Inverted Block Price [1] Each month will have a set outdoor goal based on the tax assessed lot size and an irrigation application rate of 8.66 gallons per square foot of total assessed lot size. The monthly irrigation requirements will be shaped by historical weather and ET. Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-17  City of Boulder—Volume 1 – Evaluation of Water Rate Structures S-FRRS5–WF(4) INGLEAMILY ESIDENTIAL ATETRUCTURE ATER BUDGET WITH OUR CB.B1FFIU,B2BU ONSUMPTION LOCKSLOCK IS IXED ORNDOOR SELOCK IS ASEDPON ECPIS,D5,200F ITHER A USTOMER ROVIDEDRRIGABLE IZE OR A EFAULT OF SQUARE EET OF IA.SBBURB2. RRIGABLE REAUCCEEDINGLOCKSASED PONELATIONSHIP TO LOCK Basis for Block Determining Block Size Pricing of the Block Block 1 First 5,000 gallons Inverted Block Price [1] Block 2 Customer Provided or Default Size Inverted Block Price Block 3 101% to 125% of Outdoor Goal Inverted Block Price Block 4 Over 125% of Outdoor Goal Inverted Block Price [1] Each month will have a set outdoor goal based on either the customer provided irrigable area or assumed “default” irrigable area of 5,200 and an application rate of 15 gallons per square foot. The monthly irrigation requirements will be shaped by historical weather and ET. S-FRRS6–ECRS INGLEAMILY ESIDENTIAL ATETRUCTURE XISTING ITY ATE TRUCTURE MTRCCG. ODIFIEDOEFLECT URRENT ITY OALS Basis for Block Determining Block Size Pricing of the Block Block 1 AWC, capped at 8,000 gallons Inverted Block Price Block 2 Next 16,000 gallons Inverted Block Price Block 3 All Excess Usage Inverted Block Price Multi-Family Residential Rate Structures To Be Evaluated M-FRRS1–SDR ULTIAMILY ESIDENTIAL ATETRUCTURE EASONALLY IFFERENTIATED ATE S2-BWR2-BSR. TRUCTURE WITH A LOCKINTER ATE AND A LOCK UMMER ATE Basis for Block Determining Block Size Pricing of the Block Winter Period - Block 1 First 4,000 gallons per unit Inverted Block Winter Price Block 2 All Excess Usage Inverted Block Winter Price Summer Period - st Block 1 First 4,000 gallons per unit Same Price as 1 Block Winter Block 2 All Excess Usage Inverted Block Summer Price Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-18  City of Boulder—Volume 1 – Evaluation of Water Rate Structures M-FRRS2–WBWF(5) ULTIAMILY ESIDENTIAL ATETRUCTURE ATERUDGET ITH IVE CB.B1IAFPUT,B2IBO ONSUMPTION LOCKSLOCKSIXED ERNIT HRESHOLDLOCK SASEDN TCSIA,SBBU HEUSTOMER PECIFIC RRIGABLE REA AND UCCEEDING LOCKS ASEDPON RTOG. ELATIONSHIP OUTDOOROAL Basis for Block Determining Block Size Pricing of the Block Block 1 First 4,000 gallons per unit Inverted Block Price [1] Block 2 Varies By Month – Irrigable Area Inverted Block Price Block 3 101% to 125% of Outdoor Goal Inverted Block Price Block 4 125% to 150% of Outdoor Goal Inverted Block Price Block 5 Over 150% of Outdoor Goal Inverted Block Price [1] Each month will have a set outdoor goal based on the irrigable area as determined by the city and an irrigation application rate of 15 gallons per square foot. The monthly irrigation requirements will be shaped by historical weather and ET. M-FRRS3–WBWF(4) ULTIAMILY ESIDENTIAL ATETRUCTURE ATERUDGET ITH OUR CB.B1IAFPUT,B2IBO ONSUMPTION LOCKSLOCKSIXED ERNIT HRESHOLDLOCK SASEDN TCSIA,SBBU HEUSTOMER PECIFIC RRIGABLE REA AND UCCEEDING LOCKS ASEDPON RTOG. ELATIONSHIP OUTDOOROAL Basis for Block Determining Block Size Pricing of the Block Block 1 First 4,000 gallons per unit Inverted Block Price [1] Block 2 Varies By Month – Irrigable Area Inverted Block Price Block 3 101% to 125% of Outdoor Goal Inverted Block Price Block 4 Over 125% of Outdoor Goal Inverted Block Price [1] Each month will have a set outdoor goal based on the irrigable area as determined by the city and an irrigation application rate of 15 gallons per square foot. The monthly irrigation requirements will be shaped by historical weather and ET. Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-19  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Commercial/Large User Rate Structures to Be Evaluated C/LURS1–SDR OMMERCIALARGE SERATE TRUCTURE EASONALLY IFFERENTIATED ATE SWA2-BWRAA2-BSR. TRUCTURE ITHLOCK INTER ATENDLOCK UMMER ATE Basis for Block Determining Block Size Pricing of the Block Winter Period - [1] Block 1 Average Monthly Use Inverted Block Winter Price Block 2 All Usage Over Block 1 Inverted Block Winter Price Summer Period - [1]st Block 1 Average Monthly Use Same Price as 1 Block Winter Block 2 All Usage Over Block 1 Inverted Block Summer Price [1] Average monthly use is to be determined for each individual customer based upon a three-year average, reviewed and established periodically. The same block 1 size is used for both winter and summer time periods. C/URS2–SDR OMMERCIALLARGE SERATETRUCTURE EASONALLY IFFERENTIATED ATE SWA2-BWRAA2-BSR. TRUCTURE ITHLOCK INTER ATENDLOCK UMMER ATE Basis for Block Determining Block Size Pricing of the Block Winter Period - [1] Block 1 90% Average Monthly Use Inverted Block Winter Price Block 2 All Usage Over Block 1 Inverted Block Winter Price Summer Period - [1] Block 1 90% Average Monthly Use Same Price as Winter Block 1 Block 2 All Usage Over Block 1 Inverted Block Summer Price [1] Average monthly use is to be determined for each individual customer based upon a three-year average, reviewed and established periodically. The same block 1 size is used for both winter and summer time periods. The use of 90% represents the city’s perception of this class to improve water efficiency. Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-20  City of Boulder—Volume 1 – Evaluation of Water Rate Structures MIRSTBE ETEREDRRIGATION ATETRUCTURES OEVALUATED MIRS1–UR. ETERED RRIGATION ATETRUCTURE NIFORM ATE Basis for Block Determining Block Size Pricing of the Block Block 1 All Metered Consumption Fixed Price MIRS2–WT(3)C ETERED RRIGATION ATETRUCTURE ATER BUDGET WITH HREEONSUMPTION B.B1BUCSIA,S LOCKSLOCK IS ASEDPON USTOMER PECIFIC RRIGABLE REAUCCEEDING BBURTOG. LOCKS ARE ASED PON ELATIONSHIP OUTDOOROAL Basis for Block Determining Block Size Pricing of the Block [1] Block 1 Customer Specific Irrigable Area Inverted Block Price Block 2 101% to 150% of Outdoor Goal Inverted Block Price Block 3 Over 150% of Outdoor Goal Inverted Block Price [1] Each month will have a set outdoor goal based on the irrigable area as determined by the city and an irrigation application rate of 15 gallons per square foot. The monthly irrigation requirements will be shaped by historical weather and ET. MIRS3–WT(3)C ETERED RRIGATION ATETRUCTURE ATER BUDGET WITH HREEONSUMPTION B.B1BU90%C’AS LOCKSLOCK IS ASEDPON OF THE USTOMERSVERAGE UMMER C(ASC),SBBURTO ONSUMPTION UCCEEDING LOCKS ARE ASED PONELATIONSHIP OUTDOOR G. OAL Basis for Block Determining Block Size Pricing of the Block [1] Block 1 90% of Customer’s ASC Inverted Block Price Block 2 101% to 150% of Block 1 Inverted Block Price Block 3 Over 150% of Block 1 Inverted Block Price [1] Average summer consumption is to be determined for each individual customer based upon a three-year average, reviewed and established periodically. The use of 90% represents the city’s perception of this class to improve water efficiency. 5.11 Summary This section of the report has described the approach and methodology to be used to establish the classes of service and block sizes for the various rate structures to be evaluated. The next section of the report will discuss the development of the pricing for each of the rate structures. Selection of Final Rate Design Alternatives and Development of Block Thresholds 5-21  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Section 6 Development and Evaluation of the Rate Structures 6.1 Introduction The previous section of the report discussed the rate structures and the block thresholds for each customer class of service that are to be evaluated. An important element of the development of each rate structure is the pricing that is used for the fixed and variable portions of the rate design. This section of the report will review each of the rate designs and provide specific pricing for each. At the same time, bill comparisons will be provided to compare the rate structure being evaluated to the city’s existing rate structure. 6.2 Review of the City’s Existing Rate Structure In developing alternative rate structures, an important perspective is the city’s existing rate structure and the level of the prices within that rate structure. The city’s current rate structure is composed of both a fixed monthly service charge and a variable consumption charge. The fixed monthly service charge varies by the size of the customer’s meter. The consumption charge is a three (3) block structure. The size of the first block is established based upon the customer’s average winter consumption (AWC). The succeeding blocks of consumption are sized in relationship to the customer’s first block size. Within Section 2 of this report, a summary of the city’s existing rate structure was provided (Table 2-1). The city has established, in essence, two different rate schedules. The first rate schedule applies to residential and irrigation customers. Compared to the commercial/industrial rate schedule, the residential and irrigation rate has higher consumption charges for the second and third block. In addition, drought surcharges apply to the residential and irrigation customers, but not to those customers served under the commercial/industrial rate schedule during a drought period. In developing the bill comparisons for the rate structures reviewed, the city’s existing rates, for that particular type of customer (e.g. residential, commercial, etc.) will be used for the comparison. 6.3 Overview of the Approach to Pricing For each rate structure selected for further evaluation, an inverted block rate structure was proposed. Under an inverted block rate structure, the price per unit of consumption increases with additional consumption. The key issue associated with an inverted block rate structure is Development and Evaluation of the Rate Structures 6-1  City of Boulder—Volume 1 – Evaluation of Water Rate Structures the basis or justification for establishing the price within each block. At the same time, the final rate structure must produce the desired or target level of revenue for that specific class of service, based upon the price charged within each block, and the amount of consumption that is anticipated to occur within each block. The following discussion will focus on the cost-basis for the establishment of the prices within each block. It is from this approach that the final proposed rate structures will be developed. Traditional water utility rate setting uses an average embedded cost of service analysis to determine pricing for rate setting purposes. Average embedded pricing uses historical or accounting costs to establish price. Alternatively, marginal cost of service pricing is the cost associated with expanding system capacity. A more recent pricing perspective is value of  service pricing. “Instead of analyzing and allocating costs alone, value-of-service pricing involves factors that reflect customer perceptions about the value of utility service, as well as their willingness to pay for different levels or types of service. In other words, value of service pricing considers customer preferences beyond those traditionally represented in cost-based pricing.”  Pricing based upon marginal costs “theoretically provide the foundation for efficient use of existing system capacity as well as efficient capital investment in future capacity. True marginal costs, however, typically produce revenues that differ substantially from average cost rates, requiring modification to collect the proper level of revenue. In other words, if “pure”  marginal costs are used for pricing, the utility will over-recover their revenue requirement. Given that, marginal costs are often adjusted to collect the appropriate level of revenue for the utility. However, marginal cost theory and average cost approaches can often be successfully blended in water rate design. In general, this blended pricing approach will be utilized for the  city’s study. In an average embedded cost of service study, costs are classified to various cost components, and allocated to each customer class of service based upon proportional use. In very simplified form, the basic cost components for a water utility under an average embedded cost of service analysis are as follows: Base Costs – Base costs are those costs that tend to vary with the total quantity of water used under average load (demand) conditions. Extra-Capacity Costs – Extra-capacity costs are related to meeting the capacity (flow) needs of customers over and above their average demand conditions. Customer Costs – Costs related to the addition or deletion of a customer on the utility system, irrespective of the amount of water use. Fixed meter (service) charges generally include all of the costs classified as customer related costs, and may also include a portion of other fixed costs associated with the maintenance of the distribution system. In the case of the city, they have historically included the customer related costs, plus 30% of the cost of the city’s capital costs.  29 American Water Works Association M-1 Manual, Principles of Water Rates, Fees and Charges (Denver, CO, AWWA, Fifth Edition, 2000), p. 120. 30 Ibid. p. 161. 31 Ibid. p. 120. 32 Ibid. p. 120. Development and Evaluation of the Rate Structures 6-2  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Base costs are related to the total flow of water on the city’s system and represent average demand flow conditions. Base costs are allocated to each class of service on the basis of average volumetric use (demand), and as a result, the base cost, stated in $/1,000 gallons, is the same for all customer classes of service. Extra-capacity costs represent the difference between average demand usage and peak demand usage for each customer class of service. For those customers that tend to have a fairly level pattern of use year-round, they will have a small component of extra-capacity costs. In contrast, those customers that have wide variations of use (e.g. irrigation use) will have a larger allocation of extra-capacity costs. It is the difference in peak usage patterns that creates the difference in costs between customer classes of service. For a water utility, the costs associated with meeting peak use capacity requirements are significant. Given the above overview the cost components within the city’s cost of service analysis, the focus shifts to how the cost of service analysis will be used to establish prices for each customer class of service, and in particular for the different block sizes. The objective in developing the pricing was to establish prices based upon “cost of service” or other pricing approaches, and not to rely upon arbitrary methods. The general approach used in establishing the city’s prices is discussed in detail below. EES began by reviewing the city’s most recent cost of service study. Within that study, the  costs are classified by the basic cost components noted above. The customer related costs are stated as fixed per customer meter charges. EES has assumed that these costs provide the foundation or basis for establishing the fixed meter charges for the city. The volumetric costs are separated between base costs, extra-capacity peak day, and extra- capacity peak hour costs. While the cost of service makes the distinction between peak day and peak hour, for cost allocation purposes, no major distinction has been made within the pricing. To establish the first or initial block, it is assumed that base-related costs represent average demand conditions, which are relatively synonymous with the definition of the first block of consumption within the rate structures developed as a part of this report. Therefore, in general, base costs were used to establish the first block of each class of service. The second block is used to collect the extra-capacity costs of the system. Given that the demand patterns differ for each of the customer classes of service, different costs and prices result for each class of service. The second block price assumes the class capacity characteristics, or in other words, the class average use to peak use characteristics. In establishing the blocks beyond the second block, a different technique is used. Usage beyond the second block assumes that the customer is placing higher peak demands upon the system than the average customer within that class of service. Therefore, the higher use customer has a capacity peaking factor that is greater than the class average. In that case, the customer should   33 Integrated Utilities Group Final Report, Volume II, Water, Wastewater, and Stormwater Rate Study and Plant Investment Fee Analyses (November 2001). 34 Capacity peaking factor is a ratio that is the relationship between peak use and average demand. For example a customer with a peak use of 25,000 gallons and an average use of 12,500 gallons has a peaking factor of 2.0 (25,000/12,500). Development and Evaluation of the Rate Structures 6-3  City of Boulder—Volume 1 – Evaluation of Water Rate Structures be allocated a greater share of the extra capacity costs, which implies a greater price in $/1,000 gallons. In order to determine the prices for succeeding blocks, EES used the results of the city’s cost of service analysis, and assumed different peaking factors for a class of service to determine the cost/price impact of customers who exceed the class average peaking factor. From these analyses, the prices for blocks over and above the second block was determined. In those cases where there are more than three blocks of consumption, the tail block has been set at the city’s marginal cost. The marginal cost was estimated assuming the marginal cost of new water rights and expansions to the city’s water supply reservoirs and treatment plants. The balance of the costs (rate) associated with the delivery of water was priced at the city’s current average embedded cost. Using this approach, the city’s marginal costs were estimated at approximately $6.80/1,000 gallons. While the approach used to estimate the city’s marginal costs was not a formal or detailed study, the results are within the range of costs that might be anticipated if a more formal analysis were conducted. The range of marginal costs that was anticipated was in the $5.00 - $7.00/1,000 gallon range. Given that the estimated marginal costs fell within this anticipated range, it was assumed that the marginal cost value of $6.80/1,000 gallons was reasonable for purposes of this study. This marginal costing analysis is provided in the Technical Appendices. Finally, certain rate designs contain a seasonal component to the rate designs. The seasonal differential is a function of capacity costs and the period over which the capacity related costs are collected. For non-seasonal rate structures, the capacity related costs are collected over the entire year. In contrast, a seasonal rate structure may collect a greater proportion of the extra-capacity related costs over the peak-use period (i.e. summer period). By recognizing that the capacity related costs are more seasonally related, the price charged during that period better reflects the cost of providing services in that period. Therefore, to establish the seasonal price differential, the extra-capacity costs within the city’s cost of service study were assumed to be collected primarily over the summer peak use period. This pricing concept is sometimes referred to as “tailored rates.”  While the above basic costing/pricing concepts were used to establish the prices within the city’s rates, the final prices needed to be established to meet the specific revenue requirements of each class of service. For purposes of this study, it has been assumed that all rate structures should be “revenue neutral” or in other words, collect the same level of overall revenue as the city’s existing rates. Finally, different approaches have been suggested by individual members of WRAB concerning the assumptions of usage and pricing in the various blocks. Some utilities that use water budget rate structures establish the first and second block price to cover their entire revenue requirements, and then assume that any revenues collected in succeeding blocks is considered “excess” revenue and available to fund additional conservation programs. In our opinion, this approach develops rates that are technically incorrect and clearly not “cost-based” since they are purposely and intentionally designed to exceed a utility’s revenue requirements. Therefore, in designing the city’s rates, it has been assumed that consumption will, as indicated by the consumption information, occur in all of the rate blocks of the rate structure. As such, the rate  35 Manuel P Teodoro, “Tailored Rates,” Journal AWWA 94:10 October 2002. Development and Evaluation of the Rate Structures 6-4  City of Boulder—Volume 1 – Evaluation of Water Rate Structures design will produce total revenues that are approximately equal to the targeted total revenue requirement for that particular customer class of service. 6.4 Analysis of Customer Usage Characteristics In order to further analyze the various rate structures still under consideration, various customer specific city data was collected and analyzed. In some cases, this data was readily available, and in other cases, the data was difficult to capture or was not captured in a manner that allowed for ease of use within our analyses. In those instances, additional analysis and data manipulation was required to produce data suitable for this study. In order to develop rate structures with varying sized blocks, the city must have an understanding of the amount of consumption that occurs, by class of service, at varying levels of consumption, e.g. the total consumption used by a customer class at the 1,000 gallon level, the 10,000 gallon level, etc. This analysis is called a bill frequency analysis, and is often generated via a report writer within the utility’s billing system software. In the case of the city, the current billing system software provides consumption information only by the three existing blocks, e.g. usage in block 1. The city’s existing report of consumption by existing blocks was not suitable or useful for analyzing alternative block sizes. Given that, monthly consumption data for each class of service was placed in an Excel file and sorted to provide the necessary data. Data was analyzed for three different time periods. Bill frequency analyses were prepared for calendar years 1997, 1998 and 2002 consumption data. These years were selected not only because they represented a variety of weather conditions but also because historical utility billing data was not available electronically prior to 1996. Calendar year 1998 was considered to be a “typical” year for purposes of consumption patterns. In contrast, 1997 was considered to be a “wet” year for purposes of consumption patterns. Finally, calendar year 2002 was considered to be the dry/drought year for purposes of the analyses. The objective in looking at the three different years is to test the various rate designs and determine how revenue sensitive they may be under wet, dry and normal conditions. The other area of data that was analyzed extensively was the single-family residential customers. Certain proposed rate structures utilize lot size as the basis for establishing the second block size of consumption. The most detailed rate structure utilizes individual customer lot sizes to establish the block. Given that, the city was able to provide a file of information for single- family residential customers that contained information on each account, the tax assessed lot size, and the monthly consumption. While the data that was provided was not 100% of all single-family residential customers, it was a significant share. There were approximately 18,300 of the 20,000 single-family residential accounts that were reviewed as a part of this analysis. In some cases, accounts were removed from the data set because of partial or incomplete monthly consumption data or data that appeared to be incorrect (e.g. SFR lot sizes of 25 square feet). From this data set, each account was analyzed to determine the appropriate block sizes for each account, and the consumption that would have been billed each month, given the various and differing block sizes for each account. From this information, an estimate of the anticipated amount of consumption that might be billed in the various blocks was derived. These billing relationships were then applied to the test period consumption for purposes of designing the final rates. Development and Evaluation of the Rate Structures 6-5  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Other city data and information was analyzed as a part of this study. For example, multi-family and commercial accounts were also analyzed in detail. However, the above described analyses represented the most detailed and complex analyses undertaken. 6.5 Establishment of Fixed Service (Meter) Charges The city currently has two components to their rate structure; a fixed service charge and a consumption charge. Up to this point of the study, the discussion has focused on the structure of the consumption charge. While that is a major focus of this study, it is also important to review and establish fixed service charges. The fixed monthly service charges must be included within the final proposed rate structures for each class of service. In establishing the fixed monthly service charges, there are a number of different perspectives as to what should be included within these charges. At a minimum, they should reflect the costs associated with meter reading, billing, customer accounting and the customer service function. These costs are included within the fixed monthly service charge since they are incurred, regardless of the amount of volumetric use by the customer. At the same time, utilities often include a portion of the other fixed costs associated with the utility. As an example, it is not uncommon to include a portion of a utility’s fixed costs associated with the maintenance of the distribution system, debt service, or a portion of the capital improvements. By doing so, the utility is recognizing that there is a significant portion of the utility’s costs that are truly fixed, but also at the same time, attempting to provide revenue (financial) stability to the utility. Section 3.2 and Table 3-1 of this report discussed the “generally-accepted” method for establishing fixed service charges that vary by meter size. For this study, the city’s most recent cost of service study was reviewed to determine a cost-based level of monthly charges. From the review of that cost of service study, it was determined that the city’s existing fixed service charges appear to be set at an appropriate and reasonable level. Therefore, for purposes of this study, it has been assumed that the city’s monthly service charges should remain at their existing level, and use the same structure or approach. The next time the city conducts a comprehensive cost of service study the fixed service charges should be reviewed again, and updated as appropriate. 