7 - Notes to City Council from WRAB on Water BudgetsDiscussion from WRAB for Council Study Session on Water Budget DraR: September 21, 2007
Notes to City Council from WRAB on Water Budgets
(For WRAB/Council study session)
General Comments
Boulder's water budget rate shuctur~ was created in response to the drought and water
resh-ictions experienced in 2002/2003. As you remember, it was generally believed that
Boulder's water rights were so senior, and the water supply system was so robust that the
city really did not have to worry about shortages. In 2002, we were reminded that we are
not immune from droughts by the fact that there was essentially no snow pack remaining
at the end of May, which resulted in the Boulder Creek watershed reservoirs not filling.
At the same time there was a decreased allocation in the ColoradoBig Thompson project,
which reduced the yield to the Boulder Reservoir system. This was a very serious
situation, and it caught the city off-guard.
In response to the 2002 drought a series of water restrictions were put into place that
focused almost exclusively on irrigation use. These mandated very limited watering
times and schedules for all irrigation, and resulted in some significant degradation of
landscapes and the loss of mature trees, which effects aze still being seen.
The water budget system was an attempt on the part of WRAB and the citizens to design
a more flexible and fair drought response system. IYs main goals were:
• To establish reasonable allocations of water (i.e. Water Budgets) for each
customer based on their actual characteristics and needs.
• To define a rate structure that chazges all customers at the same rate as long as
they stay within their budgets. This rate was to be based on the actual revenue
requirements of the city from water sales.
• To chazge for water use in excess of the budgets at mazginal and then penalty
rates so that all customers will have an economic incentive to conserve.
• To integrate the water rate structure into overall water management for drought
response and emergency situations that require curtailment of water use, but to
give customers the maacimum flexibility in how they choose to use their
allocations of water.
• To use the water billing system, rather than security patrols, to identify customers
that aze exceeding their water budgets so that they can be contacted and offered
assistance.
There was much discussion about the details of the system, but the WRAB believed that
the details of how the ordinance was to be addressed should be left as flexible as possible.
The code authorization for the charges is given in chapter 4-20(b) which describes the
water budget rate structure.
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Discusswn finm WRAB for Council SNdy Session on Water Budget Draft: Sep[ember 21, 2007
From the ordinance chapter 4-20 (b)
"...The rate structure provides an individualized water budget to each customer that is
expected to meet the customer's specif:c water needs... "
"...'Monthly water budget' means the amount of water allocated to the water utility
customers to meet their anticipated watering needs.for the month... "
"... based on reasonable and necessary indoor and/or outdoor use... "
From the rules...
6. Water Budget Adjustments
"Water budget adjustments may be granted by the ciry manager ...The city manager may
consider the following,..
• Number of people in household...
• Irrigable area...
• Irrigable area ofpublic right-of-way...
• Average monthly use (commercial and industrial accounts only).
• Other... "
This is a five block water rate structure. The intention of the WRAB was that the average
rates for blocks 1 and 2 would be based on the actual cost of service for water use in
Boulder; block 3 was to be based on the marginal cost of new water; blocks 4 and 5 were
to be based on penalty charges for excessive (wasteful) use of water.
Even though the staff was not initially in support of the water budget rate structure they
have moved fonvard to implement the system based on council's direction. The main
work that needed to be done was the development of individual budgets for each
residential and irrigation account. (There aze 26,400 of these accounts). Since the system
was first put into practice in January of 2007 only a few individuals have come to the
boazd with complaints, but these have been vocal. We ]rnow that staff has received some
complaints and have asked for a summary of their number and nature. We hope that
council will direct staff to make the necessary changes to the rules in order to address
them.
Current Issues
There are just a few current issues that need attention:
• Conecting errors for CI (commercial & industrial) customers with one meter
serving inside and outside uses.
• Clarifying the authority of the Manager to malce water budget adjustments
• Including irrigated right of way areas
• Refining how mulri-family budgets are determined
• Making retroactive adjustment for erroneous bills
• Determining the capabilities of the billing system
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Discussion from WRAB for ( ouncil Study Session on Water E3udget Draft: September 2l, 2007
In general, we believe that the system has been very successful. There are several ways
to gage this. First, if you look at the actual volumes of water used by each category of
customer within the five blocks, shown in Figure 1, you will see that the vast majority of
use has been within blocks 1 and 2, and that the amount of consumption in the upper
three tiers has been relatively small. The amount in the top two, penalty, tiers has been
relatively small compared to total deliveries. The exception to this is with the imgation
accounts, which have used over 48,000 kgal out 244,000 kgal (~20%) in blocks 4 and 5.