6.6 Overview of the Analysis The analyses undertaken to review each of the rate structures is a culmination of the tasks and efforts undertaken in the previous sections of the report. One of the key tasks undertaken as a part of this study was to identify the city’s rate design goals and objectives and to prioritize the rate structure attributes. These rate structure attributes were previously summarized in Table 4- 1. In summary form, these rate structure attributes identified were as follows: Yields Total Revenue Requirements Revenue Stability and Predictability Fair Allocation of Costs to Attain Equity Discourage Wasteful Use Dynamic Ability to Respond To Changing Supply & Demand Conditions Development and Evaluation of the Rate Structures 6-6  City of Boulder—Volume 1 – Evaluation of Water Rate Structures The rate structures evaluated within this section of the report were a part of the 22 rate structures that were evaluated against these attributes. These final rate structures represent the highest scoring rate structures against those attributes. Therefore, in reviewing each of the rate structures analyzed within this section of the report, it is important to understand that each of the rate structures is designed to meet (yield) the total revenue requirements, and provide comparable revenue stability and predictability. Next, each of the rate structures uses cost of service techniques to assure a fair allocation of costs to attain equity and establish cost-based prices. At the same time, all of the rate structures, as inverted block pricing structures, are intended to encourage conservation and discourage wasteful use. Finally, the feature of responding to changing supply and demand conditions is an enhancement that can be added to any of the rate structures developed herein. Given that each of the rate structures are relatively comparable in meeting the city’s goals for rate structure attributes, the focus of the discussion for each of the rate structures will be on the final rate structure, the prices of the blocks, the perceived strengths and weaknesses of each rate structure, the administrative issues associated with the rate structure, and the rate structure’s compatibility with the city’s existing billing system. Another aspect in the evaluation process of each rate structure is the issue of customer appeals. Customer appeals refer to the situation where a customer may disagree with the city’s billing records as they relate to lot size or irrigable area. It has been assumed for purposes of this study, that some rate structures may not be appealed (i.e. the block sizes are fixed and non-appealable). In other cases, it is assumed that the rate structure may contain elements that are appealable (e.g. lot size, irrigable area, bin assignment, number of persons per household, etc.). This study has made no determination of the elements of the rate structure that may be appealable. In theory, if the city so desires, all elements of a rate structure may be appealed by their customers, and it is a policy decision of the city to make that determination. At the same time, if the city allows appeals, they would need to establish a process for appeals. While this study has not attempted to determine the process that would be used for appeals, we have attempted to estimate the potential number of appeals that may arise from the implementation of a rate structure and a range of costs associated with these appeals. For purposes of estimating these costs, it has been assumed that the city would attempt to resolve all appeals in the most cost and time-efficient manner by working directly with the customer to resolve any differences. However, it has also been assumed that some appeals may require a formal hearing process and be more expensive to resolve. For purposes of this study it was assumed that the number of persons per household is an element that would not be appealable. As described in section 5.5, block 1 for single-family residential was established after reviewing several different methods including allocating a reasonable amount of water per person and assuming that the city’s average household size is 2.2 occupants. If the city decided to accept appeals for the indoor block size, then the estimated number of appeals for single-family residential could be approximately 500-750. This assumes that approximately 25% of the 20,000 single-family residential accounts have more than four persons per household and that 10-15% of these would appeal. If the cost for addressing these appeals were $10.00 to $25.00 per account (on average) the total cost to the city would be $5,000 to $18,750. Some appeals may require a formal hearing process and therefore be more expensive to resolve. The first block for each unit of a multi-family account was set based on 80% of the single family first block size. The number of multi-family appeals was estimate to be approximately 115-175. This was calculated on the total number of multi-family accounts of Development and Evaluation of the Rate Structures 6-7  City of Boulder—Volume 1 – Evaluation of Water Rate Structures 4,600 and that 25% have more than 4 people, and 10% – 15% of those would appeal. It was then determined that these appeals would also range in cost from $10-$25 per appeal. Therefore, if the indoor allocation for the multi-family class were also appealable, the impact to the city would range from $1,150 to $4,375. As with the single family appeals, it was assumed that some of the appeals would require a more formal hearing process and therefore would be more costly. During the review of each of the rate structures, it has been noted that the rate structure either is or is not compatible with the city’s current billing system. In making this assumption it was determined that the current billing system was compatible if it could implement the rate structure with some additional software programming. However, if the billing system was not able to be reprogrammed to handle the requirements of a rate structure it was determined that it was not compatible with the current system. Each rate structure was evaluated in this manner. For each rate structure that was determined to be compatible, the different required functions were discussed in more detail with a software programmer. These functions included: having different rate calculations for different customer classes; establishing a block size on a fixed amount or a percentage of the previous block; or setting the block size at average monthly use based on a three-year average. It was determined that if the system was reprogrammed it would be best to do it in a way that would meet one or all of the required functions. This would allow the city greater flexibility to add or change specific functions in the future. The cost for this reprogramming effort would be $100,000 to $150,000. This then assumes that the reprogrammed billing system is capable of handling one or all of the rate structures that are assumed to be compatible with the current billing system. In addition, the rates, as designed in this analysis, are based on an inside-city customer. Any final rate design that is selected would need to be developed for both inside and outside-city customers. Also, within this study, the city has stated a goal that annual swings in planned revenue should be no greater than 5% and 10% throughout the typical range of wet to dry years. Dry years of a severity that fall within the Drought Management Plan may produce revenue fluctuations outside of this range but this could be addressed by implementing drought surcharges, changing block sizes, or other means. Given the above background discussion of the approach used to develop the various rate structures, the focus of the discussion now shifts to the review of each of the individual classes of service and the development of the rates. 6.7 Review of the Single-Family Residential Rate Structures The first class of service reviewed is the single-family rate structures. In the previous section of the report, each of the six (6) single-family rate structures was discussed. Provided below is a detailed review of each of the rate structures, along with a discussion of the perceived strengths and weaknesses of each rate structure, along with any administrative issues/costs associated with the rate design. Single-Family Residential Rate Structure 1 – The first single-family residential rate structure reviewed is a seasonally differentiated rate structure. As will be recalled, the block 2 usage in the summer period is based upon the assumed irrigation requirements for a 9,000 square foot lot, with 5,200 square feet of irrigable area. Provided below is the proposed pricing for the single-family residential rate structure 1. Development and Evaluation of the Rate Structures 6-8  City of Boulder—Volume 1 – Evaluation of Water Rate Structures S-FRRS1–SDR INGLEAMILY ESIDENTIAL ATETRUCTURE EASONALLY IFFERENTIATED ATE SWA2-BWRAA3-BSR. TRUCTURE ITHLOCK INTER ATENDLOCK UMMER ATE Fixed Monthly Service Charges - 3/4” Meter $8.12/Month 1” 13.88/Month 1-1/4” 21.28/Month 1-1/2” 30.30/Month 2” 53.32/Month Consumption Charges - Winter Period – (Oct. – April) Block 1 - First 5,000 gallons $1.75/1,000 gallons Block 2 - All Usage Over 5,000 gallons $2.60/1,000 gallons Summer Period – (May – Sept.) Block 1 - First 5,000 gallons $1.75/1,000 gallons Block 2 - Next 16,000 gallons $3.05/1,000 gallons Block 3 - All Usage Over 21,000 gallons $6.80/1,000 gallons As can be seen from above, this is a st Overview of the Block Sizes seasonal rate structure. The 1 and Single-Family - Option 1 nd 2 blocks are intended to capture indoor and outdoor water use needs. 25,000 The block sizes were established 20,000 around an average or typical single- Tail Block 15,000 family residential customer. As Block 2 10,000 such, for purposes of this study, it is Block 1 5,000 assumed that the block sizes can not 0 be appealed by the customer. This rate design is attempting to provide a structure that generally reflects the typical single-family residential indoor and outdoor water use needs, Single-Family Residential Rate Structure 1 without the administrative com- Average Annual Bill plexity found in some of the other $1,000.00 rate structure options. The graph at $800.00 left illustrates the approach used to $600.00 Present establish the monthly block sizes. Proposed $400.00 For this particular rate structure, $200.00 nd $0.00 there is no “shaping” of the 2 AWC = 3AWC = 5AWC = 8 block to reflect evapotranspiration (ET). PresentProposedDifference% Change AWC = 3$196.44$200.64$4.202.1% st The price associated with the 1 AWC = 5$397.74$376.89($20.85)-5.2% AWC = 8$701.34$795.59$94.2513.4% block of consumption represents Note: Assumes an Average Customer has an AWC of 5 ´base” costs or the costs incurred Development and Evaluation of the Rate Structures 6-9  City of Boulder—Volume 1 – Evaluation of Water Rate Structures under average demand conditions. Single-Family Rate Structure 1 Base costs are assumed to be the Consumption By Block same for both the winter and sum- 70% 61% mer seasons. The second block 60% 51% price reflects the costs associated 50% 39% with the extra-capacity required to Block 1 40% 31% serve customers. Extra-capacity is Block 2 30% 18% the difference between peak demand Block 3 20% and averagedemand (base) condi- 10% tions. The price differential between 0% seasons for the second block is cre- WinterSummer ated by collecting a greater propor- tion of the extra-capacity costs in the summer period than the winter period. This follows the costing principle of “those that create the peak capacity requirements, should pay for the peak capacity.” Therefore, this rate design attempts to collect the extra-capacity requirements from those customers creating the peak in that particular time period. Finally, the pricing of the tail block is set at the city’s estimated marginal cost. The bill comparison for this rate option indicates that on an annual basis, customers with below average consumption may see a slight increase in their annual bill. Customers with above average consumption would see an increase in their annual bill. The impact to customers in the seasonal periods is similar to the annual bills displayed above. Those customers with consumption below the class average will have a fairly comparable decreases in the bills between winter and summer periods. In contrast, the above average use customers will remain at current levels in the winter period, but should increase in the summer period by up to 20%, particularly at the highest (excessive) levels of use. PSS-FRRS1 – There are ERCEIVED TRENGTHS OF INGLEAMILY ESIDENTIAL ATETRUCTURE four perceived major strengths associated with this rate structure. These strengths are as follows: Price Differential for Seasonality Block Sizes Reflect Typical Requirements Ease of Administration Ease of Customer Understanding The use of a seasonal price differential is, in our opinion, a strength since it reflects the different impacts of seasonal usage on the city and sends a price signal to consumers in the peak use period concerning the value of the resource. If this rate design is ultimately selected the city may wish to redefine the seasons to better reflect Boulder’s unique water supply characteristics such as the direct flow period. This would further refine the price signal to consumers regarding the value of water at different times of the year. This rate structure also has developed block sizes that bear a strong relationship to the indoor and outdoor water requirements of the typical single- family residential customer. This is also an easy rate design to implement as there are very few administrative issues associated with it. The major billing issue associated with it is proration of bills between seasons. Finally, this rate design is not overly complex, such that customers should be able to understand the city’s approach and philosophy concerning the allocation and pricing of the water. Development and Evaluation of the Rate Structures 6-10  City of Boulder—Volume 1 – Evaluation of Water Rate Structures PWS-FRRS1 – There are ERCEIVED EAKNESSES OF INGLEAMILY ESIDENTIAL ATE TRUCTURE three perceived weaknesses associated with this rate structure. These weaknesses are as follows: Does Not Reflect Individual Customer Irrigation Requirements nd Irrigation Block (2 Block) Is Not Shaped For Irrigation Requirements nd 2 Block Size Does Not Relate Well to System Water Supply Characteristics This rate structure has used an assumed “typical” lot size to establish the outdoor water requirements and thus the second block of summer consumption. Those customers with lot sizes larger than 9,000 square feet may have irrigation requirements that would place their use in the third block of consumption. Some may believe that this is inequitable to those customers with nd larger lots. At the same time, this rate structure has not attempted to shape the 2 block based nd upon the monthly irrigation requirements. Rather, the 2 block was sized to meet the peak requirements and does not decrease in the shoulder periods of the summer period or follow the city’s water supply characteristics. ACS-FRRS1 – DMINISTRATIVE ONSIDERATIONS OF INGLEAMILY ESIDENTIAL ATE TRUCTURE For purposes of this study, it is assumed that this particular rate structure, and the elements within it, are not appealable by the customer. That is, the block sizes are designed to relate to the stnd typical or average customer, and are fixed and may not be appealed to change the 1 or 2 block size. The vast majority of current water rate structures in the U.S. use fixed blocks and are not appealable by the customer. In terms of administrative costs, this particular rate structure does not have any significant implementation costs or ongoing administrative costs associated with it. Any new billing system would be capable of handling a seasonal rate structure. In addition, given the fixed block sizes, the billing of the customer is greatly simplified. The only major administrative issue associated with this rate design is the issue of proration. Proration refers to the billing of customers as they change from one time period to another (e.g. winter to summer). There are typically two options for dealing with this issue. The first approach is to ignore the proration issue, and simply bill the customer for all consumption based upon the rates that are in effect as of the day of billing. This approach is generally used in those instances where the utility’s billing system is incapable of prorating the bill between seasons. In contrast to this, a prorated bill will take the consumption for the billing period, and split it between the two seasonal periods, based upon the number of days in each period. The prorated consumption for the winter period is billed at the winter rates, and the prorated summer consumption is billed at the summer rates. It is our understanding that a new billing system would have the capability of prorating bills to two billing periods. In summary, it appears that there would be no significant implementation costs associated with this rate structure, and no significant on-going costs associated with this rate structure. RSS-FRRS1– In reviewing this EVENUE TABILITY OF INGLEAMILYESIDENTIAL ATE TRUCTURE rate structure, the potential revenue volatility of a wet year or drought year was examined. For this particular rate design, during a wet year the annual swing in revenue may be approximately - 5.89%, while in a drought year, the annual revenue swing may be 18.21%. It should be noted that the revenue derived in the drought year is calculated without any drought surcharges. It is assumed that any drought period may require the implementation of drought surcharges. Development and Evaluation of the Rate Structures 6-11  City of Boulder—Volume 1 – Evaluation of Water Rate Structures CS-FRRS1C’ OMPATIBILITY OF INGLEAMILY ESIDENTIAL ATETRUCTURE TO THE ITYS ESBS – This particular rate design is currently compatible XISTING OFTWARE ILLING YSTEM with the city’s existing billing software but would require some reprogramming efforts. 7MRKPI*EQMP]6IWMHIRXMEP6EXI7XVYGXYVIz The second rate structure reviewed is a water budget rate structure. Block 2, or the outdoor water requirement, is based upon an assumed 9,000 square foot lot size, and the irrigation requirements for 5,200 square feet of irrigable area are shaped based upon the monthly evapotranspiration (ET). Provided below is a summary of the rate design. S-FRRS2–WBWF(4) INGLEAMILY ESIDENTIAL ATETRUCTURE ATERUDGET ITHOUR CB.B1IFFIU,B2IBUT ONSUMPTION LOCKSLOCK SIXED ORNDOOR SELOCK SASED PONHE IROA9,000SFLS,B3U150%O RRIGATION EQUIREMENTS FQUARE OOT OTIZELOCKSES F B2TDS,AB4IAUOB3. LOCK OETERMINE IZEND LOCK SLLSAGE VERLOCK Fixed Monthly Service Charges - 3/4” Meter $8.12/Month 1” 13.88/Month 1-1/4” 21.28/Month 1-1/2” 30.30/Month 2” 53.32/Month Consumption Charges - Block 1 - First 5,000 gallons $1.75/1,000 gallons [1] Block 2 - Varies by Month - Uses 9,000 sq. ft. $3.05/1,000 gallons Block 3 - 101% to 150% of Outdoor Goal $3.65/1,000 gallons Block 4 - Over 150% of Outdoor Goal $6.80/1,000 gallons [1] Each month will have a set outdoor goal based on an average lot size of 9,000 square feet and an outdoor application rate of 8.66 gallons per square foot of lot size. The monthly irrigation nd requirements are shaped by historical weather and ET. 2 Block size is as follows: January 5,000 gal. May 18,000 gal. September 12,000 gal. February 5,000 gal. June 20,000 gal. October 8,000 gal. March 5,000 gal. July 20,000 gal. November 5,000 gal. April 7,000 gal. August 16,000 gal. December 5,000 gal. Development and Evaluation of the Rate Structures 6-12  City of Boulder—Volume 1 – Evaluation of Water Rate Structures As can be seen, this is a water Overview of the Block Sizes budget rate structure and it has a Single-Family - Option 2 fixed block size for the initial use, nd and the 2 block size varies by 40,000 35,000 month. The third and fourth block Tail Block 30,000 are a function of the outdoor goal 25,000 Block 3 20,000 (i.e. block 2 size). As with the Block 2 15,000 previous rate structure, it has been 10,000 Block 1 5,000 assumed for purposes of this study 0 that the block sizes are fixed and non-appealable. This particular rate structure is again attempting to provide an allocation Single-Family Residential Rate Structure 2 of water for an average or typical Average Annual Bill residential customer. As noted $1,000.00 nd earlier, the 2 block assumes a $800.00 9,000 square foot lot size with 5,200 $600.00 Present square feet of irrigable area. The $400.00 Proposed $200.00 rate structure has added the shaping $0.00 nd of the 2 block to reflect the AWC = 3AWC = 5AWC = 8 differing irrigation requirements throughout the year as they relate to PresentProposedDifference% Change ET. The graph at left shows the size AWC = 3$196.44$200.64$4.202.1% AWC = 5$397.74$387.39($10.35)-2.6%and shaping of the blocks for this AWC = 8$701.34$763.64$62.308.9% particular option. Note: Assumes an Average Customer has an AWC of 5 As with the previous rate structure, Single-Family Rate Structure 2 st the price associated with the 1 block Consumption By Block of consumption represents “base” 50% 42% costs or the costs incurred under 42% 40% average demand conditions. The second block price reflects the costs 30% associated with the extra-capacity 20% required to serve customers under 7% 9% the assumed class peaking 10% characteristics (peaking factor). The 0% rd prices developed for the 3 block Block 1Block 2Block 3Block 4 reflect the costs associated with a customer that places a higher than normal demand upon the system. Finally, the tail block is set at the city’s marginal cost. This rate structure is designed to collect the same overall level of revenue as rate structure 1. The bill comparison developed for this particular rate structure indicates results similar to rate structure 1. That is, those customers with below average consumption may see a slight increase in their annual bill, while those with average consumption may see a slight decrease. Finally, those customers with above average consumption should see an increase in their annual bill. In looking at the impacts during various times of the year, the winter period should see minimal Development and Evaluation of the Rate Structures 6-13  City of Boulder—Volume 1 – Evaluation of Water Rate Structures changes in the bills. It is the “shoulder” periods when customers may be irrigating more than needed that the large impacts may be seen on their bill. These impacts may be as high as 20% increases. Finally, in reviewing the consumption that occurs within each of the blocks under this rate structure, the vast majority of the consumption will be billed in the first and second block of the rate structure. Provided below is a discussion of the perceived strengths, weaknesses and any administrative consideration in the implementation of this rate design. PSS-FRRS2 – There are ERCEIVED TRENGTHS OF INGLEAMILY ESIDENTIAL ATETRUCTURE three perceived major strengths associated with this rate structure. These strengths are as follows: Outdoor Watering Allocation Shaping of the Water Allocation Establishment of a Standard Lot Size nd The strength of the water budget rate structure is in the establishment of the 2 block of consumption based upon the irrigation requirements of the customer. In this case, the outdoor irrigation requirements are based upon a typical lot size of 9,000 square feet, and this water is then shaped to reflect the historical ET. In this particular case, the establishment of a standard lot size is perceived as a strength. This is based upon the administrative perspective that this particular water budget is not as administratively complex to implement as some of the other water budget rate structures being proposed. PWS-FRRS2 – There are ERCEIVED EAKNESSES OF INGLEAMILY ESIDENTIAL ATE TRUCTURE two perceived major weaknesses associated with this rate structure. These weaknesses are as follows: Use of a Standard Lot Size Complexity/Customer Understanding While the use of the standard lot size was perceived as a strength from an administrative perspective, it can also be perceived as a weakness from a water budget perspective. The concept of a water budget is to provide an allocation of water to the customer that reflects their indoor and outdoor water needs. In this case, the use of the typical lot size may under or over- nd allocate 2 block water to customers. However, in the data that was analyzed, approximately 65% of the single-family residential customers had lot sizes of 9,000 square feet or less, and approximately 75% of the single-family residential customers have lots of 11,000 square feet or less. The other perceived weakness of this rate design is simply the complexity. In particular, the changing block sizes from month-to-month has the potential of being confusing to customers particularly if customers are attempting to stay within their “budget.” ACS-FRRS2 – DMINISTRATIVE ONSIDERATIONS OF INGLEAMILY ESIDENTIAL ATE TRUCTURE As previously discussed, it has been assumed that this particular rate structure, for purposes of this study, is non-appealable. Given that, this particular rate structure has one major administrative issue associated with it. The previous rate structure discussed the issue of proration between seasons. In this particular case, given the change in block sizes on a monthly basis, and the timing of the billing of customers, the bills will need to be handled on a monthly basis, in a manner similar to the discussion of seasonal rates. That is, the customer will simply be given the block size for the month they are billed in, or they will be prorated between months. Development and Evaluation of the Rate Structures 6-14  City of Boulder—Volume 1 – Evaluation of Water Rate Structures While proration is simply an algorithm within the billing program, the program must be able to handle proration. Finally, the bill will appear more complex than other approaches, depending upon the level of detail provided concerning the proration. In summary, it appears that there would be no significant implementation costs associated with this rate structure, other than establishing within the billing program the proration formula. At the same time, there does not appear to be any significant on-going costs associated with this particular rate structure. RSS-FRRS2– In reviewing this EVENUE TABILITY OF INGLEAMILYESIDENTIAL ATE TRUCTURE rate structure, the potential revenue volatility of a wet year or drought year was examined. Within this study, the city has stated a goal of annual swings in planned revenue should be no greater than 5% and 10%. For this particular rate design, during a wet year the annual swing in revenue may be approximately 6.30%, while in a drought year, the annual revenue swing may be 18.86%. As noted with the previous rate structure, the calculation of the revenue swing assumes no drought surcharges within the drought period. CS-FRRS2C’ OMPATIBILITY OF INGLEAMILY ESIDENTIAL ATETRUCTURE TO THE ITYS ESBS – This particular rate design is currently not compatible XISTING OFTWARE ILLING YSTEM with the city’s existing billing software. 7MRKPI*EQMP]6IWMHIRXMEP6EXI7XVYGXYVIz The third rate structure reviewed for single-family residential is another form of a water budget. Under this particular rate structure the approach is to segregate lot sizes into three “bins” for nd purposes of establishing the outdoor watering allocation (i.e. 2 block size). The concept of “bins” is to attempt to better match the irrigation requirements of the customer, without the need for measuring individual customer lots. Provided below is an overview of the rate structure and design. Development and Evaluation of the Rate Structures 6-15  City of Boulder—Volume 1 – Evaluation of Water Rate Structures S-FRRS3–WBWF(4) INGLEAMILY ESIDENTIAL ATETRUCTURE ATERUDGET ITHOUR CB.B1IFFIU,B2UT ONSUMPTION LOCKSLOCK SIXED ORNDOOR SELOCK SESHREE D“B”DIR,B3U125%O IFFERENT INS TO ETERMINE RRIGATION EQUIREMENTSLOCKSES F B2TDSAB4IAUOB3. LOCK OETERMINE IZE ND LOCK SLLSAGE VERLOCK Fixed Monthly Service Charges - 3/4” Meter $8.12/Month 1” 13.88/Month 1-1/4” 21.28/Month 1-1/2” 30.30/Month 2” 53.32/Month Consumption Charges - Block 1 - First 5,000 gallons $1.75/1,000 gallons [1] Block 2 - Varies By Month – Uses 3 “Bins” $2.95/1,000 gallons Block 3 - 101% to 125% of Outdoor Goal $3.30/1,000 gallons Block 4 - Over 125% of Outdoor Goal $6.80/1,000 gallons [1] Each month will have a set outdoor goal based on three separate lot size “bins” (0- 9,000 sq. ft., 9,001 – 18,000 sq. ft., and greater than 18,000 sq. ft.) and an outdoor application rate of 8.66 gallons per square foot of “typical” lot size. The irrigable requirements for the 0 –9,000 sq. ft. bin will be allocated based upon 9,000 sq. ft. The 9,001 – 18,000 sq. ft. bin size will be based upon 15,000 sq. ft, and the third bin will be based upon irrigable requirements for 24,000 sq. ft. The monthly irrigation requirements will be shaped by historical weather and ET. Provided below are the Block 2 allocations based upon bin size. Block 2 - Water Allocation (Gallons) Up to 9,001 – . Over 9,000 S.F. 18,000 S.F. 18,000 S.F. January 5,000 5,000 5,000 February 5,000 5,000 5,000 March 5,000 5,000 5,000 April 7,000 7,000 7,000 May 18,000 35,000 57,000 June 20,000 38,000 63,000 July 20,000 38,000 63,000 August 16,000 31,000 50,000 September 12,000 23,000 38,000 October 8,000 8,000 8,000 November 5,000 5,000 5,000 December 5,000 5,000 5,000 Development and Evaluation of the Rate Structures 6-16  City of Boulder—Volume 1 – Evaluation of Water Rate Structures This particular rate structure is a Overview of the Block Sizes variation of the previous rate Single-Family - Option 3 structure. In the previous rate Bin Size - Less than 9,000 sq. ft. structure, no consideration was 35,000 given to the size of a customer’s lot 30,000 Tail Block 25,000 size and their irrigable area. As 20,000 Block 3 discussed above, this rate structure 15,000 Block 2 10,000 attempts to address this issue Block 1 5,000 without presumably incurring the 0 administrative costs associated with determining individual customer lot sizes or irrigable areas. Rather, three “bins” are created based upon the estimated lot size of the customer. The three lot sizes are large enough that any appeals associated with the placement of a customer within a bin should be minimized. nd In each case, the 2 block is sized and shaped for historical ET. The amount of water within the second block was established based upon the range of lot sizes to be irrigated. For the first bin size, it is assumed nd that the 2 block of water is based upon a 9,000 square foot lot size, with 5,200 square feet of irrigable area. For the next bin, the lot sizes range from 9,001 to 18,000 square feet. For purposes of this study, it has been assumed that the allotment of water would be sufficient for a lot size of 15,000 square feet. Therefore, customers with lot sizes smaller than 15,000 square feet would be allocated an amount of water greater than their requirements, and customers with lot sizes greater than 15,000 square feet, but less than 18,000 square feet would be allocated an amount slightly less than their irrigation requirements. Finally, nd for lots over 18,000 square feet, the amount of water provided within the 2 block would be sufficient to irrigate a 24,000 square foot area. In pricing the block sizes, an approach similar to that described for the previous option was used. That is, the first block is priced at the base costs, and succeeding blocks are priced based upon the capacity requirements each different block size places upon the system. Finally, the tail Development and Evaluation of the Rate Structures 6-17  City of Boulder—Volume 1 – Evaluation of Water Rate Structures block has been priced at the marginal cost. While there are three bins, the price for each block is the same, regardless of the bin that the customer is assigned to. In looking at the impacts to customers from this rate structure, Single-Family Residential Rate Structure 3 the impacts are similar to rate Average Annual Bill structures 1 and 2 discussed previously. While the charts at left $800.00 relate to a customer with a 9,000 $600.00 Present square foot lot (i.e. the first bin $400.00 Proposed size), the impacts indicate that a $200.00 customer with below average $0.00 AWC = 3AWC = 5AWC = 8 consumption will potentially see a slight increase in their overall annual bill, while the average PresentProposedDifference% Change customer may see a slight decrease. AWC = 3$196.44$200.24$3.801.9% AWC = 5$397.74$380.29($17.45)-4.4% However, customers that have AWC = 8$701.34$741.89$40.555.8% above average consumption will Note: Assumes an Average Customer has an AWC of 5 potentially see a slight increase in their annual bill. Between seasons, Single-Family Rate Structure 3 Consumption By Block the winter period bills should be 60% similar for below average and 47% average customers. Customers with 50% 39% an AWC greater than 5,000 gallons 40% may see a slight increase since the 30% st 1 block size under the proposed 20% 10% 4% rate structure is 5,000 gallons. 10% Finally, it is the shoulder periods to 0% the summer period where the largest Block 1Block 2Block 3Block 4 increases or impacts to customers may occur. This is due to the nd shaping of the 2 block and that excessive usage is most likely to occur in these shoulder periods (early spring and late fall). The consumption that falls in each block is also interesting to note. For this particular rate structure, the vast majority of the consumption again will fall within the first and second block of the rate structure. PSS-FRRS3 – There are ERCEIVED TRENGTHS OF INGLEAMILY ESIDENTIAL ATETRUCTURE two perceived major strengths associated with this rate structure. These strengths are as follows: Outdoor Watering Allocation Generally Related to Lot Size Shaping of the Water Allocation This particular rate structure for single-family residential has attempted to allocate the water resource for block 2, based upon the irrigation needs of the customer. In this particular case, the use of “bins” has been utilized as a method to help minimize the administrative issues associated with the measurement of individual lots. At the same time, similar to the previous rate structure, Development and Evaluation of the Rate Structures 6-18  City of Boulder—Volume 1 – Evaluation of Water Rate Structures the shaping of the water allocation to reflect the varying irrigation requirements is a perceived strength. PWS-FRRS3 – There are ERCEIVED EAKNESSES OF INGLEAMILY ESIDENTIAL ATE TRUCTURE four perceived major weaknesses associated with this rate structure. These weaknesses are as follows: Use of Bins Requires Determination and Verification of Lot Sizes Potential for a Limited Number of Customer Appeals Possible Customer Perception of Significant Inequities rd Small Block Size for the 3 Block The weaknesses for this rate structure may be significant. While the use of “bins” has provided some simplification of the administrative issues associated with this rate structure, it will still require the city to determine lot sizes for each single-family residential account, and verify the lot to the account, and then place it within the proper bin. As lot sizes are determined, and customers are placed in a bin, there will be some potential for customer appeals, particularly given the magnitude of difference in the volume of water provided from one bin to the next. As an example, a customer with a property size of 8,999 square feet will be provided with 20,000 gallons of water in July for the second block. In contrast to this, a customer with a lot size of 9,001 square feet will be provided with 38,000 gallons of water in July at the second block price. Given this difference, some customers may challenge the city’s placement of their property within a certain bin. Finally, the issue of the perception of equity may surface under this approach. As noted above, a customer with as little as 10 square feet of additional property, may be allocated as much as 18,000 gallons per month of additional water in the peak use period. Some customers may perceive this as inequitable; that is; receiving a larger block of low-cost water simply because the customer owns a slightly larger piece of property. Finally, the use of 125% as the goal for establishing the tail block may be set at too low of a level and push individuals into the higher cost blocks. ACS-FRRS3 – DMINISTRATIVE ONSIDERATIONS OF INGLEAMILY ESIDENTIAL ATE TRUCTURE The administrative issues associated with this rate structure are very similar to the previous rate structure, with the added administrative consideration of the need to determine and verify lot sizes for each single-family residential account, and properly place the account with the appropriate “bin.” As a result of this process, it is anticipated that there would be a customer appeal process whereby a customer could appeal their lot classification, claiming that it is either incorrectly measured, or has been placed in an inappropriate bin. There are approximately 19,000 inside city single-family residential accounts, and 750 outside city single-family customers. The data for the outside city customers may be limited. Assuming a range of cost of $1.00 to $2.50/account to initially determine, verify and place accounts, the total cost may be in the range of approximately $20,000 to $50,000. After the initial classification, there may be customer appeals. Based upon the lot size data reviewed as a part of this study, there may be approximately 175 accounts that are within 100 square feet of the next largest bin size. Assuming that only 25% of those accounts appeal, there would be approximately 45 appeals. While it is difficult at this time to estimate the cost to the city of an appeal, for purposes of this study, it has been estimated at $50 - $250 per appeal. This cost Development and Evaluation of the Rate Structures 6-19  City of Boulder—Volume 1 – Evaluation of Water Rate Structures would cover the administrative time associated with the appeal process, plus any time associated with meeting with the customer and determining the lot size for purposes of establishing the final lot size. Given these assumed per appeal costs, it could cost the city $2,250 to $11,250 to resolve any appeals by single-family residential customers. Should there be more or fewer appeals than the anticipated 45 assumed within this study, then the cost to the city would change accordingly. As with the previous rate structure, the issue of proration between time periods is also an issue with this rate structure. While it is not technically difficult, it does create a more complex billing statement depending upon the level of detail contained within the customer’s monthly billing statement. In summary, the implementation costs to the city from this rate structure may be as high as approximately $50,000. Any customer appeals to the initial classification process would be additional. Once the lot size is determined and finalized for each account, then the on-going costs should be minimal. However, as property is developed or sub-divided, it will require updating of the city’s billing information database. It is anticipated that the on-going costs for this particular rate structure should not be significant. RSS-FRRS3– In reviewing this EVENUE TABILITY OF INGLEAMILYESIDENTIAL ATE TRUCTURE rate structure, the potential revenue volatility of a wet year or drought year was examined. Within this study, the city has stated a goal of annual swings in planned revenue should be no greater than 5% and 10%. For this particular rate design, during a wet year the annual swing in revenue may be approximately 3.00%, while in a drought year, the annual revenue swing may be 14.03%. As with the previous rate structures, the revenue variability shown for this particular rate structure has not included the use of a drought surcharge. CS-FRRS3C’ OMPATIBILITY OF INGLEAMILY ESIDENTIAL ATETRUCTURE TO THE ITYS ESBS – This particular rate design is currently not compatible XISTING OFTWARE ILLING YSTEM with the city’s existing billing software. 7MRKPI*EQMP]6IWMHIRXMEP6EXI7XVYGXYVIz The fourth rate structure reviewed for single-family residential is another form of a water budget. Under this particular rate structure the approach is to use individual lot sizes to establish the outdoor watering block (block 2). By using individual customer lot sizes, the rate structure does not require or use “bins.” The rate structure also has a total of five blocks. Provided below is a summary of the rate structure. Development and Evaluation of the Rate Structures 6-20  City of Boulder—Volume 1 – Evaluation of Water Rate Structures S-FRRS4–WBWF(5) INGLEAMILY ESIDENTIAL ATETRUCTURE ATERUDGET ITHIVE CB.B1IFFIU,B2IBT ONSUMPTION LOCKSLOCK SIXED ORNDOOR SELOCKSASEDAX ALS,B3I125%OB2,B4I150%OB2,A SSESSED OTIZELOCKSFLOCKLOCK SFLOCK ND B5IAUOB4. LOCK SLL SAGE VERLOCK Fixed Monthly Service Charges - 3/4” Meter $8.12/Month 1” 13.88/Month 1-1/4” 21.28/Month 1-1/2” 30.30/Month 2” 53.32/Month Consumption Charges - Block 1 - First 5,000 gallons $1.75/1,000 gallons [1] Block 2 - Varies–Uses Tax Assessed Lot Size $2.80/1,000 gallons Block 3 - 101% to 125% of Outdoor Goal $3.25/1,000 gallons Block 4 - 125% to 150% of Outdoor Goal $3.70/1,000 gallons Block 5 - Over 150% of Outdoor Goal $6.80/1,000 gallons [1] Each month will have a set outdoor goal based on the tax assessed lot size and an irrigation application rate of 8.66 gallons per square foot of total assessed lot size. The monthly irrigation requirements will be shaped by historical weather and ET. This particular rate structure creates individual block allocations for each customer based upon the specific tax assessed lot size of the customer. The customer’s tax assessed lot size nd Overview of the Block Sizes - Assumes 9,000 s.f. is used to determine the 2 block Single-Family - Option 4 of water consumption. Given this approach, it has been assumed that 40,000 this aspect of the rate design is 35,000 30,000 appealable. By moving to the use Tail Block 25,000 of tax assessed lot sizes, this rate 20,000 Block 4 15,000 structure attempts to better match Block 3 10,000 the irrigation requirements of the Block 2 5,000 customer to the actual lot size. The 0 Block 1 nd 2 block size is shaped to the specific irrigation requirements of rdth the customer. At the same time the succeeding blocks (3 block – 5 block) are based upon the nd relationship to the 2 block allocation of water. Development and Evaluation of the Rate Structures 6-21  City of Boulder—Volume 1 – Evaluation of Water Rate Structures The establishment of the prices for this particular rate structure is Single-Family Residential Rate Structure 4 based upon the approach discussed Average Annual Bill for the previous options. That is, $800.00 the initial block is priced at the $600.00 base rate, and the succeeding Present $400.00 blocks are based upon the extra- Proposed $200.00 capacity costs associated with $0.00 serving those customers. Finally, AWC = 3AWC = 5AWC = 8 the tail block is set at the marginal costs. Given the various lot sizes of customers, the amount of water PresentProposedDifference% Change AWC = 3$196.44$199.64$3.201.6% nd allocated to the 2 block is AWC = 5$397.74$371.54($26.20)-6.6% different than under the previous AWC = 8$701.34$727.64$26.303.7% alternatives. Therefore, the price Note: Assumes an Average Customer has an AWC of 5 nd of the 2 block varies slightly from the other rate structures previously reviewed. However, the prices of the blocks are adjusted to generate the appropriate revenue to meet the target revenue level for this class of service. In developing this particular rate Single-Family Rate Structure 4 structure, data was reviewed for Consumption By Block individual accounts and their tax 100% assessed lot sizes. In this process, approximately 18,300 accounts 80% were reviewed and the monthly 60% 41%41% consumption associated with it. 40% 11% 3% 4% The bill impacts as a result of this 20% rate structure are similar to the 0% previous two (2) rate structures Block 1Block 2Block 3Block 4Block 5 reviewed. That is, average users will see a slight decrease in their annual bills while below and above average users should see a slight increase in their bill. The graph of annual bill impacts assumes a customer with a 9,000 square foot lot size. One of the more interesting aspects of this particular rate design is the amount of consumption that occurs in each of the blocks. Given that this rate structure is designed around each individual customer lot size, the vast majority of consumption falls within the first and second block. However, interestingly there is a large proportion of consumption that falls within the fifth block, or the tail block. This appears to result from the setting of the block sizes based upon the specific lot size of the customer, and possibly a result of undersized allowances for blocks 3 and 4. PSS-FRRS4 – There are ERCEIVED TRENGTHS OF INGLEAMILY ESIDENTIAL ATETRUCTURE two perceived major strengths associated with this rate structure. These strengths are as follows: Outdoor Watering Allocation Individually Tailored to Lot Size Shaping of the Water Allocation Development and Evaluation of the Rate Structures 6-22  City of Boulder—Volume 1 – Evaluation of Water Rate Structures While this rate structure may appear to be similar to the previous water budget, it is significantly different in the way that it is applied to customers. In the previous rate structure there could be nd significant differences in the allocation of 2 block water to customers with lot size differences as small as 100 square feet because of the “bins”. A major advantage of this rate structure is that each individual customer is provided an outdoor watering allotment that attempts to take into nd account their specific lot size. By doing so, the allocation of water for the 2 block bears a nd direct relationship to the lot size. At the same time, this rate structure has shaped the 2 block of water to reflect the irrigation requirements in that time period. PWS-FRRS4 – There are ERCEIVED EAKNESSES OF INGLEAMILY ESIDENTIAL ATE TRUCTURE three perceived weaknesses associated with this rate structure. These weaknesses are as follows: Potential for a Large Number of Customer Appeals Overall Complexity of the Rate Structure Possible Customer Perception of Inequities As with the previous rate structure, there is the potential for some appeals. The major difference with this rate structure is that the entire single-family residential class of service ( 19,000 nd customers) may appeal the lot size used by the city for determining the 2 block size. The use of the bins in the previous rate structure was intended to minimize appeals. In this rate structure, any customer who believes their lot size is not correct (i.e. under-measured) may have the basis for appealing. However, while it is difficult to judge at this time, we would anticipate a limited number of appeals unless there is a significant error in the measurement/assessment. The reason we believe there would be a limited number of appeals is the volume of additional water achieved from an appeal is minimal (i.e. there is not a lot to be gained). Under the previous rate structure, using the bin approach, customers on the cusp of a larger bin would gain a significant nd amount of water within their 2 block allocation by being moved up one bin size. In contrast, under this rate structure, a change of 100 – 200 square feet of additional lot size gained through nd an appeal process simply adds 866 – 1,732 gallons annually to the 2 block. Therefore, there is not a large incentive to going through the appeals process unless there clearly is a significant problem or error with the tax assessor’s records. The other weakness of this rate structure is the complexity of the number of blocks and the shaping of the blocks. While the shaping of the water may be perceived as a strength as it relates to irrigation patterns, it does add a level of complexity to the rate that some consumers would find very confusing. Finally, the issue nd concerning the allocation of the 2 block of water on the basis of lot size may be perceived as inequitable by some customers. From their perspective, a customer may not understand why nd another customer should receive a greater allocation of 2 block water simply because another customer’s lot size is larger. ACS-FRRS4 – DMINISTRATIVE ONSIDERATIONS OF INGLEAMILY ESIDENTIAL ATE TRUCTURE The administrative issues associated with this rate structure are very similar to the previous rate structure. In this case, for every account the city must determine and verify lot sizes for each single-family residential account. The cost associated with the initial determination of lot sizes would not be significantly different from the previous rate structure. Therefore, the cost may be in the range of $20,000 to $50,000 to establish the lot sizes. Development and Evaluation of the Rate Structures 6-23  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Similar to the previous rate structure, the city would also need an appeal process for any customer who disputes their lot size measurement. As noted earlier, it is difficult, if not impossible, to anticipate the potential number of appeals. Using a similar approach as the previous rate structure, and assuming that ½ of 1% of all accounts appeal (many people may not question the assessor’s records), that would imply approximately 100 appeals. Using the same per appeal cost of $50 - $250 per appeal, the cost to the city may be in the range of $5,000 to $25,000 to resolve any appeals. Should there be more or less appeals than the anticipated 100 assumed within this study, then the cost to the city would change accordingly. Similar to the previous water budget rate structures, the bills may be prorated between the time periods. In terms of the proration, this rate structure is no more complex or difficult than the previous water budgets from a proration perspective. In summary, the initial implementation costs to the city from this rate structure may be as high as $50,000. Any customer appeals to the initial classification process would be additional costs to the city depending upon the number of appeals and the process used to resolve the appeal. Once the lot size is determined and finalized for each account, then the on-going costs should be minimal. It is anticipated that the on-going costs for this particular rate structure should not be significant. RSS-FRRS4– In reviewing this EVENUE TABILITY OF INGLEAMILYESIDENTIAL ATE TRUCTURE rate structure, the potential revenue volatility of a wet year or drought year was examined. Within this study, the city has stated a goal of annual swings in planned revenue should be no greater than 5% and 10%. For this particular rate design, during a wet year the annual swing in revenue may be approximately 7.02%, while in a drought year, the annual revenue swing may be 19.93%. As with the previous rate structure, the calculation of revenue stability under a drought condition has not assumed the use of a drought surcharge. CS-FRRS4C’ OMPATIBILITY OF INGLEAMILY ESIDENTIAL ATETRUCTURE TO THE ITYS ESBS – This particular rate design is currently not compatible XISTING OFTWARE ILLING YSTEM with the city’s existing billing software. 7MRKPI*EQMP]6IWMHIRXMEP6EXI7XVYGXYVIz The fifth rate structure reviewed for single-family residential is another form of a water budget. In this particular case, the city will assume a default size of 5,200 square feet of irrigable area (i.e. same assumption used in rate structure 2). In this particular case, the customer could provide their specific irrigable area and have a different amount of water provided for their nd outdoor watering requirements (2 block). Provided below is an overview of this particular rate structure. Development and Evaluation of the Rate Structures 6-24  City of Boulder—Volume 1 – Evaluation of Water Rate Structures S-FRRS5–WF(4) INGLEAMILY ESIDENTIAL ATETRUCTURE ATER BUDGET WITH OUR CB.B1FFIU,B2BU ONSUMPTION LOCKSLOCK IS IXED ORNDOOR SELOCK IS ASEDPON ECPIS,D5,200F ITHER A USTOMER ROVIDEDRRIGABLE IZE OR A EFAULT OF SQUARE EET OF IA.SBBURB2. RRIGABLE REAUCCEEDINGLOCKSASED PONELATIONSHIP TO LOCK Fixed Monthly Service Charges - 3/4” Meter $8.12/Month 1” 13.88/Month 1-1/4” 21.28/Month 1-1/2” 30.30/Month 2” 53.32/Month Consumption Charges - Block 1 - First 5,000 gallons $1.75/1,000 gallons [1] Block 2 - Customer Provided or Default Size $2.90/1,000 gallons Block 3 - 101% to 125% of Outdoor Goal $3.25/1,000 gallons Block 4 - Over 125% of Outdoor Goal $6.80/1,000 gallons [1] Each month will have a set outdoor goal based on either the customer provided irrigable area or assumed “default” irrigable area of 5,200 and an application rate of 15 gallons per square foot. The monthly irrigation requirements will be shaped by historical weather and ET. This particular rate structure is a Overview of the Block Sizes variation of the previous water Single-Family - Option 5 budget rate structure. Under the previous rate structure, the city 35,000 30,000 would use the customer’s tax 25,000 Tail Block assessed lot size to determine the 20,000 Block 3 nd allotment of water for the 2 block 15,000Block 2 size. In contrast to this approach, 10,000Block 1 this rate structure assumes a default 5,000 irrigable area of 5,200 square feet 0 (i.e. the equivalent of a lot size of 9,000 square feet). The customer could provide to the city a customer specific irrigable area. Irrigable area is technically the most nd accurate method of determining 2 block irrigation requirements. With this rate structure, the nd 2 block size is shaped by historical ET and succeeding blocks are in relationship to this goal. The determination of the block prices under this option is similar to the other water budget previously discussed. The difficult part of determining the block prices for this particular option nd is establishing the amount of sales that may occur within the 2 block. As noted above, a default size of 5,200 square feet of irrigable area may be used, or the customer could provide their specific irrigable area. Development and Evaluation of the Rate Structures 6-25  City of Boulder—Volume 1 – Evaluation of Water Rate Structures 7 he annual bill impacts for this rate structure are very similar to the Single-Family Residential Rate Structure 5 previous rate structures reviewed. Average Annual Bill For this particular graph, the $800.00 assumed irrigable area is 5,200 $600.00 square feet. Using that assumption, Present $400.00 a customer that has below average Proposed $200.00 consumption will see a slight $0.00 increase in their annual bill. In AWC = 3AWC = 5AWC = 8 contrast, the average consumer should see a decrease in their annual PresentProposedDifference% Change bill. As with the previous rate AWC = 3$196.44$200.04$3.601.8% AWC = 5$397.74$377.24($20.50)-5.2% structure those customers with AWC = 8$701.34$734.89$33.554.8% higher than average use will see an Note: Assumes an Average Customer has an AWC of 5 increase in their annual bill. The Single-Family Rate Structure 5 impacts within the various seasons Consumption By Block are also similar to the previous rate 50% structures. That is, the winter period 42% 42% appears to have minor impacts to 40% customers, while the shoulder 30% periods in the fall and spring produce 20% the largest impacts. Similar to the 12% 4% 10% other rate structures, the vast majority of the consumption occurs 0% in the first two blocks. There is a Block 1Block 2Block 3Block 4 fairly significant amount of th consumption that does occur in the tail (4) block of this rate structure. In part, this may be due rd to the setting of a low 3 block at 125% of the goal. PSS-FRRS5 – There are ERCEIVED TRENGTHS OF INGLEAMILY ESIDENTIAL ATETRUCTURE three perceived major strengths associated with this rate structure. These strengths are as follows: Outdoor Watering Allocation Shaping of the Water Allocation Use of Customer Irrigable Area Given that this rate structure is very similar to the single-family rate structure 2, the strengths associated with it are also very similar. The major difference between this rate structure and rate structure 2 is the opportunity for the customer to provide their actual irrigable area and use that nd figure to determine their allocation of water for the 2 block of consumption. As noted nd previously, irrigable area provides the best relationship for establishing the 2 block of water. PWS-FRRS5 – There are ERCEIVED EAKNESSES OF INGLEAMILY ESIDENTIAL ATE TRUCTURE two perceived major weaknesses associated with this rate structure. These weaknesses are as follows: Development and Evaluation of the Rate Structures 6-26  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Customer Provided Irrigable Area – Highest Potential for Appeals rd Small Block Size for the 3 Block One of the strengths of this structure was that it allowed customers to provide to the city their nd irrigable area and use that for purposes of establishing the 2 block size. At the same time, this aspect of the rate structure creates a major weakness for this structure. At this point, it is unclear and undefined how the city would obtain and determine the customer specific irrigable area. For purposes of this study, it is assumed that customers would submit their specific irrigable area through an appeal process to determine the irrigable area to be used for billing purposes. It should also be noted that the use of irrigable area is difficult to measure and determine. In comparison to the use of tax assessed lot sizes, the tax assessed lot sizes ultimately would use legal property lines for the boundaries. In contrast, irrigable area doesn’t contain such clear boundaries. In addition, irrigable area may change over time as changes in landscaping occur (e.g. sidewalks added, decks enlarged, etc.) The other weakness of this rate structure is the small rd size of block 3. Given the small size of the block, customers may quickly pass through the 3 th block and be billed at the higher cost 4 block. Even in the summer period of peak use, the size rd of the 3 block is only 5,000 gallons. Having this small block size may lead to customer complaints and higher bills. ACS-FRRS5 – DMINISTRATIVE ONSIDERATIONS OF INGLEAMILY ESIDENTIAL ATE TRUCTURE The major administrative issue associated with this rate structure is how to handle the customer provided irrigable area measurements. In every case, the city will need to modify their billing database for that specific account to reflect the customer provided data. While this is a “one- time” adjustment, it is assumed that customers will only provide their irrigable area if it is over and above the default value of 5,200 square feet. The city does not currently have information on individual property irrigable areas for this class of service, however, it may be reasonable to assume that any customer with a lot over 9,000 square feet may provide a customer specific irrigable area. Using those assumptions, there may be the potential for approximately 6,600 customers to provide account/lot specific information on their irrigable area. Assuming that 10% of the potential 6,600 customer would appeal, this would mean that there could be up to 660 appeals. Of this number of appeals, it is anticipated that 90% can be resolved at a cost of $50.00 -$100.00 per account or a total cost of $29,700 - $59,400. For the remaining 66 customers, a more formal appeal process may be required. Assuming a formal appeal cost of $100 - $250 per appeal, this may translate into a cost of $6,600 - $16,500. Therefore, the total cost for appeals could range from $36,300 to $75,900 for this rate structure. As with the previous water budget rate structures, this rate structure may be prorated between the time periods, based upon the billing date. This rate structure is no more complex, from a proration perspective, than the other water budgets. RSS-FRRS5– In reviewing this EVENUE TABILITY OF INGLEAMILYESIDENTIAL ATE TRUCTURE rate structure, the potential revenue volatility of a wet year or drought year was examined. Within this study, the city has stated a goal of annual swings in planned revenue should be no greater than 5% and 10%. For this particular rate design, during a wet year the annual swing in revenue may be approximately 6.51%, while in a drought year, the annual revenue swing may be 19.56%. As with the other rate structures discussed, the calculation of the revenue stability in the drought period did not assume a drought surcharge. Development and Evaluation of the Rate Structures 6-27  City of Boulder—Volume 1 – Evaluation of Water Rate Structures CS-FRRS5C’ OMPATIBILITY OF INGLEAMILY ESIDENTIAL ATETRUCTURE TO THE ITYS ESBS – This particular rate design is currently not compatible XISTING OFTWARE ILLING YSTEM with the city’s existing billing software. 7MRKPI*EQMP]6IWMHIRXMEP6EXI7XVYGXYVIz The final rate structure reviewed for the single-family residential class of service is a modified nd version of the city’s current rate structure. Under this rate structure, the 2 block was modified to better reflect the outdoor water requirements and uses an approach similar to that used for rate ndnd structure 1 to establish the 2 block size. The 2 block is based upon an assumed lot size of 9,000 square feet, but the water is not shaped by months. Provided below is a summary of the rate design. S-FRRS6–ECRS INGLEAMILY ESIDENTIAL ATETRUCTURE XISTING ITY ATE TRUCTURE MTRCCG. ODIFIEDOEFLECT URRENT ITY OALS Fixed Monthly Service Charges - 3/4” Meter $8.12/Month 1” 13.88/Month 1-1/4” 21.28/Month 1-1/2” 30.30/Month 2” 53.32/Month Consumption Charges - Block 1 - AWC, capped at 8,000 gallons $1.75/1,000 gallons Block 2 - Next 16,000 gallons $3.05/1,000 gallons Block 3 - All Excess Usage $6.80/1,000 gallons As discussed above, this particular rate structure is based upon the Overview of the Block Sizes city’s existing rate structure. In Single-Family - Option 6 nd this case, the 2 block is capped 30,000 at 16,000 gallons per month. This 25,000 rate structure does not shape the Tail Block 20,000 block size for ET. The size of the 15,000Block 2 nd 2 block is based upon the 10,000 Block 1 average summer irrigation 5,000 requirements for a 9,000 square 0 foot lot size. The city’s existing nd rate structure sizes the 2 block in Note: Block 1 based uon AWC = 8000 allons p,g relation to the consumption within nd the first block. Therefore, this rate structure has “disconnected” the 2 block from the st customer’s 1 block consumption or AWC. For purposes of this study, it is assumed that this particular rate structure is not appealable. Development and Evaluation of the Rate Structures 6-28  City of Boulder—Volume 1 – Evaluation of Water Rate Structures The pricing for this rate are based upon the pricing principles Single-Family Residential Rate Structure 6 discussed earlier. The first block is Average Annual Bill set at the base costs. The second $800.00 block is designed to collect the $600.00 extra-capacity costs. Finally, the Present $400.00 tail block has been set at the Proposed $200.00 estimated marginal cost of the city. $0.00 The prices are designed to produce AWC 3AWC 5AWC 8 the level of target revenues for this particular class of service. PresentProposedDifference% Change AWC 3$196.44$195.44($1.00)-0.5% AWC 5$397.74$360.29($37.45)-9.4% The bill impacts from this rate AWC 8$701.34$727.09$25.753.7% structure are similar to the other Note: Assumes an Average Customer has an AWC of 5 single-family rate structures that Single-Family Rate Structure 6 have been reviewed. The below Consumption By Block average, and average use 60% customers should see a decrease in 48% 50% their annual bill. In contrast, the 40% 40% above average customer should see 30% a slight increase in their annual 12% bill. The reason why the lower use 20% customers would see a slight 10% nd decrease is the 2 block price is set 0% nd slightly lower than the current 2 Block 1Block 2Block 3 block price. The price for the tail block is slightly higher than the current rate structure. The consumption that occurs within each block under this rate structure is similar to the other rate structures. A majority of the stnd consumption occurs within the 1 and 2 block of the rate structure. PSS-FRRS6 – There are ERCEIVED TRENGTHS OF INGLEAMILY ESIDENTIAL ATETRUCTURE three perceived major strengths associated with this rate structure. These strengths are as follows: Similar to Existing Rate Structure Compatible to the Existing Billing System Software Block 2 Has Some Relationship to Outdoor Water Needs in the Summer The strengths of this rate structure are different than the other rate structures reviewed for this class of service. Given that it is a variation of the existing rate structure, it is presumed that customers should easily recognize and understand the approach being used. At the same time, this rate structure is compatible with the city’s existing software. Finally, the modification made nd to this rate structure was to establish the 2 block size based upon outdoor summer watering requirements for a lot size of 9,000 square feet with 5,200 square feet of irrigable area. The nd city’s existing rate structure does not use this approach to establish the 2 block, but rather, uses nd a relationship of the first block consumption or AWC to establish the 2 block. This change eliminates the ability of a customer to increase their block 2 size by increasing their AWC. Development and Evaluation of the Rate Structures 6-29  City of Boulder—Volume 1 – Evaluation of Water Rate Structures PWS-FRRS6 – There are ERCEIVED EAKNESSES OF INGLEAMILY ESIDENTIAL ATE TRUCTURE two perceived weakness associated with this rate structure. These weaknesses are as follows: Lack of Incentives for Indoor Conservation No individualization of Block 2 nd The modification of the 2 block improved the relationship to outdoor watering in the summer period, but the rate structure does not provide strong incentives for indoor conservation, nd particularly in the winter period. In addition, the 2 block of this rate structure is not individualized and does not take into account the customer’s specific irrigation requirements. ACS-FRRS6 – DMINISTRATIVE ONSIDERATIONS OF INGLEAMILY ESIDENTIAL ATE TRUCTURE For this rate structure, it is assumed that it is non-appealable. In addition, administratively, this rate structure appears to be the simplest to implement and administer. Many of the administrative issues noted above for the other rate structures are not an issue with this rate structure. Therefore, the implementation costs and the on-going costs associated with this rate are minimal, or not much different than the existing rate structure. RSS-FRRS6– In reviewing this EVENUE TABILITY OF INGLEAMILYESIDENTIAL ATE TRUCTURE rate structure, the potential revenue volatility of a wet year or drought year was examined. Within this study, the city has stated a goal of annual swings in planned revenue should be no greater than 5% and 10%. For this particular rate design, during a wet year the annual swing in revenue may be approximately 6.16%, while in a drought year, the annual revenue swing may be 19.47%. As with the other rate structures, the calculation of the revenue stability in the drought period did not use a drought surcharge. CS-FRRS6C’ OMPATIBILITY OF INGLEAMILY ESIDENTIAL ATETRUCTURE TO THE ITYS ESBS – This particular rate design is compatible with the XISTING OFTWAREILLING YSTEM city’s existing billing software but would require some reprogramming efforts. This concludes the review of the single-family residential rate structures. The focus will now shift to the multi-family rate structures. 6.8 Review of the Multi-Family Residential Rate Structures The next class of service reviewed was the multi-family residential rate structures. For this particular class of service, three rate structures were recommended for review and analysis by the WRAB. Provided below is a detailed review of each of the rate structures, a discussion of the perceived strengths and weaknesses of each rate structure, along with any administrative issues/costs associated with the rate design. 1YPXM*EQMP]6IWMHIRXMEP6EXI7XVYGXYVIz The first multi-family residential rate structure reviewed is a seasonally differentiated rate structure. Provided below is an overview of the structure. Development and Evaluation of the Rate Structures 6-30  City of Boulder—Volume 1 – Evaluation of Water Rate Structures M-FRRS1–SDR ULTIAMILY ESIDENTIAL ATETRUCTURE EASONALLY IFFERENTIATED ATE S2-BWR3-BSR. TRUCTURE WITH A LOCKINTER ATE AND A LOCK UMMER ATE Fixed Monthly Service Charges - 3/4” Meter $8.12/Month 1” 13.88/Month 1-1/4” 21.28/Month 1-1/2” 30.30/Month 2” 53.32/Month 3” 119.02/Month 4” 211.00/Month 6” 473.93/Month 8” 841.99/Month Consumption Charges - Winter Period (Oct. – April) - Block 1 First 4,000 gallons per unit $1.75/1,000 gallons Block 2 All Excess Usage $2.35/1,000 gallons Summer Period (May – Sept.) - Block 1 First 4,000 gallons per unit $1.75/1,000 gallons Block 2 101% to 150% of Block 1 $2.65/1,000 gallons Block 3 All Excess Usage $4.70/1,000 gallons As can be seen from above, this is a Overview of the Winter Block Sizes - seasonal rate structure. In Per Unit Multi-Family - Option 1 analyzing the multi-family rate structure, it was discovered that this 6,000 option needed a third block in the 5,000 summer period since some multi- 4,000 Tail Block family accounts have a need for 3,000 Block 1 st outdoor watering. The 1 block is 2,000 based upon an assumed indoor use. 1,000 0 The block size is based upon the number of living units in the particular multi-family complex. Each living unit is provided with Overview of the Summer Block Sizes - 4,000 gallons per month to Per Unit Multi-Family - Option 1 st establish the size of the 1 block size. During the summer irrigation 8,000 season block 2 is based on all 7,000 6,000 consumption up to 150% of block Tail Block 5,000 1, while in the winter block 2 is the 4,000Block 2 3,000 Block 1 tail block and considered to be 2,000 excessive indoor use or outdoor 1,000 0 irrigation requirements. During the summer irrigation month’s, Development and Evaluation of the Rate Structures 6-31  City of Boulder—Volume 1 – Evaluation of Water Rate Structures nd consumption over and above the 2 block is attributed to excessive indoor XVH or outdoor watering. st The price associated with the 1 block of consumption represents “base” costs or the costs incurred under average demand conditions. Base costs are assumed to be the same for both the winter and summer seasons. The second block price reflects the costs associated with the extra- capacity required to serve customers. Extra-capacity is the difference between peak demand and average demand (base) conditions. The third block price was set equal to the calculated flat rate for irrigation (see page 6-50) as the consumption in this block is assumed to be for those multi- family accounts which do not have a separate irrigation meter. As with the single-family seasonal rate structure, the price differential between seasons for the second block is created by collecting a greater proportion of the extra-capacity costs in the summer period than the winter period. The bill comparison for this rate option indicates that on an annual Multi-Family Residential Rate Structure 1 basis, customers may see an Average Annual Bill increase in their annual bill if, on $10,000.00 average, indoor use is greater than $8,000.00 4,000 gallons per unit. The graph $6,000.00 Present at left shows the annual bill $4,000.00 Proposed impacts for three different multi- $2,000.00 family customers with living units $0.00 of 2, 10 and 50 units. 2 Units (AWC = 8)10 Units (AWC = 57)50 Units (AWC =235) The impact to customers in the PresentProposedDifference% Change 2 Units (AWC = 8)$358.14$366.39$8.252.3% seasonal periods is dependent 10 Units (AWC = 57)$1,442.19$1,720.79$278.6019.3% upon whether the customer has 50 Units (AWC =235)$7,694.04$8,583.69$889.6511.6% metered irrigation. If the customer has metered irrigation, Multi-Family Rate Structure 1 the rate structure should have little Consumption By Block 100% impact. For those customers that 82% irrigate their common areas under 80% 56% this rate schedule, if there is 60% Block 1 excessive use, the potential 30% Block 2 40% 18% 14%impacts may be very limited. This Block 3 20% is the result of a three-block rate 0% structure. WinterSummer PSM-FRRS1 – There are four ERCEIVED TRENGTHS OF ULTIAMILY ESIDENTIAL ATETRUCTURE perceived major strengths associated with this rate structure. These strengths are as follows: Establishes Reasonable Block Sizes Price Differential for Seasonality Compatible to the Existing Billing System Software Ease of Customer Understanding Development and Evaluation of the Rate Structures 6-32  City of Boulder—Volume 1 – Evaluation of Water Rate Structures The strengths of this rate structure are based upon its simple design. The first block size is based upon a reasonable relationship to the single-family residential block size. This provides a level of continuity to the city’s philosophy in establishing the first block size. At the same time, the rate structure has used seasonal pricing to reflect the cost differences associated with winter and summer water use. The rate structure would also be compatible with the city’s existing software. However, this may not be a significant advantage if the city determines that it wants to move to other rate structures for the other customer classes of service that would require upgrades to the city’s billing software. Finally, this rate structure is very simple to understand from a customer perspective. PWM-FRRS1 – There are ERCEIVED EAKNESSES OF ULTIAMILY ESIDENTIAL ATE TRUCTURE two perceived weaknesses associated with this rate structure. These weaknesses are as follows: nd 2 Block Size Does Not Relate Well to System Water Supply Characteristics No Penalty Rate For Excessive irrigation Consumption The first perceived weakness of this rate structure is the lack of shaping the third block to follow ET and the city’s water supply characteristics for irrigation purposes. The second weakness is that there is no penalty rate for those customers who use excessive water for irrigation purposes. Under other rate structures this excessive use is priced at the marginal cost, while under this structure it is set at a lower price. ACM-FRRS1 – DMINISTRATIVE ONSIDERATIONS OF ULTIAMILYESIDENTIAL ATETRUCTURE This rate structure will require the city to determine and verify the number of living units for each multi-family customer. While the city has this information within an existing database, it must be verified to assure that the proper number of living units is assigned to each account. Given that there are approximately 4,600 multi-family accounts, the cost per account to reconcile the database may be in the range of $1.00 - $3.00 per account, or a total cost of $4,600 to $13,800. Once the database and number of living units has been verified, there would be little or no on-going cost associated with this class of service. As new multi-family units are built and become new customers, the city would need to add this information to the billing records. This process would not have a significant on-going cost associated with it. Finally, as with the other rate structures, this particular rate structure will require proration between seasonal periods. RSM-FRRS1– In reviewing this EVENUE TABILITY OF ULTIAMILY ESIDENTIAL ATETRUCTURE rate structure, the potential revenue volatility of a wet year or drought year was examined. Within this study, the city has stated a goal of annual swings in planned revenue should be no greater than 5% and 10%. For this particular rate design, during a wet year the annual swing in revenue may be approximately 9.61%, while in a drought year, the annual revenue swing may be 56.59%. The revenue variability for the drought period is calculated without drought surcharges. CM-FRRS1C’ OMPATIBILITY OF ULTIAMILY ESIDENTIAL ATETRUCTURE TO THE ITYS ESBS – This particular rate design is currently compatible XISTING OFTWARE ILLING YSTEM with the city’s existing billing software but would require some reprogramming efforts. Development and Evaluation of the Rate Structures 6-33  City of Boulder—Volume 1 – Evaluation of Water Rate Structures 1YPXM*EQMP]6IWMHIRXMEP6EXI7XVYGXYVIz The second multi-family residential rate structure reviewed is a water budget rate structure with six blocks. Provided below is an overview of the structure. M-FRRS2–WBWS(6) ULTIAMILY ESIDENTIAL ATETRUCTURE ATERUDGET ITH IX CB.B12AFPUT,B3I ONSUMPTION LOCKSLOCKS AND RE IXED ERNIT HRESHOLDSLOCK S BOTCSIA,SBB ASEDNHEUSTOMER PECIFIC RRIGABLE REA AND UCCEEDING LOCKS ASED URTOG. PONELATIONSHIP OUTDOOR OAL Fixed Monthly Service Charges - 3/4” Meter $8.12/Month 1” 13.88/Month 1-1/4” 21.28/Month 1-1/2” 30.30/Month 2” 53.32/Month 3” 119.02/Month 4” 211.00/Month 6” 473.93/Month 8” 841.99/Month Consumption Charges - Block 1 - First 4,000 gallons per Living Unit $1.75/1,000 gallons Block 2 - Next 2,000 gallons per Living Unit $2.60/1,000 gallons [1] Block 3 - Varies By Month – Irrigable Area $3.35/1,000 gallons Block 4 - 101% to 125% of Outdoor Goal $3.90/1,000 gallons Block 5 - 125% to 150% of Outdoor Goal $4.15/1,000 gallons Block 6 - Over 150% of Outdoor Goal $6.80/1,000 gallons [1] Each month will have a set outdoor goal based on the irrigable area as determined by the city and an irrigation application rate of 15 gallons per square foot. The monthly irrigation requirements will be shaped by historical weather and ET. When reviewing the consumption Overview of the Block Sizes - Per Unit data for the multi-family proposed Multi-Family - Option 2 rate structure 2, it was noted that a significant level of consumption 70,000 Tail Block would fall into the tail block under 60,000 Block 5 50,000 the proposed blocks as presented in Block 4 40,000 Section 5. As a result, the rate 30,000 Block 3 structure was modified to add a new 20,000 Block 2 second block for excessive indoor 10,000 Block 1 0 consumption and the third block represents the outdoor irrigation requirements. The level of Note: Based upon 5 units and 5,000 sq. ft. irrigable area consumption in the first two blocks, under the newly proposed structure, now is more closely related to the historical level of consumption that the city has assumed to be indoor usage. Development and Evaluation of the Rate Structures 6-34  City of Boulder—Volume 1 – Evaluation of Water Rate Structures The pricing of the blocks is very similar to that used for the other rate structures developed. rd Most importantly, the price of the 3 block, or the irrigation block, is set at a level that is comparable to the metered irrigation price in the irrigation rate structures 2 and 3. Therefore, a customer will not benefit from keeping their irrigation use on this account and may want to consider a separate metered irrigation account for their property. In reviewing the impacts to customers, the impacts will vary based upon two factors. The first factor is the number of living units. The second and more important factor is the amount of irrigable area and whether the customer has separately metered irrigation. If the customer has separate metered irrigation the customer should remain in the lower blocks of the rate structure and not see large impacts. It appears that the annual bills for the multi-family customers under Multi-Family Residential Rate Structure 2 this rate structure should be fairly Average Annual Bill comparable to the existing rate $10,000.00 structure. The bill comparisons $8,000.00 developed in the graph to the left Present $6,000.00 Proposed assume 7,000 square feet of $4,000.00 irrigable area. As noted above, the $2,000.00 impacts may vary based upon the $0.00 amount of irrigable area. Finally, 2 Units (AWC = 8)10 Units AWC = 57)50 Units (AWC = 235) it appears that the vast majority of PresentProposedDifference% Change the consumption will occur within 2 Units (AWC = 8)$358.14$351.74($6.40)-1.8% the first two blocks of 10 Units AWC = 57)$1,442.19$1,640.54$198.3513.8% consumption (83%). It should be 50 Units (AWC = 235)$7,694.04$8,543.64$849.6011.0% noted that some outdoor irrigation consumption may be captured in the second block, depending upon Multi-Family Rate Structure 2 Consumption By Block the average indoor use of the 80% customer. However, at this time it 69% is unclear as to the amount of 60% consumption related to irrigation. 40% PS 14%10% ERCEIVED TRENGTHS OF 20% M-FR 6% ULTIAMILY ESIDENTIAL 1% 1% RS2 – There are ATETRUCTURE 0% two perceived major strengths Block 1Block 2Block 3Block 4Block 5Block 6 associated with this rate structure. These strengths are as follows: Outdoor Watering Allocation Shaping of the Water Allocation As with the single-family residential rate structure, the strength of the water budget rate structure is in the establishment of a block of consumption based upon the irrigation requirements of the Development and Evaluation of the Rate Structures 6-35  City of Boulder—Volume 1 – Evaluation of Water Rate Structures customer. In this case, the customer’s irrigable area is the basis for establishing the block size. This allocation of water is then shaped to reflect the historical ET. PWM-FRRS2 – There are ERCEIVED EAKNESSES OF ULTIAMILY ESIDENTIAL ATE TRUCTURE three perceived major weaknesses associated with this rate structure. These weaknesses are as follows: Measurements Needed to Use Customer Specific Irrigable Area Master Metered vs. Individually Metered Customers Complexity Based Upon the Number of Blocks In some of the other water budgets reviewed for the single-family residential class of service, standard lot sizes were used as a means to establish the outdoor watering requirements. While that approach is desirable from an administrative standpoint, it does not work well for multi- family customers, given the varying configurations of each property. Therefore, this rate rd structure has used the customer-specific irrigation area to establish the 3 block. This will require the city to determine (i.e. measure) each property to determine the irrigable area. This will obviously require time and effort on the city’s part, but also will be open to challenge by the property owners. The other issue that makes this rate structure challenging is that some properties have a master meter, while others may have individually metered customers or units. Administratively, the master metered situation works very well for this rate structure. In rd contrast, for individually metered customers, determining the 3 block size may be more challenging. In that situation, the individually metered customer does not control outdoor watering, yet has a block established for outdoor watering. In addition, it is unclear how the block would be established for an individually metered multi-family customer (e.g. total irrigable area ÷ total units). If a multi-family customer (account) has separate metered irrigation, it is rd unclear whether the 3 block even makes sense. The final perceived weakness of this rate structure is the number of blocks. This is the only proposed rate structure that has six blocks for pricing purposes. From the consumption data sorted by block sizes, it is clear that six blocks are not required for this particular class of service. ACM-FRRS2 – DMINISTRATIVE ONSIDERATIONS OF ULTIAMILYESIDENTIAL ATETRUCTURE This particular rate structure has two major administrative issues associated with it. First is the issue of the determination of the customer specific irrigation area. There are two approaches that can be used to make this determination. Billing for stormwater (inside city only) is based upon lot size and impervious area. From this information, a rough approximation of irrigable area could be determined. It should be noted that the city’s GIS is not linked to the account information for non-residential customers, because there may not be a one to one relationship between parcel and service location. The other alternative is for the city to physically measure the irrigable area of each property. There are approximately 4,500 inside city multi-family accounts. Assuming a cost range of $2 to $5 per account, the cost associated with determining irrigable for each individual account/property may be in the range of $9,000 to $22,500. In addition to the inside city customers there are also approximately 100 outside city accounts. To physically measure or determine the irrigable areas for these properties, it may cost $25.00 - $50.00 per account. This would translate into $2,500 to $5,000. Once the irrigable area is determined, the city would need to add information for new customers. For existing customers, it would be difficult to determine changes in irrigable area, and most likely, it would be up to the Development and Evaluation of the Rate Structures 6-36  City of Boulder—Volume 1 – Evaluation of Water Rate Structures customer to report any significant changes in irrigable area. Similar to rate structure 1, in order to implement rate structure 2, the city would need to verify the number of living units for each account. Based on the total number of accounts this cost has been estimated to be between $1.00 - $3.00 per account, or a total cost of $4,600 to $13,800. In addition to the implementation costs, there is the potential for appeals. The appeals would primarily be centered around the irrigable area. Given that a small portion of these customers have metered irrigation, it is difficult to determine the number of anticipated appeals the city would receive. It was determined that there was the possibility of 2,500 customers that may appeal. This was calculated by subtracting the 2,100 single units, which typically have minimal irrigable requirements, from the total of 4,600 multi-family customers. Assuming that 5% of those customers may potentially appeal, there could be 125 accounts that appeal. Ninety percent of those may be resolved at a cost to the city in the range of $50.00 - $100.00 per account. This would translate to a range of costs $5,600 - $11,200. Should a more formal appeal process be required for the remaining 13 customers, the cost to resolve may be in the range of $100 - $250 per appeal. This would have a cost in the range of $1,300 to $3,250. The other significant administrative issue associated with this rate structure is the issue of proration. As with the other water budget rate structures, the city may need to prorate the customer bill each month to reflect the timing of the billing and the quantity of water provided in each of the blocks over the billing period. In summary, it appears there are some significant implementation costs associated with this rate structure, but there would be minimal annual on-going costs. At the same time, the administrative issue of proration would need to be addressed within the billing system. RSM-FRRS2– In reviewing this EVENUE TABILITY OF ULTIAMILY ESIDENTIAL ATETRUCTURE rate structure, the potential revenue volatility of a wet year or drought year was examined. Within this study, the city has stated a goal of annual swings in planned revenue should be no greater than 5% and 10%. For this particular rate design, during a wet year the annual swing in revenue may be approximately -3.35%, while in a drought year, the annual revenue swing may be37.16%. The revenue variability for the drought period is calculated without drought surcharges. CM-FRRS2C’ OMPATIBILITY OF ULTIAMILY ESIDENTIAL ATETRUCTURE TO THE ITYS ESBS – This particular rate design is currently not compatible XISTING OFTWARE ILLING YSTEM with the city’s existing billing software. 1YPXM*EQMP]6IWMHIRXMEP6EXI7XVYGXYVIz The third and final multi-family residential rate structure reviewed is a variation of the previous rate structure. This particular rate structure uses a 5-block rate structure, and the tail block is set at a lower level than the previous multi-family rate structure. Provided below is an overview of the rate structure. Development and Evaluation of the Rate Structures 6-37  City of Boulder—Volume 1 – Evaluation of Water Rate Structures M-FRRS3–WBWF(5) ULTIAMILY ESIDENTIAL ATETRUCTURE ATERUDGET ITH IVE CB.B12AFPUT,B3I ONSUMPTION LOCKSLOCKS AND RE IXED ERNIT HRESHOLDSLOCK S BOTCSIA,SBB ASEDNHEUSTOMER PECIFIC RRIGABLE REA AND UCCEEDING LOCKS ASED URTOG. PONELATIONSHIP OUTDOOR OAL Fixed Monthly Service Charges - 3/4” Meter $8.12/Month 1” 13.88/Month 1-1/4” 21.28/Month 1-1/2” 30.30/Month 2” 53.32/Month 3” 119.02/Month 4” 211.00/Month 6” 473.93/Month 8” 841.99/Month Consumption Charges - Block 1 - First 4,000 gallons per unit $1.75/1,000 gallons Block 2 - Next 2,000 gallons per unit $2.60/1,000 gallons [1] Block 3 - Varies By Month – Irrigable Area $3.35/1,000 gallons Block 4 - 101% to 125% of Outdoor Goal $3.90/1,000 gallons Block 5 - Over 125% of Outdoor Goal $6.80/1,000 gallons [1] Each month will have a set outdoor goal based on the irrigable area as determined by the city and an irrigation application rate of 15 gallons per square foot. The monthly irrigation requirements will be shaped by historical weather and ET. This particular rate structure is very similar to the previous rate structure. As with the previous rate structure, nd a new 2 block has been added, and the outdoor irrigation block has rd been moved to the 3 block within th the rate structure. The 4 block size of this rate structure is set at 125% of the outdoor goal (block 3). The pricing used for this rate structure is very similar to the previous rate structure. The main difference being that this rate structure has five blocks, as opposed to the previous rate structure’s six blocks. Development and Evaluation of the Rate Structures 6-38  City of Boulder—Volume 1 – Evaluation of Water Rate Structures In viewing the customer bill impacts from this rate design, the impacts Multi-Family Residential Rate Structure 3 are very similar to the previous rate Average Annual Bill design. As noted previously, the $10,000.00 impacts are a function of the $8,000.00 number of living units, irrigable Present $6,000.00 Proposed area for the customer, and whether $4,000.00 the customer has metered irrigation. $2,000.00 The bill comparison shown in the $0.00 graph to the left utilizes an irrigable 2 Unit (AWC = 8)10 Unit (AWC = 57)50 Units (AWC = 235) area of 7,000 square feet for various PresentProposedDifference% Change living unit configurations. 2 Unit (AWC = 8)$358.14$351.74($6.40)-1.8% 10 Unit (AWC = 57)$1,442.19$1,651.14$208.9514.5% 50 Units (AWC = 235)$7,694.04$8,641.69$947.6512.3% The consumption by block size is very similar to the previous multi- family rate structure. The vast ma- Multi-Family Rate Structure 3 jority of the consumption appears Consumption By Block within the first two blocks (83%), 80% 69% with minimal consumption occur- ring in blocks 3 and 4. Finally, the 60% tail block does have a comparable 40% amount of consumption in it as it 14% 10% does in the previous rate structure. 20% 6% 1% 0% Block 1Block 2Block 3Block 4Block 5 PSM-FRRS3 – There are two ERCEIVED TRENGTHS OF ULTIAMILY ESIDENTIAL ATETRUCTURE perceived major strengths associated with this rate structure. These strengths are as follows: Outdoor Watering Allocation Shaping of the Water Allocation As with the previous multi-family residential rate structure, the strength of this rate structure is the establishment of a block of consumption based upon the irrigation requirements of the customer, and the shaping of that water to reflect historical ET. PWM-FRRS3 – There are ERCEIVED EAKNESSES OF ULTIAMILY ESIDENTIAL ATE TRUCTURE three perceived major weaknesses associated with this rate structure. These weaknesses are as follows: Measurements Needed for Customer Specific Irrigable Area Master Metered vs. Individually Metered Customers Small Block Size for the 4th Block The perceived weaknesses for this rate structure are very similar to the comments provided for multi-family rate structure 2. One additional item, and the major difference in this rate structure, is the setting of the tail block at over 125% of the outdoor water goal. As noted in the discussion Development and Evaluation of the Rate Structures 6-39  City of Boulder—Volume 1 – Evaluation of Water Rate Structures of the single-family residential rate structures using this level of goal, there is some concern that it is set too low, and pushes customers into the higher cost block for relatively small changes in overall consumption patterns, particularly in the winter and shoulder months. ACM-FRRS3 – DMINISTRATIVE ONSIDERATIONS OF ULTIAMILYESIDENTIAL ATETRUCTURE The administrative considerations for this rate structure are the same as those detailed in multi- family rate structure 2. That is, the city will need to determine the customer specific irrigation area, and the number of living units for each multi-family account. In total it has been estimated that these issues may have a cost to the city in the range of $23,000 to $55,750. As with the previous rate structure, it was noted that there is not a link between the city’s GIS information, the number of living units per multi-residential account or the pervious area. In addition, this rate structure must also deal with the issue of proration, which is no different than any of the other water budget rate structures reviewed up to this point. In summary, it appears that there would be some significant implementation costs associated with this rate structure, but there would be minimal annual on-going costs. At the same time, the administrative issue of proration would need to be addressed within the billing system. RSM-FRRS3– In reviewing this EVENUE TABILITY OF ULTIAMILY ESIDENTIAL ATETRUCTURE rate structure, the potential revenue volatility of a wet year or drought year was examined. Within this study, the city has stated a goal of annual swings in planned revenue should be no greater than 5% and 10%. For this particular rate design, during a wet year the annual swing in revenue may be approximately -3.38%, while in a drought year, the annual revenue swing may be -37.46%. The revenue variability for the drought period is calculated without drought surcharges. CM-FRRS3C’ OMPATIBILITY OF ULTIAMILY ESIDENTIAL ATETRUCTURE TO THE ITYS ESBS – This particular rate design is currently not compatible XISTING OFTWARE ILLING YSTEM with the city’s existing billing software. This concludes the review of the multi-family residential rate structures. The focus will now shift to the commercial/large user rate structures. 6.9 Review of the Commercial/Large User Rate Structures The next class of service reviewed was the commercial/large user rate structures. For this particular class of service, three rate structures were recommended for review and analysis by the WRAB. Provided below is a detailed review of each of the rate structures, a discussion of the perceived strengths and weaknesses of each rate structure, along with any administrative issues/costs associated with the rate design. In reviewing the customer classes of service it was noted that the city may segregate their customers, for rate setting purposes, between commercial and large user customers. The objective being that cost differences may exist in serving a commercial customer versus a large user. These cost differences may be a result of differences in usage patterns (i.e. primarily peak use characteristics) and facility requirements. In reviewing the city’s most recent cost of service study, the cost allocation did not provide sufficient detail to determine the cost differences Development and Evaluation of the Rate Structures 6-40  City of Boulder—Volume 1 – Evaluation of Water Rate Structures associated with serving these two types of customers. Given that, it is recommended that at the time of the city’s next cost of service study, this costing issue be reviewed to determine whether two separate classes of service, commercial and large user, is prudent and justified. Therefore, for purposes of this study, the commercial and large user customers are combined for purposes of establishing and reviewing the rate structures. 'SQQIVGMEP0EVKI9WIV6EXI7XVYGXYVIz The first rate structure reviewed is a seasonally differentiated structure. Provided below is the detail of this rate design. C/LURS1–SDR OMMERCIALARGE SERATE TRUCTURE EASONALLY IFFERENTIATED ATE SWA2-BWRAA2-BSR. TRUCTURE ITHLOCK INTER ATENDLOCK UMMER ATE Fixed Monthly Service Charges - 3/4” Meter $8.12/Month 1” 13.88/Month 1-1/4” 21.28/Month 1-1/2” 30.30/Month 2” 53.32/Month 3” 119.02/Month 4” 211.00/Month 6” 473.93/Month 8” 841.99/Month Consumption Charges - Winter Period (Oct. – April) - [1] Block 1 - Average Monthly Use $1.75/1,000 gallons Block 2 - All Usage Over Block 1 $3.00/1,000 gallons Summer Period (May – Sept.) - [1] Block 1 - Average Monthly Use $1.75/1,000 gallons Block 2 - All Usage Over Block 1 $3.30/1,000 gallons [1] Average monthly use is to be determined for each individual customer based upon a three-year average, reviewed and established periodically. The same block 1 size is used for both winter and summer time periods. Development and Evaluation of the Rate Structures 6-41  City of Boulder—Volume 1 – Evaluation of Water Rate Structures The commercial/large user rate Overview of the Block Sizes design is a seasonal rate structure, Commercial/Large User - Option 1 designed to reflect the higher cost associated with meeting peak use requirements for this particular class of service. In comparison to Ave. Mth the single-family residential class of Tail Block Block 1 service, the usage patterns of this class of service do not vary significantly from season to season. For purposes of this study, it has Note: 1st Block based upon customer specific average monthly use been assumed that no portions of this rate structure are appealable by the customer. The calculation of their average monthly use is calculated for all commercial/large user customers at the same time, using the same criteria (i.e. time periods). In determining the price for each of the blocks, an approach similar to Commercial/Large User Rate Structure 1 that used for the other classes of Average Annual Bill service was utilized. The first $12,000.00 $10,000.00 block reflected the “base” costs $8,000.00 Present associated with serving this $6,000.00 Proposed particular class of service. The $4,000.00 $2,000.00 second block was based upon the $0.00 extra-capacity costs required to Brew PubHotelRestaurant serve these customers. The seasonal differential was a function PresentProposedDifference% Change Brew Pub$3,668.85$3,740.95$72.102.0% of a greater share of the extra- Hotel$9,737.04$9,843.39$106.351.1% capacity costs (peaks) occurring in Restaurant$3,207.39$2,975.69($231.70)-7.2% the summer period. For this particular rate structure, there is not a penalty tail block set at the marginal cost. It is our understanding that over 50% of the commercial/large users have metered irrigation, which partly accounts for the relatively flat patterns of use seen by this class of service. However, if desired, the city can add a third consumption block which could then be set at the marginal cost for those customers with excess outdoor usage. It is assumed that the second block would then be set at a level to provide reasonable outdoor watering for those customers without a separate irrigation account. City staff has also indicated during the course of this study that working directly with customers on commercial conservation audits and measures is an effective and preferable way to achieve water efficient practices with these customers. Development and Evaluation of the Rate Structures 6-42  City of Boulder—Volume 1 – Evaluation of Water Rate Structures In viewing the bill comparisons, it can be seen that the annual bill Commercial/Large User Rate Structure 1 impacts to customers will be Consumption By Block 100% fairly comparable to the city’s 88% 77% existing rates. The seasonal 75% component of this rate structure Block 1 50% may impact customers differently, Block 2 particularly if their business is 23% 12% 25% more seasonally related. Those with businesses that tend to be 0% WinterSummer busiest in the winter period may see slight decreases in their bills, and those businesses that are busiest in the summer period may see a slight increase in their annual bills. For the development of the bill comparisons three commercial customers were selected and their annual bills calculated under present and proposed rates. Specific impacts by type of business may vary based upon consumption characteristics. The final item of interest is the anticipated amount of consumption that will be billed within each block of consumption. As can be seen in the graph, the summer period will bill a greater amount of consumption in the second block than the winter period. While there is some difference between the winter and summer consumption patterns, there does not appear to be huge swings in consumption between those time periods. PSC/LURS1 – There are three ERCEIVED TRENGTHS OF OMMERCIALARGE SER ATETRUCTURE perceived major strengths associated with this rate structure. These strengths are as follows: Price Differential for Seasonality Compatible to the Existing Billing System Software Ease of Customer Understanding The strengths of this rate structure are similar to the other seasonal rate structures that have been reviewed in this study. The seasonal price structure should provide some incentive for efficient use by the customer during the peak use period. At the same time, this rate structure should be compatible with the city’s existing billing software with some reprogramming effort. Finally, this rate structure is simple to understand from a customer perspective, yet it is sophisticated in its design that it imparts the proper price signals to customers. PWC/LURS1 – There are ERCEIVED EAKNESSES OF OMMERCIALARGESERATETRUCTURE three perceived major weaknesses associated with this rate structure. These weaknesses are as follows: Potential Lack of Incentives for Efficient Use Lack of an “Excessive Use” Block for Indoor Use nd 2 Block Size Does Not Relate Well to System Water Supply Characteristics For this rate structure, the first block of consumption is developed based upon the customer’s historical consumption. It could be perceived that this approach does not encourage efficient use from these customers because of its use of historical consumption to establish the first block, or alternatively, by its failure to establish an “efficient use” block size for the particular type of Development and Evaluation of the Rate Structures 6-43  City of Boulder—Volume 1 – Evaluation of Water Rate Structures commercial customer (e.g. grocery store, restaurant, etc.). The second perceived weakness of this rate structure is its lack of a third block to penalize customers for “excessive use” whether it is related to indoor or outdoor use. Finally, this rate structure has not shaped the block sizes. Shaping is primarily an outdoor irrigation issue. However, as has been noted previously, approximately one-half of the customers within this class of service have metered irrigation. ACC/LURS1 – DMINISTRATIVE ONSIDERATIONS OF OMMERCIALARGESER ATE TRUCTURE Given the design of this rate structure, it is assumed that the block sizes are non-appealable. Therefore, administratively, this rate structure does not have any significant administrative issues associated with it. The only administrative issue that would need to be addressed is the method that would be used to develop the average monthly use figures for billing. The city would need to determine the procedures or methodology to determine these monthly averages, and the billing system should have the capability to automatically calculate and update this information. It is presumed that these averages would be calculated and updated on a periodic basis. It is not anticipated that there would be a significant upfront cost associated with determining these averages, nor would there be any significant on-going administrative costs. In addition, this rate structure must also deal with the issue of proration, which is no different than any of the other seasonal rate structures that have been reviewed. In summary, it appears that there would not be any significant implementation or on-going administrative costs associated with this rate structure. RSC/LURS1– In reviewing this EVENUE TABILITY OF OMMERCIALARGE SER ATE TRUCTURE rate structure, the potential revenue volatility of a wet year or drought year was examined. Within this study, the city has stated a goal of annual swings in planned revenue should be no greater than 5% and 10%. For this particular rate design, during a wet year the annual swing in revenue may be approximately 16.50%, while in a drought year, the annual revenue swing may be 42.49%. The revenue variability for the drought period is calculated without drought surcharges. CC/LURS1C’E OMPATIBILITY OF OMMERCIALARGE SERATE TRUCTURE TO THE ITYSXISTING SBS – This particular rate design is currently compatible with the city’s OFTWARE ILLING YSTEM existing billing software but would require some reprogramming effort. 'SQQIVGMEP0EVKI9WIV6EXI7XVYGXYVIz The second commercial/large user rate structure reviewed is very similar to the previous rate structure. The key difference being the approach used to establish the first block size. Under this rate structure, the first block size is set at 90% of the customer’s historical average monthly use. Provided below is the detail of this rate design. Development and Evaluation of the Rate Structures 6-44  City of Boulder—Volume 1 – Evaluation of Water Rate Structures C/URS2–SDR OMMERCIALLARGE SERATETRUCTURE EASONALLY IFFERENTIATED ATE SWA2-BWRAA2-BSR. TRUCTURE ITHLOCK INTER ATENDLOCK UMMER ATE Fixed Monthly Service Charges - 3/4” Meter $8.12/Month 1” 13.88/Month 1-1/4” 21.28/Month 1-1/2” 30.30/Month 2” 53.32/Month 3” 119.02/Month 4” 211.00/Month 6” 473.93/Month 8” 841.99/Month Consumption Charges - Winter Period (Oct. – April) - [1] Block 1 - 90% Average Monthly Use $1.75/1,000 gallons Block 2 - All Usage Over Block 1 $3.00/1,000 gallons Summer Period (May – Sept.) - [1] Block 1 - 90% Average Monthly Use $1.75/1,000 gallons Block 2 - All Usage Over Block 1 $3.30/1,000 gallons [1] Average monthly use is to be determined for each individual customer based upon a three-year average, reviewed and established periodically. The same block 1 size is used for both winter and summer time periods. The use of 90% represents the city’s perception of this class to improve water efficiency. The second commercial/large user Overview of the Block Sizes rate structure is a variation of the Commercial/Large User - Option 2 first commercial/large user rate structure presented. As with the previous rate structure, it is assumed that this rate structure is Ave. Mth non-appealable. Under this Tail Block option, the customer’s first block Block 1 is set at 90% of their average monthly use. The objective of setting the first block at 90% of their average use is to provide an Note: 1st Block based uon 90% of customer secific averae monthl use ppgy incentive to customers to improve their efficiency. As with the previous rate structure, this is a seasonal rate design, with a two block structure in the winter and summer period. The pricing of this rate structure used the same approach as the previous rate structure. As with the commercial/large user rate structure 1, the city may want to review the possibility of adding a third consumption block to this rate structure for those customers with large irrigation requirements. Development and Evaluation of the Rate Structures 6-45  City of Boulder—Volume 1 – Evaluation of Water Rate Structures In viewing the bill comparisons, they appear to be very similar to the previous option. However, Commercial/Large User Rate Structure 2 Average Annual Bill upon closer review it should be $12,000.00 noted that the bills under this $10,000.00 option will be higher for all $8,000.00 Present customers given that the first block $6,000.00 Proposed $4,000.00 is set at 90% of the average $2,000.00 monthly use. Therefore, the 10% $0.00 difference between their first block Brew PubHotelRestaurant and their average monthly use will nd PresentProposedDifference% Change be priced at the higher 2 block Brew Pub$3,668.85$3,902.78$233.936.4% price, which is the component that Hotel$9,737.04$10,193.62$456.574.7% Restaurant$3,207.39$3,050.09($157.30)-4.9% creates the higher bills under this option. The calculated bills in the bill comparison graph use the same Commercial/Large User Rate Structure 2 customers and assumptions as the Consumption By Block previous bill comparison. 100% 84% 71% 75% The consumption that occurs in each block is similar to the Block 1 50% 29% previous rate option. Under this Block 2 16% 25% option, more consumption will be billed within the second block, and 0% the largest billing will be in the WinterSummer summer period. PSC/LURS2 – There are four ERCEIVED TRENGTHS OF OMMERCIALARGE SER ATETRUCTURE perceived major strengths associated with this rate structure. These strengths are as follows: Use of 90% of Average Monthly Use Price Differential for Seasonality Compatible to the Existing Billing System Software Ease of Customer Understanding The strengths of this rate structure are very similar to the previous commercial/large user rate structure reviewed. The major difference between this rate structure and the previous rate structure is the method used to establish the first block of consumption. One of the potential perceived weaknesses of the previous rate structure was that it may not provide sufficient incentive for customers to become more efficient in their use. Under this rate structure, the first block is set at 90% of their historical monthly average, thereby moving a portion of their consumption to the higher cost second block. Combined with the seasonal pricing features of this rate structure, it should help to encourage efficient use. Under this approach, as a customer improves their efficiency, they will still have 10% of their average monthly use billed at the nd higher cost 2 block price, regardless of the improvements made. The other perceived strengths of this rate structure are the same as the previous commercial/large user rate structure. That is, the rate structure contains seasonal pricing to better reflect the value of the water in the peak use Development and Evaluation of the Rate Structures 6-46  City of Boulder—Volume 1 – Evaluation of Water Rate Structures periods. At the same time, this rate structure should be compatible with the city’s existing billing software, and finally, this rate structure should be relatively easy for customers to understand, yet not so overly simplistic that it does not communicate the goals of efficiency. PWC/LURS2 – There are two ERCEIVED EAKNESSES OF OMMERCIALARGESER ATETRUCTURE perceived major weaknesses associated with this rate structure. These weaknesses are as follows: Lack of an “Excessive Use” Block nd 2 Block Size Does Not Relate Well to System Water Supply Characteristics Similar to the previous commercial/large user rate structure, this rate structure does not contain a third block to penalize “inefficient” use, whether it be indoor or outdoor use. However, it should be noted that the use of the 90% factor for the first block size was intended to help mitigate the lack of an excessive use block. Finally, as with the previous rate option, this rate structure has not created an outdoor block of water and shaped it for irrigation requirements. As noted previously, approximately one-half of the customers within this class of service have separate metered irrigation. ACC/LURS2 – DMINISTRATIVE ONSIDERATIONS OF OMMERCIALARGESER ATE TRUCTURE This rate structure is assumed to be non-appealable. Therefore, the administrative issues associated with this rate structure are identical to the previous commercial/large user rate structure. In the previous commercial/large user rate structure discussion, it was noted that the city would need to establish the method to calculate and determine, for billing purposes, the average monthly use for each individual customer. In this particular rate structure, it will require the same level of effort, and the monthly average is simply set at 90% of the average amount. It is again presumed that these averages would be calculated and updated on a periodic basis, and that there would not be any significant upfront costs associated with determining these averages, nor would there be any significant on-going administrative costs. Finally, as with the other rate structures, the issue of proration must be addressed within the billing system for the seasonal change in price. In summary, it appears that there would not be any significant implementation or on-going administrative costs associated with this rate structure. RSC/LURS2– In reviewing this EVENUE TABILITY OF OMMERCIALARGE SER ATE TRUCTURE rate structure, the potential revenue volatility of a wet year or drought year was examined. Within this study, the city has stated a goal of annual swings in planned revenue should be no greater than 5% and 10%. For this particular rate design, during a wet year the annual swing in revenue may be approximately 16.53%, while in a drought year, the annual revenue swing may be 42.77%. The revenue variability for the drought period is calculated without drought surcharges. CC/LURS2C’E OMPATIBILITY OF OMMERCIALARGE SERATE TRUCTURE TO THE ITYSXISTING SBS – This particular rate design is currently compatible with the city’s OFTWARE ILLING YSTEM existing billing software but would require some reprogramming efforts. Development and Evaluation of the Rate Structures 6-47  City of Boulder—Volume 1 – Evaluation of Water Rate Structures 'SQQIVGMEP0EVKI9WIV6EXI7XVYGXYVIz The final commercial/large user rate structure uses a different approach to establish the first block size. Under this approach, the block size varies based upon the customer’s meter size. For each meter size, the average monthly usage is determined, and that is used as the first block size. Provided below is the detail of this rate design. C/URS3–N-SRSW OMMERCIALLARGE SERATETRUCTURE ONEASONAL ATETRUCTURE ITH TFBBMSAU HEIRST LOCK ASED UPON THE ETER IZE AND THE VERAGE SE OF THE CCHTSMS. OMMERCIAL USTOMERS AVING HATAME ETER IZE Fixed Monthly Service Charges - st Meter Size1 Block Size Mthly Service Charge 3/4” Meter 11,000 $8.12/Month 1” 33,000 13.88/Month 1-1/4” 96,000 21.28/Month 1-1/2” 77,000 30.30/Month 2” 146,000 53.32/Month 3” 249,000 119.02/Month 4” 817,000 211.00/Month 6” 2,569,000 473.93/Month 8” 2,486,000 841.99/Month Consumption Charges - [1] Monthly Allowance by Meter Size $1.75/1,000 gallons All Usage Over Block 1 $3.00/1,000 gallons [1] First block size is determined based upon the meter size of the customer and the average use of commercial customers with the same meter size. As noted above, this rate structure is unique Overview of the Block Sizes in comparison to the other two commercial Commercial/Large User - Option 3 rate structures presented. The size of the first block varies based upon the meter size of the customer. For each meter size, the Ave. Mth average monthly use is determined for all Tail Block the commercial/large user customers with Block 1 that same meter size. Given the average monthly use for each meter size, the first block of the rate structure is established. Note: 1st Block based upon meter size and ave. cust. use for that specific meter size How often the average (first block) sizes are recalculated is an administrative matter. The pricing of this rate structure used the same approach as the previous rate structures. As with the previous commercial/large user rate structures presented, the city may want to review the possibility of adding a third consumption block to this rate structure for those customers with “excessive” use or large irrigation requirements. Development and Evaluation of the Rate Structures 6-48  City of Boulder—Volume 1 – Evaluation of Water Rate Structures In viewing the bill comparisons, there appears to be the potential for Commercial/Large User Rate Structure 3 large customer impacts from this Average Annual Bill rate structure. It should be noted $16,000.00 that the bill comparisons for the $14,000.00 $12,000.00 commercial/large user selected Present $10,000.00 $8,000.00 Proposed three random commercial $6,000.00 $4,000.00 customers, and the impacts for $2,000.00 $0.00 specific customers may vary Brew PubHotelRestaurant widely. The large impacts are a result of the change in the rate PresentProposedDifference% Change structure. Under the present rates, Brew Pub$3,668.85$5,367.60$1,698.7546.3% Hotel$9,737.04$14,949.84$5,212.8053.5% a customer is billed for usage up to Restaurant$3,207.39$3,585.84$378.4511.8% their individual AWC amount at the first block price. Under this Commercial/Large User Rate Structure 3 rate structure, the average amount Consumption By Block by Meter Size of usage for all customers within 75% 66%66% the same meter size would 60% 59% 52%56%57% 53%53% 54% 47% determine the breakpoint for the 44% 49%47%46%44% 50% 41% 40% first and second block prices. 34% 35% Block 1 Block 2 Therefore, by definition, for certain 25% customers with above “average” usage, more of their usage will be 0% billed at the higher second block 5/8"3/4"1"1-1/4"1-1/2"2"3"4"6"8" MeterMeterMeterMeterMeterMeterMeterMeterMeterMeter price. Those customers with “below” average consumption should see below average impacts, and conversely, those customers with above average usage will see above average impacts from this change in structure and determination of the first block size. While the above impacts may be considered appropriate and acceptable to the city, for purposes of encouraging efficient use for this class of service, caution should be taken in assuming that any consumption over and above average use is “inefficient” use. PSC/LURS3 – There are three ERCEIVED TRENGTHS OF OMMERCIALARGE SER ATETRUCTURE perceived major strengths associated with this rate structure. These strengths are as follows: Encourage Efficient Use Compatible to the Existing Billing System Software Ease of Customer Understanding The strengths of this rate structure are fairly similar to the previous commercial/large user rate structures reviewed. This rate structure has attempted to provide a stronger approach to encouraging efficient use for commercial customers. At the same time, this rate structure should be compatible with the city’s existing billing software, and finally, this rate structure should be relatively easy for customers to understand. It is a bit more complex than the prior rate structures, but it is not so overly complex such that customers would not understand the approach. Development and Evaluation of the Rate Structures 6-49  City of Boulder—Volume 1 – Evaluation of Water Rate Structures PWC/LURS3 – There are ERCEIVED EAKNESSES OF OMMERCIALARGESERATETRUCTURE three perceived major weaknesses associated with this rate structure. These weaknesses are as follows: Lack of an “Excessive Use” Block nd 2 Block Size Does Not Relate Well to System Water Supply Characteristics May Have Large Rate/Financial Impacts to Customers Similar to the previous commercial/large user rate structure, this rate structure does not contain a third block to penalize “inefficient” use, whether it be indoor or outdoor use. However, the rate is structured with the intent of encouraging efficient use, by using the meter size averages. The major problem is that “above average” use does not necessarily imply “inefficient” use. It may simply imply a customer that has a larger than average restaurant, a larger than average office building, or a more water intensive business (e.g. laundromat, etc.). These customers, as demonstrated in the bill comparisons may see fairly large rate/financial impacts from this rate structure. Finally, as with the previous rate option, this rate structure has not created an outdoor block of water and shaped it for irrigation requirements. As noted previously, the majority of customers within this class of service have separate metered irrigation. ACC/LURS3 – DMINISTRATIVE ONSIDERATIONS OF OMMERCIALARGESER ATE TRUCTURE This rate structure is assumed to be non-appealable. Therefore, the administrative issues associated with this rate structure are identical to the previous commercial/large user rate structure. In the previous commercial/large user rate structure discussions, it was noted that the city would need to establish the method to calculate and determine, for billing purposes, the average monthly use for each individual customer. In this particular case, the city would need to determine the method to be used to consistently determine the average use for each meter size. It is again presumed that these averages would be calculated and updated on a periodic basis, and that there would not be any significant upfront costs associated with determining these averages, nor would there be any significant on-going administrative costs. In summary, it appears that there would not be any significant implementation or on-going administrative costs associated with this rate structure. RSC/LURS3– In reviewing this EVENUE TABILITY OF OMMERCIALARGE SER ATE TRUCTURE rate structure, the potential revenue volatility of a wet year or drought year was examined. Within this study, the city has stated a goal of annual swings in planned revenue should be no greater than 5% and 10%. For this particular rate design, during a wet year the annual swing in revenue may be approximately 12.05%, while in a drought year, the annual revenue swing may be 34.76%. The revenue variability for the drought period is calculated without drought surcharges. CC/LURS3C’E OMPATIBILITY OF OMMERCIALARGE SERATE TRUCTURE TO THE ITYSXISTING SBS – This particular rate design is currently compatible with the city’s OFTWARE ILLING YSTEM existing billing software assuming some reprogramming efforts. For each meter size, the block size will need to be determined and entered into the system. This concludes the review of the commercial/large user rate structures. The focus will now shift to the metered irrigation rate structures. Development and Evaluation of the Rate Structures 6-50  City of Boulder—Volume 1 – Evaluation of Water Rate Structures 6.10 Review of the Metered Irrigation Rate Structures The final class of service reviewed was the metered irrigation rate structures. For this particular class of service, three rate structures were recommended for review and analysis by the WRAB. Provided below is a detailed review of each of the rate structures, along with a discussion of the perceived strengths and weaknesses of each rate structure, along with any administrative issues/costs associated with the rate design. 1IXIVIH-VVMKEXMSR6EXI7XVYGXYVIz The first rate structure reviewed is a uniform rate structure. Provided below is the detail of this rate design. MIRS1–UR. ETERED RRIGATION ATETRUCTURE NIFORM ATE Fixed Monthly Service Charges - 3/4” Meter $8.12/Month 1” 13.88/Month 1-1/4” 21.28/Month 1-1/2” 30.30/Month 2” 53.32/Month 3” 119.02/Month 4” 211.00/Month 6” 473.93/Month 8” 841.99/Month Consumption Charges - All Metered Consumption $4.70/1,000 gallons For this particular rate structure, all consumption is priced at the Irrigation Rate Structure 1 same rate, and there is no Average Annual Bill distinction between base or extra- $8,000.00 capacity costs in the development $6,000.00 Present of the prices. Rather, the $4,000.00 Proposed consumption charges have been $2,000.00 set at a level to meet the target $0.00 revenue requirements for this 4,800 Sq. Ft.9,500 Sq. Ft.100,000 Sq. Ft. Irrigable AreaIrrigable AreaIrrigable Area class of service. In assessing the impact to PresentProposedDifference% Change 4,800 Sq. Ft. Irrigable Area$1,391.04$1,277.14($113.90)-8.2% customers from this rate 9,500 Sq. Ft. Irrigable Area$3,285.24$3,246.44($38.80)-1.2% structure, various sized irrigable 100,000 Sq. Ft. Irrigable Area$6,473.04$7,161.54$688.5010.6% areas were reviewed. It would appear that small irrigable areas would potentially receive a slight reduction in their annual bills, and larger irrigable areas may see a slight increase in their annual bill. The specific impacts to a customer is a function of their irrigation practices and usage levels. Development and Evaluation of the Rate Structures 6-51  City of Boulder—Volume 1 – Evaluation of Water Rate Structures PSMIRS1 – There are two ERCEIVED TRENGTHS OF ETERED RRIGATION ATE TRUCTURE perceived strengths associated with this rate structure. These strengths are as follows: Compatible to the Existing Billing System Software Ease of Administration/Customer Understanding The strength of this rate structure is its simplicity. In particular, this rate structure would be compatible with the city’s existing billing system software and it would be very easy for customers to understand and the city to administer. PWMIRS1 – There are two ERCEIVED EAKNESSES OF ETERED RRIGATION ATE TRUCTURE perceived weaknesses associated with this rate structure. These weaknesses are as follows: Uniform Rate Structure Lack of an “Excessive Use” Block While some may view customer understanding and administrative ease as a strength for a uniform rate structure, it can also be viewed as a weakness from a price signal and resource perspective. A uniform rate structure may not provide incentives for efficient use or conservation. This might suggest the need for an “excessive use” or tail block. However, the price established for this rate option is at a level which should encourage some efficient use and conservation. ACMIRS1 – This rate DMINISTRATIVE ONSIDERATIONS OF ETERED RRIGATION ATE TRUCTURE structure is very simple from an administrative perspective and there does not appear to be any administrative issues associated with it, nor any major implementation costs or on-going costs associated with it. RSMIRS1– In reviewing this rate EVENUE TABILITY OF ETERED RRIGATION ATE TRUCTURE structure, the potential revenue volatility of a wet year or drought year was examined. Within this study, the city has stated a goal of annual swings in planned revenue should be no greater than5% and 10%. For this particular rate design, during a wet year the annual swing in revenue may be approximately 13.97%, while in a drought year, the annual revenue swing may be56.45%. CMIRS1C’E OMPATIBILITY OF ETERED RRIGATION ATETRUCTURE TO THE ITYSXISTING SBS – This particular rate design is compatible with the city’s existing OFTWARE ILLING YSTEM billing software but would require some reprogramming efforts. Development and Evaluation of the Rate Structures 6-52  City of Boulder—Volume 1 – Evaluation of Water Rate Structures 1IXIVIH-VVMKEXMSR6EXI7XVYGXYVIz The next metered irrigation rate structure reviewed is a water budget rate structure. Provided below is the detail of this rate design. MIRS2–WT(3)C ETERED RRIGATION ATETRUCTURE ATER BUDGET WITH HREEONSUMPTION B.B1BUCSIA,S LOCKSLOCK IS ASEDPON USTOMER PECIFIC RRIGABLE REAUCCEEDING BBURTOG. LOCKS ARE ASED PON ELATIONSHIP OUTDOOROAL Fixed Monthly Service Charges - 3/4” Meter $8.12/Month 1” 13.88/Month 1-1/4” 21.28/Month 1-1/2” 30.30/Month 2” 53.32/Month 3” 119.02/Month 4” 211.00/Month 6” 473.93/Month 8” 841.99/Month Consumption Charges - [1] Block 1 - Customer Specific Irrigable Area $3.00/1,000 gallons Block 2 - 101% to 150% of Outdoor Goal $3.50/1,000 gallons Block 3 - Over 150% of Outdoor Goal $6.80/1,000 gallons [1] Each month will have a set outdoor goal based on the irrigable area as determined by the city and an irrigation application rate of 15 gallons per square foot. The monthly irrigation requirements will be shaped by historical weather and ET. This rate structure option is a water budget rate structure that uses the Overview of the Block Shapes customer’s irrigable area to establish Metered Irrigation - Option 2 the first block size. The block is shaped by historical ET, and there is 25,000 a fixed allowance in the winter 20,000 period for watering of shrubs and Tail Block 15,000 trees based on an assumed level of Block 2 10,000 watering requirements. Block 1 5,000 Given that this rate structure uses the 0 st irrigable area for establishing the 1 block size, it is assumed that this rate structure is appealable. In establishing the prices for this rate structure, the first block contains both the base and extra- capacity costs. The succeeding blocks are based upon placing higher than average demand (peaking factors) upon the system. The tail block has been set at the estimated marginal cost of the city. Development and Evaluation of the Rate Structures 6-53  City of Boulder—Volume 1 – Evaluation of Water Rate Structures In developing this particular rate structure and the associated bill Irrigation Rate Structure 2 Average Annual Bill comparisons, the most difficult part $7,000.00 was the lack of readily accessible $6,000.00 $5,000.00 irrigable data. Therefore, for Present $4,000.00 Proposed $3,000.00 purposes of this study, the total $2,000.00 irrigable area needed to be $1,000.00 $0.00 estimated. In terms of the bill 4,800 Sq. Ft.9,500 Sq. Ft.100,000 Sq. Ft. comparison, three different Irrigable AreaIrrigable AreaIrrigable Area irrigable areas have been shown. It PresentProposedDifference% Change appears that under this rate 4,800 Sq. Ft. Irrigable Area$1,391.04$1,404.24$13.200.9% structure, the largest irrigable areas 9,500 Sq. Ft. Irrigable Area$3,285.24$3,706.44$421.2012.8% 100,000 Sq. Ft. Irrigable Area$6,473.04$4,829.34($1,643.70)-25.4% will receive the largest reduction in bills (benefit). This is because, the Irrigation Rate Structure 2 existing rate structure bases the Consumption By Block (assumes 20,000 sq. ft. area) irrigation customer’s first and 75% second block size on the average 55% AWC of all customers with that 50% particular meter size. Currently it 35% appears that large irrigation 25% customers have a significant 10% portion of their consumption in the current tail block ($6.60/1,000 0% gallons). By comparison, this Block 1Block 2Block 3 approach provides the estimated irrigation requirements to the customer at $3.00/1,000 gallons, with an additional 50% over and above that at $3.50/1,000 gallons. It appears that even with this rate structure a large amount of consumption will still be consumed in the third block. This amount of consumption is estimated given the lack of customer/property specific irrigable areas. PSMIRS2 – There are three ERCEIVED TRENGTHS OF ETERED RRIGATION ATE TRUCTURE perceived major strengths associated with this rate structure. These strengths are as follows: Outdoor Watering Allocation Shaping of the Water Allocation Penalty for “Excess” Use As with the other water budget rate structures, the strength of this rate structure centers around the development of the first block of water that is based upon the irrigable area of the customer. At the same time, this allocation of water is shaped to reflect the changing irrigation requirements by month (i.e. historical ET). Finally, this rate structure contains a penalty component for “excess” use. Development and Evaluation of the Rate Structures 6-54  City of Boulder—Volume 1 – Evaluation of Water Rate Structures PWMIRS2 – There are two ERCEIVED EAKNESSES OF ETERED RRIGATION ATE TRUCTURE perceived major weaknesses associated with this rate structure. These weaknesses are as follows: Measurement Needed of Customer Specific Irrigable Area Possible Customer Perception of Significant Inequities By using customer specific irrigable area, the city will need to determine the area to be used for billing purposes, and convert that amount of irrigable area to a volume of water for use in the first block of the rate structure. How the irrigable area is determined is an administrative issue, but it would potentially open the city up to appeals and requests for variances. At the same time, the volume of water provided to the customer at the low cost first block is a function of irrigable area. Some customers may perceive that this approach is inequitable. That is, a customer that has 10,000 square feet of irrigable area receives 150,000 gallons of water at the low cost first block price. In contrast, the customer with 100,000 square feet of irrigable area receives 1,500,000 gallons of water at the low cost block. ACMIRS2 – This DMINISTRATIVE ONSIDERATIONS OF ETER RRIGATION ATETRUCTURE particular rate structure has two major administrative issue associated with it. First is the issue of the determination of the customer specific irrigation area. There are approximately 1,200 metered irrigation accounts. The city does not currently have information on individual property irrigable areas for this class of service. Using the assumption of $25 - $50 per account to determine the irrigable area, the cost associated with determining irrigable area for each individual account/property may be in the range of $30,000 to $60,000. Assuming that 5% of the accounts may appeal, this would translate to approximately 60 appeals. Of this amount, 55 could be resolved at a cost of $50.00 -$100.00 per account or a total cost of $2,750 - $5,500. For the remaining 5 customers, a more formal appeal process may be required. Assuming a formal appeal cost of $100 - $250 per appeal, this may translate into a cost of $500 - $1,250. Once the irrigable area is determined, the city would need to add/update information for new customers. For existing customers, it would be difficult to determine changes in irrigable area, and most likely, it would be up to the customer to report any significant changes in irrigable area. The other significant administrative issue associated with this rate structure is the issue of proration. As with the other water budget rate structures, the city may need to prorate the customer bill each month to reflect the timing of the billing and the quantity of water provided in each of the blocks over the billing period. In summary, it appears that there would be some significant implementation costs associated with this rate structure, but there would be minimal annual on- going costs. At the same time, the administrative issue of proration would need to be addressed within the billing system. RSMIRS2– In reviewing this rate EVENUE TABILITY OF ETERED RRIGATION ATE TRUCTURE structure, the potential revenue volatility of a wet year or drought year was examined. Within this study, the city has stated a goal of annual swings in planned revenue should be no greater than5% and 10%. For this particular rate design, during a wet year the annual swing in revenue may be approximately 17.59%, while in a drought year, the annual revenue swing may be74.93%. Development and Evaluation of the Rate Structures 6-55  City of Boulder—Volume 1 – Evaluation of Water Rate Structures CMIRS2C’E OMPATIBILITY OF ETERED RRIGATION ATETRUCTURE TO THE ITYSXISTING SBS – This particular rate design is currently not compatible with the OFTWARE ILLING YSTEM city’s existing billing software. 1IXIVIH-VVMKEXMSR6EXI7XVYGXYVIz The final metered irrigation rate structure reviewed is an inverted block rate structure. Provided below is the detail of this rate design. MIRS3–IBRT(3) ETERED RRIGATION ATE TRUCTURE NVERTED LOCK ATE WITH HREE CB.B1BU90%C’A ONSUMPTION LOCKSLOCK IS ASED PON OF THE USTOMERSVERAGE SC(ASC),SBBUR UMMER ONSUMPTION UCCEEDING LOCKS ARE ASEDPONELATIONSHIP TO B1. LOCK Fixed Monthly Service Charges - 3/4” Meter $8.12/Month 1” 13.88/Month 1-1/4” 21.28/Month 1-1/2” 30.30/Month 2” 53.32/Month 3” 119.02/Month 4” 211.00/Month 6” 473.93/Month 8” 841.99/Month Consumption Charges - [1] Block 1 - 90% of Customer’s ASC $3.30/1,000 gallons Block 2 - 101% to 150% of Block 1 $4.00/1,000 gallons Block 3 - Over 150% of Block 1 $6.80/1,000 gallons [1] Average summer consumption is to be determined for each individual customer based upon a three-year average, reviewed and established periodically. The use of 90% represents the city’s perception of this class to improve water efficiency. This rate design is an inverted block Overview of the Block Sizes rate structure with three Metered Irrigation - Option 3 consumption blocks. In this case, the first block is based upon a calculation of 90% of the average Ave. Summer summer use of the customer. The Tail Block second block and tail block are Block 2 similar to the prior water budget Block 1 rate structure in that it is based st upon the relationship to the 1 block or goal. Note: 1st Block based upon 90% of customer average summer use Development and Evaluation of the Rate Structures 6-56  City of Boulder—Volume 1 – Evaluation of Water Rate Structures The pricing for this particular rate structure is very similar to that Irrigation Rate Structure 3 Average Annual Bill used for the previous metered $7,000.00 irrigation rate structure. That is, $6,000.00 the first block assumes both base $5,000.00 Present $4,000.00 and extra-capacity use under Proposed $3,000.00 $2,000.00 average conditions. The second $1,000.00 $0.00 block assumes a customer that 4,800 Sq. Ft.9,500 Sq. Ft.100,000 Sq. Ft. places a higher than normal peak Irrigable AreaIrrigable AreaIrrigable Area use on the system, is allocated a PresentProposedDifference% Change greater share of the capacity costs. 4,800 Sq. Ft. Irrigable Area$1,391.04$979.64($411.40)-29.6% Finally, the tail block is set at the 9,500 Sq. Ft. Irrigable Area$3,285.24$2,401.54($883.70)-26.9% 100,000 Sq. Ft. Irrigable Area$6,473.04$5,175.64($1,297.40)-20.0% marginal cost rate. Customers under this rate design would likely see some reductions in their annual bill. This is primarily a function of the existing rate structure that places a large amount of consumption in the tail block by using the AWC to establish the initial block size. Under this particular rate structure, Irrigation Rate Structure 3 there is still a significant amount of Consumption By Block 60% consumption that is anticipated to 52% occur in the tail block of this rate 50% 37% structure. However, by using 90% 40% of average summer use to establish 30% the first block size, a significant 20% 12% portion of the consumption has 10% been moved to the first block price. 0% Block 1Block 2Block 3 PSMIRS3 – There are two ERCEIVED TRENGTHS OF ETERED RRIGATION ATE TRUCTURE perceived major strengths associated with this rate structure. These strengths are as follows: Use of 90% of Average Monthly Summer Use; Avoidance of Measuring Customer Specific Irrigable Area Penalties for “Excess” Use This particular rate structure uses a different approach to establish the first block size. While the previous rate structure used customer specific irrigable area measurements, this approach uses a historical consumption approach and sets the block equal to 90% of the calculated average. While this may not provide the strongest relationship between irrigable area and the allocated volume of water, it does avoid the need to determine or measure each customer’s individual irrigable area. At the same time, this rate structure does contain penalties for “excess” use. PWMIRS3 – There are two ERCEIVED EAKNESSES OF ETERED RRIGATION ATE TRUCTURE perceived major weakness associated with this rate structure. These weaknesses are as follows: Development and Evaluation of the Rate Structures 6-57  City of Boulder—Volume 1 – Evaluation of Water Rate Structures First Block Size Lacks a Direct Relationship to Irrigable Area Lack of Shaping for the Water Allocation While the approach used to establish the first block for this rate structure is a strength from an administrative standpoint, from a conservation and efficient use perspective, it may be perceived as not having a direct relationship to the irrigable area, and may simply reward past excessive use practices by the customer. At the same time, the allocation of the water is not shaped for historical ET. ACMIURS3 – It DMINISTRATIVE ONSIDERATIONS OF ETEREDRRIGATION SERATETRUCTURE is assumed that this rate structure is non-appealable. Therefore, the administrative issues associated with this rate structure appear minimal. The administrative issues associated with this rate structure require the city to determine the first block size based upon historical consumptive use. For the other rate structures that used this approach (commercial/large users), it was presumed that no significant implementation or on-going costs would be associated with this issue. RSMIRS3– In reviewing this rate EVENUE TABILITY OF ETERED RRIGATION ATE TRUCTURE structure, the potential revenue volatility of a wet year or drought year was examined. Within this study, the city has stated a goal of annual swings in planned revenue should be no greater than5% and 10%. For this particular rate design, during a wet year the annual swing in revenue may be approximately 15.86%, while in a drought year, the annual revenue swing may be60.07%. CMIRS3C’E OMPATIBILITY OF ETERED RRIGATION ATETRUCTURE TO THE ITYSXISTING SBS – This particular rate design is assumed to be compatible with the OFTWARE ILLING YSTEM city’s existing billing software but would require some reprogramming effort. This concludes the review of the metered irrigation rate structures. 6.11 Summary Matrices of Proposed Rate Options To better understand and compare the various proposed rate structures for each class of service, summary matrices have been prepared by customer class of service. Presented below is the summary of the rate structure matrix for each customer class of service. Development and Evaluation of the Rate Structures 6-58  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Development and Evaluation of the Rate Structures 6-59  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Summary Matrix of the Multi-Family Residential Rate Options MULTI-FAMILY RESIDENTIAL Rate Structure CharacteristicsOption 1Option 2Option 3 SeasonalWater Budget - IrrigableWater Budget - Irrigable Type of Structure AreaArea 2-Winter; 3-Summer65 No. of Consumption Blocks 4,000/living unit4,000/living unit4,000/living unit Size of the 1st Block (gallons) Summer period; 3rd Block,3rd Block; Based upon3rd Block; Based upon Key Assumption for Outdoor Use Use over 6,000 gal./livingcustomer specific irrigablecustomer specific irrigable unit. Winter period; Allarea w/ application rate ofarea w/ application rate of excess use over the 15 gallons/S.F of 15 gallons/S.F of first blockirrigable areairrigable area NoYesYes Outdoor Block Shaped for ET? Estimated Annual Bill Impacts $344.09$351.74$351.74 M.F. - 2 Unit - AWC = 8 ($358.14) $1,508.49$1,640.54$1,651.14 M.F. - 10 Unit - AWC = 57 ($1,442.19) $1,705.69$1,705.69$1,705.69 M.F. - 50 Unit - AWC = 101 ($1,684.74) Establishes reasonableOutdoor watering alloc.Outdoor watering alloc. Perceived Strengths block sizesShaping of water alloc.Shaping of water alloc. Price diff. for seasonality Compatible to city's existing billing system software Ease of customer understanding Structure does notMeasurements needed to Measurements needed to Perceived Weaknesses relate well to system use customer specific use customer specific water supply irrigable area irrigable area Master metered vs.Master metered vs. characteristics individually metered individually metered customers customers Complexity based uponSmall block size for the number of blocks 4th block Administrative Considerations Appealable?NoYesYes Estimated Implementation CostsSee detail belowSee detail belowSee detail below (Non-billing software related) - Determine # of living units$4,600 - $13,800$4,600 - $13,800$4,600 - $13,800 - Initial lot size determinationsN/A$11,500 - $27,500$11,500 - $27,500 - Customer appeals - Est. # and $N/A112 - $5,600 - $11,200112 - $5,600 - $11,200 13 - $1,300 - $3,25013 - $1,300 - $3,250 - Indoor appeals/If Applicable - Est. # and $N/A115-175 - $1,150 - $4,375115-175 - $1,150 - $4,375 Est. On-Going Admin. Costslowminimalminimal (Non-billing software related) Need for Proration of Bills?Yes - at change of seasonsYes - monthlyYes - monthly Revenue Stability Wet Year --9.6%-3.4%-3.4% Dry Year --56.6%-37.2%-37.5% Compatible w/ City's Existing YesNoNo Billing Software? Reprogramming EffortsUp to $150,000 Development and Evaluation of the Rate Structures 6-60  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Summary Matrix of the Commercial Rate Options COMMERCIAL/LARGE USER Rate Structure CharacteristicsOption 1Option 2Option 3 SeasonalSeasonalNon-Seasonal Type of Structure 2-Winter; 2-Summer2-Winter; 2-Summer2 No. of Consumption Blocks Cust. Specific-100% Ave. Mth.Cust. Specific - 90% Ave. Mth.Specific by Meter Size - 100% Ave. Mth. Size of the 1st Block (gallons) No specific block targetingNo specific block targetingNo specific block targeting Key Assumption for Outdoor Use outdoor use. Any outdooroutdoor use. Any outdooroutdoor use. Any outdoor use is likely billed at the use is likely billed at the use is likely billed at the 2nd block price2nd block price2nd block price N/AN/AN/A Outdoor Block Shaped for ET? $3,740.95$3,902.78$5,367.60 Comm/L.U. - Brewpub ($3,668.85) $9,843.39$10,193.62$14,949.84 Comm/L.U. - Hotel ($9,737.04) $2,975.69$3,050.09$3,585.84 Comm/L.U. - Restaurant ($3,207.39) Price diff. for seasonalitUse of 90% of average Encourage efficient use Perceived Strengthsy Compatible to city's existingCompatible to city's existing monthly use Price diff. for seasonalit billing system softwarey billing system software Ease of customeCompatible to city's existingEase of custome rr understanding billing system software understanding Ease of custome r understanding Potential lack of incentivesLack of an "excessive use"Lack of an "excessive use" Perceived Weaknesses for efficient use block for indoor use block for indoor use Lack of an "excessive use"2nd block does not relate2nd block does not relate block for indoor use well to system water well to system water 2nd block does not relate supply characteristics supply characteristics May have large rate/financial well to system water supply characteristics impacts to customers Administrative Considerations Appealable?NoNoNo Estimated Implementation CostsVery lowVery lowVery low (Non-billing software related) - Determine # of living unitsN/AN/AN/A - Initial lot size determinationsN/AN/AN/A - Customer appeals - Est. # and $N/AN/AN/A - Indoor appeals/If Applicable - Est. # and $ Est. On-Going Admin. Costsvery lowvery lowvery low (Non-billing software related) Need for Proration of Bills?Yes - at change of seasonsYes - at change of seasonsNo Revenue Stability Wet Year --16.5%-16.5%-12.1% Dry Year --42.5%-42.8%-34.8% Compatible w/ City's Existing Billing Software?YesYesYes Up to $150,000Up to $150,000Up to $150,000 Reprogramming Efforts Development and Evaluation of the Rate Structures 6-61  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Summary Matrix of the Irrigation Rate Options METERED IRRIGATION Rate Structure CharacteristicsOption 1Option 2Option 3 UniformWater Budget - IrrigableWater Budget - 90% Type of Structure Areaof Ave. Mthly Summer Use 133 No. of Consumption Blocks N/ACust. Specific Irrig. Area90% Ave. Mthly Summer Use Size of the 1st Block (gallons) N/A1st block is based upon1st block is based upon Key Assumption for Establishing customer specific irrigable90% of customer's Outdoor Watering Requirements area w/ application rate ofaverage (monthly) summer 15 gallons/S.F of consumption (ASC) irrigable area NoYesNo Outdoor Block Shaped for ET? Estimate Annual Bill Impacts 4,800 S.F. Irrigable Area ($1,277.14)$1,277.14$1,404.24$979.64 9,500 S.F. Irrigable Area ($3,285.24)$3,246.44$3,706.44$2,401.54 100,000 S.F. Irrigable Area ($6,473.04)$7,161.54$4,829.34$5,175.64 Compatible to city's existingOutdoor watering alloc.Use of 90% ASC; Avoidance Perceived Strengths Shaping of water alloc. billing system software measuring customer Ease of administrationPenalty for "excess" use specific irrigable area Ease of customerPenalty for "excess" use understanding Uniform rate structureMeasurements needed to First block lacks a direct Perceived Weaknesses Lack of an "excessive use" use customer specific relationship to irrigable block for indoor use irrigable area area Possible customer Lack of shaping for water perception of significant allocation inequitities in water allocation Administrative Considerations Appealable?NoYesNo Estimated Implementation CostsVery lowSee detail belowVery low (Non-billing software related) - Determine total lot size areaN/AN/AN/A - Determine irrigable areaN/A$30,000 - $60,000N/A - Customer appeals - Est. # and $N/A55 - $2,750 - $5,500N/A 5 - $500 - $1,250 Est. On-Going Admin. Costsvery lowminimalvery low (Non-billing software related) Need for Proration of Bills?NoYes - monthlyNo Revenue Stability Wet Year --14.0%-17.6%-15.9% Dry Year --56.5%-74.9%-60.1% Compatible w/ City's Existing YesNoNo Billing Software? Reprogramming EffortsUp to $150,000Up to $150,000 Development and Evaluation of the Rate Structures 6-62  City of Boulder—Volume 1 – Evaluation of Water Rate Structures 6.12 Other Potential Rate Structure Enhancements In developing the rate structure alternatives for the various customer classes of service, there were certain features which can be applied to any of the final rate structures developed (e.g. adjustment for water supply conditions, incentives for exceeding goals, etc.). These features were not included within the rate designs developed above. In summary form, the five features that were not included in the rate designs developed above include the following: Adjustment of blocks and price for water supply availability Goal based incentives Adjustment of block sizes for actual ET (weather) Discounts for city approved irrigation systems Drought Surcharges If the city deems any of the above features desirable, the city must first select the final rate designs and then determine the applicability of the above individual features to the specific rate design. These features may best be added at a later date, however, if the city issues a request for proposal (RFP) for new billing software, the software should be reviewed for its ability to implement the above features. Provided below is a brief overview of these features as a possible enhancement to the city’s rate structures. The first enhancement is to adjust the block sizes and price of water based upon supply availability. The difficult component of this enhancement is not so much the technical portion of adjusting the block sizes and price, but rather, making the determination on water supply availability and the recommended adjustments. If Boulder did not have a drought surcharge mechanism in place, this enhancement could be a very valuable feature. However, the city does have a schedule for drought surcharges. Therefore, EES concludes that this enhancement would provide little value to the city, since it would only apply up to and until drought surcharges are to be applied. The second enhancement is “goal-based incentives.” “Goal-based incentives” are related to block 2 usage, and rewards a customer for consuming less then their block 2 allotment in the peak use period. For example, if a customer has a block 2 size of 10,000 gallons, and uses only 8,000 gallons in the month, they would be given a credit for 2,000 gallons times a fixed incentive rate. The customer is still charged the standard rate for the 8,000 gallons consumed, but is given some level of credit (reward) for consuming below their allotted amount. This approach is most clearly tied to water budget rate structures and provides an incentive for customers to minimize their use. Our recommendation is that if water budgets are implemented that this feature not be implemented immediately. Rather, the city should first be assured that the water budgets as implemented are achieving both the conservation/efficiency and revenue goals established for that class. After some experience in working with water budgets, the city may consider the prudence of implementing this rate, and any policy issues that may be associated with it. The third enhancement is associated with adjustments for weather and ET. One of the challenges of a water budget rate structure is its complexity. Using historical ET to establish monthly block sizes creates differing block sizes from month to month. From the customer’s perspective, this is much more complex than more traditional rate structures. In reviewing water budget rate Development and Evaluation of the Rate Structures 6-63  City of Boulder—Volume 1 – Evaluation of Water Rate Structures structures, one of the features that is often discussed is the adjustment of the block sizes to reflect the actual weather/ET. By adjusting for actual weather/ET, the customer’s block 2 size and succeeding blocks are adjusted from their original allocation. Therefore, when it is hotter than typical, the customer is provided a larger block of water to reflect the customer’s increased irrigation requirements. In developing this study, numerous perspectives concerning the value of adjusting for actual weather/ET have been encountered. At this point in time, there is no solid evidence/research that suggests adjusting for actual weather/ET provides a significant benefit to the customer or the utility. At the same time, there is currently a poor feedback mechanism between the utility and the customer’s goal, such that adjusting the goal on a monthly basis may be confusing, particularly when the weather is cooler, and the block size is reduced. In addition, it would add another level of complexity to the billing system that may need further refinement over time. Given the above, it would be our recommendation at this time that this feature of the water budget rate structure not be included initially. With better customer understanding of a water budget rate structure, and technology improvements to provide better customer feedback, this may be an issue the city may want to examine again at a later date. The fourth enhancement is a discount for city approved irrigation systems. The goal of this enhancement is to encourage customers to purchase or upgrade their irrigation systems with the latest irrigation system technology (e.g. rain sensors and weather-based controllers). Under this rate enhancement, the customer would receive either a discounted rate off of the “standard” rate, or eliminate penalties for any “excess” use. The presumption is that these customers, by using efficient irrigation systems, should meet or exceed their outdoor goal, and on those few occasions when they do not, they should not be penalized since they have made a significant capital investment to attempt to be as efficient as possible. If the city desires to implement this enhancement, then it should be coordinated with any other irrigation conservation program incentives (e.g. rebates) to assure that the rate structure approach enhances any other programs. The final enhancement is a feature that is contained in the city’s current rates; drought surcharges. While this study has not examined drought surcharges, that does not imply that drought surcharges should be eliminated. The focus of this particular study was on rate structures. EES believes that any new rate structures that are adopted by the city should also consider the use of drought surcharges structured similar to the city’s existing approach. 6.13 Summary This section of the report has provided a comprehensive review of each of the rate structures. Each of the rate structures has been developed and evaluated to meet the city’s rate design goals and objectives (attributes). The next section of the report will discuss the peer review. Development and Evaluation of the Rate Structures 6-64  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Section 7 Peer Review of Rate Structures 7.1 Introduction Another aspect of reviewing and evaluating alternative water rate structures for the city was to provide a peer review of the rate structures used at other water utilities. In particular, the city requested a review of other front-range communities’ rate structures. In addition to this peer review, a more detailed review was undertaken of other utilities that currently have, or are in the process of implementing, water budget rate structures. 7.2 Review of Other Front Range Communities When a water utility is setting rates, a common practice is to compare its rates to other surrounding utilities. Typically, the utilities used for comparative purposes should be similar in items such as the number of customers, type of customers, relative size of the water system or other system specific characteristics. The city of Boulder routinely compares its rates to local surrounding water utilities. During this process of reviewing and evaluating rate structures, the city chose sixteen (16) other Front Range communities for comparison purposes. These sixteen (16) communities are provided below in Table 7-1. Table 7-1 Summary of the Front Range Communities ArvadaHighlands Ranch AuroraLafayette Broomfield Longmont Colorado Springs Louisville Denver Water Board Northglenn ErieThornton Fort Collins Town of Superior GreeleyWestminster Provided below in table 7-2 is a summary of the current rate structures for each of the above listed water utilities. Peer Review of Rate Structures 7-1  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Table 7-2 Summary of the Front Range Communities Rate Structures Bill Fixed Number of Annual Utility Frequency Type of Structure ChargesBlocks Bill [2] Classes of Service [1] 1.Boulder Monthly Inverted Block Rate Residential/Irrigation Meter Size 3 $410.94 Commercial 2.Arvada Bi-Monthly Inverted Block Rate Residential Service Charge $284.20 Per Unit 3 Multi-Units Comm./Indust.N/A 3 3.Aurora Monthly Inverted Block N/A Meter Size 3 $461.27 4.Broomfield Monthly Uniform Rate Residential Minimum1 $401.88 Comm./Indust.Meter Size 5.ColoradoMonthly Seasonal/Inverted SF Residential Meter Size 1 – Winter $348.88 SpringsBlock Rate Non-Residential3 – Summer 6.Denver Monthly/ Inverted Block Rate Residential Fixed 3 $235.32 Bi-MonthlyMulti-Family 2 SeasonalAll Other N/A 7.Erie Monthly Inverted Block Rate Residential Meter Size 3 $475.78 Uniform Commercial 1 8.Fort Collins Monthly Inverted Block Rate Residential Fixed 5 $407.29 SeasonalCommercial N/A SeasonalMulti-Family N/A 9.Greeley Monthly Uniform Rate Residential Meter Size 1 $295.80 Commercial 10.HighlandsBi-MonthlyWater Budget Residential Fixed 4 $424.00 RanchMonthlyCommercial Irrigation 11.Lafayette Monthly Inverted Block Rate Single Family Minimum 4 $316.86 Multi-Family 4 Commercial 4 12.Longmont Monthly Inverted Block Rate Residential Meter Size 3 $344.48 Uniform Multi-Family 1 Declining Block Small Comm. 2 Uniform Large Comm. 1 Uniform Irrigation1 13.Louisville Monthly Inverted Block Rate Residential Minimum 5 $262.50 Commercial 5 14.Northglenn Monthly Inverted Block Rate Residential N/A 2 $434.10 Inverted Block Rate Commercial 2 Uniform Rate Irrigation1 15.Thornton Monthly Inverted Block Rate Residential Meter Size 3$394.56 for all customers. Multi Family Meter Size 3 Blocks determined by Commercial Meter Size 3 meter size. IrrigationMeter Size 3 16.Town of Monthly Inverted Block Rate N/A Fixed 3 $429.45 Superior 17.Westminster Monthly Inverted Block Rate Residential. N/A 3 $372.30 Commercial 2 Multi Unit N/A IrrigationN/A Note: [1] If all classes have same rate then this column is not applicable [2] Annual single family residential bill based on annual consumption of 120,000 gallons Peer Review of Rate Structures 7-2  City of Boulder—Volume 1 – Evaluation of Water Rate Structures As shown in Table 7-2, the majority of the Front Range communities have an inverted block rate structure with, on average, three consumption blocks. In addition, there were some communities that had either a uniform rate or seasonal rate structure. However, these structures were not the typical structure seen, or they only applied to specific customer classes of service. These communities also had several customer classes of service typically including residential, commercial, multi-family, and irrigation. The only utility with a water budget rate structure of the surveyed utilities was Highlands Ranch. This particular utility and their specific water budget rate structure is discussed in more detail below. 7.3Water Budget Rate Structure Review Water budgets are relatively new water rate structures that have been implemented in the last several years at a few utilities around the United States. Water budgets typically provide a customer with a goal for efficient use. These usage goals are set for indoor and outdoor water usage based on varying factors, such as the number of occupants residing at the dwelling unit, size of the lot, irrigable area and weather. For this review, the water budget rate structures for Irvine Ranch Water District, Highlands Ranch Water District, Otay Water District, and the City of West Jordan were researched in detail and are discussed below. 7.3.1 Irvine Ranch Overview of the Utility - The Irvine Ranch Water District Irvine Ranch Water District (District) is located in Southern California between Los 15600 Sand Canyon Avenue Irvine, CA 92618 Angeles and San Diego, in Orange County. The District provides water service to the City of Irvine and portions of Mr. Dave Ferguson the surrounding communities. The District implemented (949) 453-5300 this rate structure in the early 90’s during the drought in order to provide customers with an allotment of water based on their perceived needs for indoor and outdoor use. Prior to this rate structure the District had a uniform rate structure, which did not meet the District's goals during the drought period. Overview of the Rate Structure – The water budget rate structure only applies to the District’s residential and irrigation customers, while the commercial customers have a slightly different rate structure. The rates for the commercial class of service are developed by calculating each individual commercial customer’s base water allocation based on their historical use. A com- mercial customer’s rate is then calculated by comparing its current monthly use to its base index for that month. The first block is set at the base index, the second block is 101% - 110% of the base index, the third block is 111% - 120% of the base index, and the final block is all usage over the third block. At this time the District does not differentiate between different types of com- mercial customers or have sub- Table 7-3 categories of commercial custom- Summary of the Commercial Rate Structure ers. All commercial customers are Block Rate/ccf% of Base Index treated as a single class of service. Conservation Base Rate $0.75 0 – 100% A summary of the commercial rate Inefficient 1.50 101 – 110% is provided in Table 7-3. Excessive 3.00 111 – 120% Wasteful 6.00 120% + Peer Review of Rate Structures 7-3  City of Boulder—Volume 1 – Evaluation of Water Rate Structures The rate for the residential customers combines an indoor and outdoor usage goal. These goals are calculated based on an assumed average number of occupants by dwelling unit type, the square footage of the lot, daily weather, and evapotranspiration information for the customer’s area. The customer’s outdoor goal is adjusted on a monthly basis depending on the weather over the last billing period. With this information, customers can adjust their watering patterns based on the current weather information. A summary of the District's residential rate is provided in Table 7-4 Table 7-4 Summary of the Residential Rate Structure Block Rate/ccfIndoor Usage Landscape % of Usage Low Volume Discount $0.59 0-5 ccf 0 – 40% Conservation Base Rate 0.75 6-12 41 – 100% Inefficient 1.50 13-18 101 – 150% Excessive 3.00 19-24 151 – 200% Wasteful 6.00 25 + 201% + The irrigation rates are calculated in the same manner as the residential outdoor goal.It is based on the irrigable area and daily weather conditions and ET. As with the residential customers, as the weather conditions change, so do the block sizes for the outdoor goal. Table 7-5 provides a summary of the potable water irrigation rates. Technical Rate Design Issues - Table 7-5 An integral part in developing a Summary of the Irrigation Rate Structure rate structure is establishing rates Block Rate/ccf% of Base Index based upon cost of service Conservation Base Rate $0.75 0 – 100% principles and information. When Inefficient 1.50 101 – 110% the prices were established for the Excessive 3.00 111 – 120% District's water budget rate Wasteful 6.00 120% + structure, the District did not perform a comprehensive cost of service study to determine the rates for each block. Rather, the District calculated its “melded rate” by dividing it’s water supply costs by total consumption. This provided the pricing for the base rate block of consumption. The pricing for the subsequent blocks was set at a "punitive" level to reduce excess water use. If available, the excess revenue received from the “penalty rates” is used to offset the revenue deficiency from the residential low volume discount rate. From a purely technical rate design perspective, it may be concluded that the District's rates are not cost-based since they are not based upon cost of service principles, and they are not designed to collect a specific target revenue requirement. Implementation Issues - A key issue for the District when implementing the water budget rate structure is the billing system requirements. The District developed its own billing system using proprietary software and its in house computer staff. Another issue facing the District was the education of its customers. However, due to the drought situation at the time, prior information on water conservation, and information on the rate structure change, it was the District’s opinion that once a short education period was over that a majority of its customers understood the rate structure and its goals and adjusted their water usage accordingly. How much of this change in consumption was a function of the drought response versus the use of water budgets is unclear to this day. Peer Review of Rate Structures 7-4  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Conservation - At this time, it is the District’s opinion that customers do adjust their usage based on current weather trends. It is also the District’s opinion that this rate structure has contributed to the increased conservation efforts of its customers. In general terms, the District has seen its average usage per acre-foot for the landscape irrigation class of service decrease by approximately 50% since the implementation of its water budgets. In addition, this rate structure provides the District with an opportunity to assist those customer’s with assumed excess usage. For example, if a customer questions its bill, the District will provide some assistance to those customers with excess water use in determining water saving efforts. Appeals Process – There is a process in place for the District’s customers to appeal their water budget if they feel there is in error in the calculation of their water budget. There are three components used in the calculation of the rate that may be challenged. The first is for the number of people living in the dwelling unit. At this time, the District assumes a typical average occupancy which varies by each type of dwelling unit type (i.e. detached home, attached home, apartment, etc.). The District's customers can then apply for a variance, and with the proper information (i.e. drivers license, birth certificate, tax returns, lease agreements, etc.) the inside water budget may be adjusted. The second variance allowed for adjusting the indoor water budget is for medical purposes. There may be some instances where a medical condition requires that the customer increase their indoor budget. Again, the customer can complete a variance form with the proper information and the indoor budget may be adjusted. The final variance is for the outdoor water budget. Currently, if the customer’s landscape area is different than the assumed average landscaped area, the customer can provide information, such as a sketch or other plans, on their specific landscaped area and the outdoor water budget may be adjusted. At this time these are the only formal variances allowed under this rate structure. Since the rate structure has been implemented the District determined that they have reviewed variances for approximately 20% of its single-family residential customers. 7.3.2 Highlands Ranch Overview of the Utility - The Centennial Water and Sanitation District (Highlands Ranch Water District) is located in Highlands Ranch, a southern suburb of Denver. The District provides water service to the Highlands Ranch area. Prior to May 2003, the District was considering updating its current rate structure. At the same time, the Colorado area was experiencing a severe drought and water budgets appeared to be an equitable method to allocate sufficient water for its customers needs. Overview of the Rate Structure – The water budget rate structure applies to the District’s residential and irrigation customers. The District’s commercial customers rates are based on each individual’s average historical use. This historical Metro Districts of average use then becomes their budget with subsequent Highlands Ranch blocks at 120%, 140%, and over 140% of their budget. At 62 W. Plaza Drive, this time the District does not sub-categorize the commercial Highlands Ranch, CO 80129 customers based upon the end-use of the water. However, Mr. Bruce Lebsack this is a possibility in the future, but with simple sub- Director of Finance and Admin. categories. Table 7-6 provides a summary of the rates that 303-791-0430 apply to all commercial customers. Peer Review of Rate Structures 7-5  City of Boulder—Volume 1 – Evaluation of Water Rate Structures As with most water budgets, the Table 7-6 District’s water budget rate Summary of the Commercial Rate Structure structure includes both an indoor and outdoor goal component. The Usage Rate/1,000 gal. 0 – 100% of Budget $2.00 indoor goal was based on the 101 – 120% of Budget 3.00 average historical consumption for 121 – 140% of Budget 4.50 the residential class of service Over 140% of Budget 6.75 based on a typical household of 3 persons which is approximately 5,500 gallons per month. In order to calculate the outdoor goal, the District based the goal on actual lot size (provided by development plans), average percentage of irrigated area (based on average of 45% of the lot size), irrigation requirements, and historical weather information. At this time the outdoor goal does not adjust based on current weather (ET). Rather it is assumed that under typical conditions the outdoor goal will allow for sufficient watering. A final point on the District’s residential water budget is that they recently made adjustments to the calculations used to determine the outdoor goal. Specifically, the ranges of blocks 2 and 3 were increased to allow for more consumption in those blocks and the prices for the final three blocks were decreased. This was done as the initial rates were set at a higher level due to the drought situation and to draw attention to the fact that excess water use would be at a penalty rate. Provided below in Table 7-7 is a summary of the previous and present residential rate structure. Again, the budget includes the sum of both the indoor and outdoor goals. Table 7-7 Summary of the Residential Rate Structure Previous Rates Present Rates Usage Rate/1,000 gal Usage Rate/1,000 gal 0 – 105% of Budget $2.00 0 – 100% of Budget $2.00 106 – 115% of Budget 4.00 101 – 120% of Budget 3.00 116 – 125% of Budget 8.00 121 – 140% of Budget 4.50 Over 125% of Budget 16.00 Over 140% of Budget 6.75 The irrigation water budget is calculated in a similar manner to the residential water budget. However, for the irrigation customers there obviously is no indoor goal, only an outdoor goal for landscape watering purposes. The outdoor goal is based on the landscaped area, historical weather and irrigation requirements. As with the residential rate, there is no adjustment made for current weather (ET). It is assumed that the current goals will provide sufficient water for irrigation purposes. The rates and block sizes for the irrigation customers are the same as those shown for the residential class of service in Table 7-7. Technical Rate Design Issues – The District’s rates were not established or set based upon a cost of service analysis. Instead the District calculated a base rate based upon the current water supply costs divided by total consumption. The rates were simply increased by 150% for each subsequent block. As this was a new rate structure, it was the District’s opinion that it would not be possible to accurately set the rates in the final blocks since it was not known how much consumption would fall into these blocks. In addition, the District assumed that the rates would Peer Review of Rate Structures 7-6  City of Boulder—Volume 1 – Evaluation of Water Rate Structures be adjusted as lot sizes were adjusted and variances were allowed for the indoor consumption. When setting the size of the blocks, the District reviewed the data on larger irrigable areas and determined that by increasing the water budget by 20%, it would allow for 80% of all consumption to fall in the first two blocks. Again, by adjusting the water budget by an additional 40%, the third block would provide for nearly 100% of the Districts consumption. In this way no customers should have usage in the final block unless they are using excess water, so no customers should be charged the higher final block rate. Implementation Issues – One of the implementation issues the District faced was the capability of its billing system to handle water budgets for each customer. In order to bill its customers under the water budget rate structure, the District had some adjustments made to its current system by computer professionals. Once these adjustments were made, staff entered in the critical data for the calculation of the outdoor goal. One benefit the District has with its billing system is if in the future it determines that monthly or daily adjustments be made of actual ET, the system can handle such an adjustment. The more critical implementation issue was the education of the customers about the change and how the change in the rate structure could affect them. The District did not have access to a local newspaper to provide information to its customers. Instead the District relied on mailers and letters to inform its customers of the change. Because of this communication issue, if a customer did not understand the water budget and had excess usage they received a very large bill based on the District's water budget rates. This accounted for a significant amount of the calls regarding the new rate structure. Appeals Process – The District’s customers can appeal their indoor water budget if they feel that it does not represent their specific needs. The customer may have their indoor goal increased if they have the appropriate information (i.e. tax forms, driver’s license, etc.) available for the number of people living in the home. The District will provide an additional 3,000 gallons per person, bi-monthly, if requested and approved. However, if a customer's indoor water budget is adjusted then the customers sewer budget is also adjusted for the same level of consumption, as it is assumed that the indoor water usage is tied directly to wastewater flows. Currently this is the only formal appeal process available to the District’s customers. However, the District is planning on reviewing the current method of calculating landscape area and customers may be provided a temporary variance if they are using excess water for new landscape or major repairs. 7.3.3 Otay Water District Overview – Otay Water District is located in the San Diego area of Southern California, and implemented water budgets as a result of the drought in the early 1990’s. Since that implementation date, Otay has eliminated their water budgets and reverted back to more traditional inverted Otay Water District 2554 Sweetwater Springs Blvd. block (tiered) rate structures. EES contacted the District 91978-2096 Spring Valley, CA to gain a better understanding of their reasoning for this change. In discussions with the District, EES could not locate anyone within the management of the District that was a part of those discussions and decisions. The District's management team has apparently had significant turnover in the last several years. However, EES was able to discuss the water budget rate structure with a staff member in customer service that was employed by the District at the time the water budget rate structure was implemented. In addition, EES reviewed a Peer Review of Rate Structures 7-7  City of Boulder—Volume 1 – Evaluation of Water Rate Structures document developed by A&N Technical Services, Inc., which discusses landscape water 36 conservation programs in Southern California in 1997, and included a discussion of Otay. Overview of the Rate Structure – In reviewing the A&N Technical Services document it appears that the driving force behind the water budget rate structure was the landscape irrigation customers which were asked to cut back their water consumption during the drought. These customers, other landscaping professionals, and District staff provided the framework for the water budgets that the District developed. The District decided to base its water budgets on historical weather, evapotranspiration rates, and irrigation requirements. In addition, customers that did not consume their entire allotment were allowed to “bank” their water for other months when they may exceed their goal. Another interesting function of the rate was that the customers were given a “grace” period if they were over their allotment. These customers could then have the next month to make up that excess water by consuming less then their goal for the next month. Technical Rate Design Issues – It was the District’s objective to have customers significantly reduce their consumption during the drought. Therefore, the pricing of the water was important. It was assumed that the water budgets would provide a sufficient level of consumption to allow for both indoor and outdoor use. Any use over and above the budget would then be charged at a higher rate, as with most water budget rate structures. However, when determining the rates the District implemented significant “penalty prices” for each subsequent block. The second block was charged 100% of the base rate, the third block was charged 200% of the base rate, the fourth block was charged 400% of the base rate, and the final block was charged at 800% of the base rate. It was assumed that any excess revenues over and above the District’s revenue requirements were to be used to fund conservation programs. Implementation Issues – There were two main issues the District faced when implementing the water budget rate structures. The first was the collection of the irrigable area data for each of the customers. The District sent out a request that customers provide this information. For those customers who did not respond, a default water allocation was provided to them. The more significant issue was the billing system upgrades to allow for water budget billing. In the A&N Technical document, it states that an extensive reprogramming effort of approximately six staff months was undertaken to reprogram the District's billing system as this rate structure had several unique functions such as the banking of water and grace periods for excess use. City of West Jordan Overview of the Utility - The City of West Jordan is located to the South of Salt Lake City, Utah. The City has been City of West Jordan discussing implementing water budgets for the last 2-3 years. 8000 Redwood Road, Most recently the City developed a proposed rate structure West Jordan, UT 84088 and methodology for its water budget rate structure. Tom Steele However, at this time it is important to note that the City has Assistant City Manager not implemented the water budget rate structure, but has 801-569-5000 delivered the proposal to the City Council for their approval. It was the City’s opinion that the implementation of a water  36 Chestnut, Thomas; Pekelny, David, Landscape Water Conservation Programs Evaluation of Water Budget Based Rate Structures, A&N Technical Services, Inc. 1997. Peer Review of Rate Structures 7-8  City of Boulder—Volume 1 – Evaluation of Water Rate Structures budget rate structure would not only promote conservation, but that it provides a fair allotment of water to each of the City’s individual customers. The following brief discussion will provide some of the assumptions the City has used in the development of its water budget rate structures. Overview of the Rate Structure – At this time the proposed water budget rate structure applies only to the residential and landscape irrigation customer classes of service. The current commercial customer’s rate structure depends on if they have a separate irrigation meter for outside usage. If the customer does have an irrigation meter, they are charged a flat rate for all their indoor water consumption. If they do not have an irrigation meter, they are then charged a higher rate for all their water usage. Provided below is a summary of the current rates for the two types of commercial customers. Commercial Customer w/ Landscape Meter All Usage $0.85/1,000 gal Commercial Customer w/o Landscape Meter All Usage $1.05/1,000 gal In addition to the consumption rate, the commercial rate includes a monthly water availability charge. At this time the City does not differentiate between the commercial customers based on the end use of the water consumption (e.g. grocery stores, restaurants, etc.). As with most residential water budget rate structures, the city's proposed structure includes both an indoor and outdoor goal. The development of the indoor goal included reviewing average historical usage patterns for the residential customers and then comparing that to an assumed usage per household occupant. The proposed structure was based on a typical household of 4. The outdoor goal was based on irrigation needs, average lot size and historical evapotranspiration (ET) data. It should be noted that the proposed rate does not base each customer’s outdoor goal on the exact square footage of landscaped area. The City determined that at this time the best method was to take a sampling of the residential customers to determine the typical landscaped portion of the lot and apply that percentage to all customers. It was also determined that there would not be any adjustments for actual weather, which could influence or change the size of the outdoor goal. The proposed irrigation rate structure was calculated similar to the residential customers except there is no indoor component. The landscape irrigation structure is calculated in the same manner as the outdoor goal for the residential customers. It is based on irrigation requirements, landscaped area, and historical evapotranspiration data. In developing the proposed water budget rate structure, it was the City’s intent to start with broader goals and then as they moved forward they could refine the data and goals to further represent the actual needs of its customers. Technical Rate Design Issues – One of the key issues of this rate structure is the pricing of the consumption blocks. When setting the proposed prices for the indoor and outdoor goals, the City started at the current consumption rate for the first block and then adjusted the following blocks to impose “penalty rates” on those customers with excessive usage. These rates where incrementally increased as a customer moved through the blocks of the rate structure. It was the opinion of the City that the revenue received from these “penalty rates” that was over and above Peer Review of Rate Structures 7-9  City of Boulder—Volume 1 – Evaluation of Water Rate Structures current operating expenses would then be used to fund future conservation programs. These conservation programs could be for xeriscaping, low-flow products, etc. Implementation Issues – One of the bigger challenges facing the City when proposing this rate structure was the constraints it put on the billing system. The City did utilize it’s current billing system but did have outside computer professionals update and rewrite programs for the current system. At this time, with the proposed rate structure, there should not be a need for additional updates. However, that is why the City chose a “simple” water budget structure that did not take into account the actual square footage by lot size and monthly or daily adjustments for actual ET. If they had, they would have had to make additional changes to the billing system. One of the other issues facing the City staff was the “selling” of the concept to its customers. At this time, the City is planning on holding future public meetings to gauge public opinion on this type of water rate structure. Appeals Process – At this time the City has not determined a method for an appeals process for the indoor and outdoor goals. It is assumed that at some point, this process will be in place for some of the variables in this rate structure.  7.4Summary This section of the report has provided a comparison of the rate structures from other front-range communities. In addition, this section has provided a brief summary of water budgets from other water utilities that have implemented this type of rate structure. The next section of this report will discuss the conclusions and recommendations from this comprehensive rate structure review and evaluation. Peer Review of Rate Structures 7-10  City of Boulder—Volume 1 – Evaluation of Water Rate Structures Section 8 Rate Structure Conclusions and Recommendations 8.1 Introduction This study has provided a comprehensive review of the water rate structures currently under consideration by the city. As a part of this comprehensive review, the goals and objectives of the city were reviewed and prioritized. In addition, twenty-two rate structures were considered for further review and analysis, and in the end, six rate structures were reviewed for single-family residential customers, three rate structures were reviewed for multi-family, two rate structures were reviewed for commercial/large user, and finally, three rate structures were reviewed for metered irrigation. This section of the report will provide a summary of findings, conclusions, and recommendations as they relate to the rate structures reviewed. 8.2 Single-Family Residential Rate Structures Recommendations Six different rate structures were reviewed for the single-family residential class of service. In summary form, these six rate structures were as follows: S-FRRS1 – Seasonally Differentiated Rate INGLEAMILY ESIDENTIAL ATETRUCTURE Structure With A 2-Block Winter Rate And A 3-Block Summer Rate. S-FRRS2 – Water Budget With Four (4) INGLEAMILY ESIDENTIAL ATETRUCTURE Consumption Blocks. Block 1 Is Fixed For Indoor Use, Block 2 Is Based Upon The Irrigation Requirements Of A 9,000 Square Foot Lot Size, Block 3 Uses 150% Of Block 2 To Determine Size, And Block 4 Is All Usage Over Block 3. S-FRRS3 – Water Budget With Four (4) INGLEAMILY ESIDENTIAL ATETRUCTURE Consumption Blocks. Block 1 Is Fixed For Indoor Use, Block 2 Uses Three Different “Bins” to Determine Irrigation Requirements, Block 3 Uses 125% Of Block 2 To Determine Size, And Block 4 Is All Usage Over Block 3. S-FRRS4 – Water Budget With Five (5) INGLEAMILY ESIDENTIAL ATETRUCTURE Consumption Blocks. Block 1 Is Fixed For Indoor Use, Block 2 Is Based Tax Assessed Lot Size, Block 3 Is 125% Of Block 2, Block 4 Is 150% Of Block 2, And Block 5 Is All Usage Over Block 4. Rate Structure Conclusions and Recommendations 8-1  City of Boulder—Volume 1 – Evaluation of Water Rate Structures S-FRRS5 – Water budget with Four (4) INGLEAMILY ESIDENTIAL ATETRUCTURE Consumption Blocks. Block 1 is Fixed For Indoor Use, Block 2 is Based Upon Either a Customer Provided Irrigable Size, or a Default of 5,200 square Feet of Irrigable Area. Succeeding Blocks Based Upon Relationship to Block 2. S-FRRS6 – Existing City Rate Structure Modified INGLEAMILY ESIDENTIAL ATE TRUCTURE To Reflect Current City Goals. In reviewing each of the rate structures, EES has concluded the following: C–S-FRRS1 – This rate structure ONCLUSIONS INGLEAMILY ESIDENTIAL ATETRUCTURE nd combines seasonal price signals with a summer 2 block size that relates well to a typical single-family customer irrigation requirements (i.e. lot size). From the customer’s perspective, this rate structure should be easy to understand, and from the city’s perspective easy to administer. EES considers this rate structure to be a viable alternative for the city. C–S-FRRS2 – This rate structure is ONCLUSIONS INGLEAMILYESIDENTIAL ATE TRUCTURE nd in many respects similar to the first rate structure, but does contain some differences. The 2 block of the structure is based upon a standard lot size which is an administrative strength from the city’s perspective. However, the use of a standard lot size may also be a weakness since it does not reflect the individual customer irrigation requirements (i.e. lot sizes/irrigable area). The water allocation is shaped for each month, which better reflects the irrigation requirements in that particular month, but at the same time, adds a level of complexity to the rate structure that may be confusing to some customers. EES considers this rate structure to be a viable alternative for the city. C–S-FRRS3 – This particular rate ONCLUSIONS INGLEAMILY ESIDENTIAL ATE TRUCTURE structure uses “bins” to help eliminate the issue of customers with differing lot sizes and irrigation requirements. In the end, EES believes that the use of bins, at least as conceptualized within this study, is not an appropriate approach since it does not gradually rd increase water allocation as lot sizes increase in size. In addition, the use of 125% as the 3 block size appeared to be too small. EES would not consider this rate structure to be a viable alternative for the city, and would eliminate it from further consideration. C–S-FRRS4 – This particular rate ONCLUSIONS INGLEAMILY ESIDENTIAL ATE TRUCTURE nd structure uses tax assessed lot size to determine irrigable area and water allocation for the 2 block. This rate structure has addressed the concerns raised in the previous rate structure. nd That is, the allocation of the 2 block water is proportional to lot size. The major administrative issue associated with this rate structure is determining and verifying the lot size for each account. The use of 5 blocks within the rate adds some complexity to the rate structure, but the major complexity to the structure is the shaping of the water allotment from month to month. The final issue may be the customer perception of equity as it relates to the nd allocation of 2 block water. EES considers this rate structure to be a viable alternative for the city. C–S-FRRS5 – The major concern ONCLUSIONS INGLEAMILY ESIDENTIAL ATE TRUCTURE raised by this rate structure is simply the concept of the customer provided irrigable area. Administratively, the city should not place itself in a situation where it would need to measure irrigable area, as opposed to total lot size. At the same time, this rate structure Rate Structure Conclusions and Recommendations 8-2  City of Boulder—Volume 1 – Evaluation of Water Rate Structures creates a situation where there is a perverse incentive for the customer to report a larger irrigable area than they actually have. Given these concerns, EES would not consider this rate structure to be a viable alternative for the city, and would eliminate it from further consideration. C–S-FRRS6 – This rate structure is ONCLUSIONS INGLEAMILYESIDENTIAL ATE TRUCTURE a variation of the city’s existing rate structure. It is a three-block rate structure, using AWC nd to establish the first block size. However, in this particular case, the 2 block has been established and fixed based upon the standard lot size irrigation requirements. One of the concerns regarding the city’s existing rate structure was that it created a perverse incentive nd for customers to artificially increase their AWC, in order to increase their 2 block allocation. This modified rate structure has eliminated this concern. EES considers this rate structure to be a viable alternative for the city. In summary, EES believes that there are four single-family rate structures available to the city that would meet the city’s overall objectives. In our opinion, rate structure 2, while a viable water budget alternative, is not as well conceived as water budget rate structure 4. Therefore, that leaves single-family rate structures 1, 4 and 6 as viable alternatives for the city. 8.3 Multi-Family Residential Rate Structures Recommendations Three different rate structures were reviewed for the multi-family residential class of service. In summary form, these three rate structures were as follows: M-FRRS1 – Seasonally Differentiated Rate ULTIAMILY ESIDENTIAL ATETRUCTURE Structure with a 2-Block Winter Rate and a 3-Block Summer Rate. M-FRRS2 – Water Budget With Six (6) ULTIAMILY ESIDENTIAL ATETRUCTURE Consumption Blocks. Blocks 1 and 2 Are Fixed Per Unit Thresholds, Block 3 Is Based On The Customer Specific Irrigable Area, and Succeeding Blocks Based Upon Relationship To Outdoor Goal (Block 3). M-FRRS3 – Water Budget With Five (5) ULTIAMILY ESIDENTIAL ATETRUCTURE Consumption Blocks. Blocks 1 and 2 Are Fixed Per Unit Thresholds, Block 3 Is Based On The Customer Specific Irrigable Area, and Succeeding Blocks Based Upon Relationship To Outdoor Goal (Block 3). In reviewing each of the rate structures, EES has concluded the following : C–M-FRRS1 – This rate structure has ONCLUSIONS ULTIAMILYESIDENTIAL ATE TRUCTURE seasonal price signals, but does not attempt to provide customers with an allocation of water for rd outdoor water requirements. While it does have a 3 block for the summer period to capture outdoor irrigation use and excessive indoor use, it does not contain an excess use penalty for outdoor use. EES does consider this rate structure to be a viable alternative for the city. Rate Structure Conclusions and Recommendations 8-3  City of Boulder—Volume 1 – Evaluation of Water Rate Structures C–M-FRRS2 – This rate structure is a ONCLUSIONS ULTIAMILYESIDENTIAL ATE TRUCTURE water budget rate structure and the third block is based upon the customer specific irrigable area. The use of irrigable area creates a direct relationship between the third block and the customer’s irrigation requirements. One aspect of this particular rate structure that is somewhat detracting is the use of six blocks. If desired, this rate structure could be simplified to five blocks (i.e. combine block 4 and 5 to 100% - 150%). In developing water budgets for the city, EES noted that the water budget rate structure was more difficult to develop for this class of service than the single-family residential customers. This is primarily a function of two issues; metered irrigation customers and individual vs. master metering. As noted previously, some multi-family customers have metered irrigation and some do not. As a result, developing a block of water for irrigable use for customers that are metered irrigation customers does not appear to be logical. At the same time, for those customers that may live in a multi-family complex, but be individually metered, the issue of how to establish the irrigable block must be resolved. While these technical issues can be resolved, they do point out that water budgets may “fit” certain classes of customers and situations better than others. However, EES does consider this rate structure to be a viable alternative. C–M-FRRS3 – This rate structure is a ONCLUSIONS ULTIAMILYESIDENTIAL ATE TRUCTURE water budget rate structure and is very similar to the prior rate structure. However, this option has only five block and sets the “excessive” use block at 125% of the outdoor goal. While this rate structure has addressed one of the concerns raised with the previous option, the use of six blocks, this rate structure has potentially raised a new issue. The use of 125% as the “excess” use threshold may be set too low. Our preference would be at 150%, which would then tie to the excess use threshold for single-family option 4. EES would consider this rate structure to be a viable alternative. In summary, EES believes that all three options are viable for the city to utilize. Of the three options, we believe that option 2, because of the use of six blocks may be the least desirable of the two water budget alternatives. EES would recommend that the city consider multi-family residential rate structure options 1 and 3 as viable options for the city. 8.4 Commercial/Large User Rate Structures Recommendations Three different rate structures were reviewed for the commercial/large user class of service. In summary form, these three rate structures were as follows: C/LURS1 – Seasonally Differentiated Rate Structure OMMERCIALARGE SERATETRUCTURE With A 2-Block Winter Rate And A 2-Block Summer Rate. Block 1 set at 100% of Average Monthly Consumption. C/URS2 – Seasonally Differentiated Rate Structure OMMERCIALLARGE SERATETRUCTURE With A 2-Block Winter Rate And A 2-Block Summer Rate. Block 1 set at 90% of Average Monthly Consumption. Rate Structure Conclusions and Recommendations 8-4  City of Boulder—Volume 1 – Evaluation of Water Rate Structures C/URS3 – Non-Seasonal Rate Structure With Two OMMERCIALLARGE SERATETRUCTURE Blocks. The First Block Size Is Based Upon the Customer Meter Size, and the Average Monthly Use of the Customers With That Same Meter Size. In reviewing each of the rate structures, EES has concluded the following: C-C/LURS1 – This rate structure uses a ONCLUSIONS OMMERCIALARGE SERATETRUCTURE seasonal pricing approach. In establishing the first block of consumption, an average monthly use approach is utilized. It can be perceived that this alternative does not send a strong incentive for indoor or outdoor efficiency. However, approximately 50% of customers within this class of service have metered irrigation, which mitigates somewhat the importance and need for a block of water based upon irrigable requirements. For those customers that will have outdoor irrigation requirements, this consumption will be priced at a level that is slightly higher, on a per unit basis, than that charged to single-family for their water allotment and consumption up to 125% over their outdoor watering goal. The price for the single-family option 4, for the 100% - nd 125% block, is $3.25/1,000 gallons. For the commercial/large user customers, the 2 block summer price is $3.30/1,000 gallons. Therefore, the price being charged for outdoor irrigation seems fair, relative to single-family. The key issue may be the lack of an “excessive” use rate in the summer period. The final issue associated with this rate is the concern that this rate structure may not encourage efficient indoor use. EES concurs that this may be a concern, and the next alternative for this rate structure has attempted to address this concern. However, EES considers this rate structure to be a viable alternative. C-C/LURS2 – This alternative sets the first ONCLUSIONS OMMERCIALARGE SER ATE TRUCTURE block at 90% of the customer’s average monthly use. By setting the first block below the customer’s average monthly use, it should provide some incentive for the customer to improve their indoor efficiency. The other components of the rate structure are similar to the conclusions noted above for the previous commercial/large user rate structure. EES considers this rate structure to be a viable alternative. C-C/LURS3 – This particular rate ONCLUSIONS OMMERCIALARGESER ATETRUCTURE structure uses an approach that is different from the previous two options and the city’s current approach. Under this rate structure, the first block is established based upon the average use of all commercial customers with the same meter size. Technically, what this does is place roughly half the consumption in the first block and the remaining consumption in the succeeding block. By doing so, a significant number of customers (roughly half of the total) will have more consumption billed in the higher priced succeeding block. This results in larger rate/financial impacts to these customers. While the goal of this rate design is to encourage more efficiency from commercial customers, it may do so in a manner that has unintended consequences. That is, customers that are already efficient in their use may, by the very nature of their business, use a higher than average amount of water. This customer would be penalized simply because their usage was higher than the “groups” average use. Higher than average use does not necessarily imply inefficient use. Therefore, we believe that care must be taken in viewing this alternative and its attributes considered carefully. Even with those concerns, this is still a viable rate structure alternative for the commercial customers. Rate Structure Conclusions and Recommendations 8-5  City of Boulder—Volume 1 – Evaluation of Water Rate Structures In summary, EES believes that all of the commercial/large user rate structures are viable options for the city to utilize. Of the first two options, EES is of the opinion that the second option, which uses 90% of the average monthly use to establish the first block size is an improvement and benefit when compared to the first rate structure. The third option is a viable alternative, but care must be taken in the implementation process to assure that the rate/financial impacts to specific customers is not overly large. 8.5 Metered Irrigation Rate Structures Recommendations Three different rate structures were reviewed for the metered irrigation class of service. In summary form, these three rate structures were as follows: MIRS1 – Uniform Rate. ETERED RRIGATION ATETRUCTURE MIRS2 – Water budget with Three (3) Consumption ETERED RRIGATION ATETRUCTURE Blocks. Block 1 is Based Upon Customer Specific Irrigable Area, Succeeding Blocks are Based Upon Relationship To Outdoor Goal (Block 1). MIRS3 – Inverted block rate with Three (3) ETERED RRIGATION ATETRUCTURE Consumption Blocks. Block 1 is Based Upon 90% of the Customer’s Average Summer Consumption (ASC), Succeeding Blocks are Based Upon Relationship To Outdoor Goal (Block 1). In reviewing each of the rate structures, EES has concluded the following: C-MIRS1 – This rate structure is a uniform ONCLUSIONS ETERED RRIGATION ATETRUCTURE rate structure. While it has certain advantages related to the administration of the rate, it may not meet the city’s objectives for encouraging efficient use. At the same time, this rate structure does not have a block for “excessive” use. EES would not consider this rate structure to be a viable alternative at this time based on the cities current goals and objectives. C-MIRS2 – The second metered irrigation ONCLUSIONS ETERED RRIGATION ATETRUCTURE rate is a water budget rate structure. As such, the first block is based upon the irrigable area of the customer, and succeeding blocks are established in relation to the first block. This is the only metered irrigation rate structure that has a shaped approach for ET. This tailoring of the first block is a distinct and significant advantage for this rate. While it will require the city to determine/measure the customer’s irrigable area, it does provide a direct relationship between the water allocated within the first block and the customer’s irrigation needs. EES considers this rate structure to be a viable alternative. C-MIRS3 – The third rate structure uses a ONCLUSIONS ETERED RRIGATION ATETRUCTURE different approach to establish the initial block size for each customer. It is based upon 90% of the customer’s average (monthly) summer consumption (ASC). Compared to the previous metered irrigation rate structure, this method is not as technically correct a method to establish the first block size. However, there is an assumed trade-off between measuring irrigable area and the establishment of this rate. In this “trade-off” may be the perception that this rate structure does not encourage efficient use. At the same time, the irrigation block is not shaped Rate Structure Conclusions and Recommendations 8-6  City of Boulder—Volume 1 – Evaluation of Water Rate Structures for this rate structure. While the sizing of the blocks is important, the other component that must be considered is the pricing. The pricing should encourage efficient use, regardless of the method used to establish block sizes. It should be noted that the second block under this rate structure is $0.50/1,000 greater than the previous rate structure. This price difference may be sufficient to encourage efficient use. EES considers this rate structure to be a viable alternative. In summary, the first rate structure appears to be too simple and lacks the incentives for efficient use that the city seems to be focusing on within this study. Of the remaining two options, the second rate structure, which used measured irrigable area, seems to be the best choice. Water budgets are ideal for this type of customer. While the third option is, in our opinion, a viable option, it is simply a default should the city not decide to implement a water budget rate structure for this particular class of service. 8.6 Summary This section of the report has provided a summary of the rate structure options developed for each class of service. This section of the report is culmination of many months of extensive policy discussion, data analysis, and meetings with the Water Resources Advisory Board. The recommendations contained herein represent the professional and technical opinions of EES. Rate Structure Conclusions and Recommendations 8-7  City of Boulder—Volume 1 – Evaluation of Water Rate Structures