Figure 2 shows the percent of water delivered to each customer category that was billed
in each block. This shows that the only 5% or less of the water delivered to the 5F, MF
and CI categories was in blocks 4 and 5. It also shows that as early as the end of July, 20
% of the irrigation account water was being used in block 4 and 5. This information tells
that the irrigation accounts are the ones that need the early attention. Revenue from sales
in blocks 4 and 5 could be used to support additional imgation auditors to assist
customers in these blocks, and to verify that the irrigation budgets have been properly
established.
Volume by Block and Category (KGAL)
(Jan,luly 2007)
Y
O
m
C
J
a
c~
Y
uvu,uuu
900,000
800,000
700,000
6~~0~0
5~~,000
aoo,ooo
300,000
zoo,ooa
--
ioo,ooo -
SF MF CI Irri
-
^ Bik 1 895,298 482,295 488,976 121.545
^ Blk 2 152,299 128,2D8 200,076 44,450
^BIk3 55,126 41,758 68,579 30,229
^ Blk 4 12.588 10,648 20,678 14,563
^ Blk 5 13,348 10,994 26,889 33,551
Figure 1: Cumulative water use Jan-June by category and block
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Discussion from W RAE3 R~r Council Study Session on Water f3udget [haft: September Z l, 2007
~o of Consumption 6y Block and Category
(Jan~luly 2007)
Figure 2: Percent of water by block to each category,
Another way of gauging the success of the system is from the revenue and water
production data. Through the end of July a total of $9.8 million of revenue has been
generated from water sales. According to the 2007 water utility fund budget, the
projected revenue from water sales was $19 million for the year. So, it appears that
revenues for the first 7 months of the year may be slightly behind the annual projection,
but not to an alarming degree.
From WRAB's perspective we have not had any single family or imgation customers
come to the board to complain about the system. We have, however had complaints from
the commercial/institutional and multi-family groups that we believe should be
addressed.
Complaints from CI (commercial & industrial) Customers
The commercial customers who have complained have been those who have one meter
for both indoor and imgation use. The problem here is that instead of determining their
budgets as the total of the indoor and outdoor use (as is done for the residential
customers, and as required by the ordinance) the budgets were determined as the total
annual use divided by 12, and this average was used for each month of the year. It is
virtually impossible for any customer with a significant amount of irrigation use to stay
within an average monthly budget determined in this manner.
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Discussion from W RAB for Council Study Session on Watcr Budgel Dratt: September 21, 2007
Figure 3 shows data for a small commercial account for the January through September
bills. Even though this customer has used less than the annual budget for the year, during
July and September it was necessary to exceed the budget in order to maintain the
landscape. The August and September bills included water use in Block 5, at $12.10/kgal.
There is no cost justification for these charges, and they are not appropriate for non-
wasteful use.
14000
12000
10000
m
°~ 8000
m
H
~
~
~: 6000
R
~
4000
2000
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Figure 3: Example of a problem CI budget when irrigation is involved
^ Budget
^ A~ctUal
While this is not a large problem for the system as a whole, as shown in Figure 1, it is a
real problem for the CI customers who have a single meter for inside/outside use, and
also a significant amount of irrigated area. Many of these are small, former residential
properties that have been converted to CI use. However, this also includes most school
district property. The City has offered the option of waiving inspection fees for new
meter installation so that they can have irrigation meters. However, inspection fees
represent only a small portion of the cost for excavation, pavement repair and plumbing
to install a separate irrigation line and meter, and WRA_B believes it is not reasonable to
expect small CI customers with single indoor/outdoor meters to go to the expense of
installing a new meter and irrigation line in order to obtain a reasonable water budget.
When the water budgets were set, there was a long discussion about how to deal with
water budgets for commercial customers. The concept of simply dividing the total annual
use by 12 was agreed to in the end, but in WRAB's opinion this was supposed to be used
for indoor uses, not outdoor uses. The discussion memo that went to council describing
the system was not absolutely clear on this point, and said that the commercial budgets
are to be calculated as the annual consumption divided by 12. The need for an irrigation
budget shaped to ET is such an obvious need we believe customers with combined meters
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Discussion from WRAB for Council Study Session on Water Budget Draft: September 21, 2007
should have been able to receive a water budget amendment from the City Manager. We
have had two meetings with the manager about this, but this still needs direction from
council.
WE believe that commercial customers with combined meters need to be able to use the
same approach used by single family residential customers in setting their water budgets.
Instead of getting an indoor allocation of 7 kgal/month, however, the CI customers would
get their annual indoor use (determined from their average winter consumption) divided
by 12 for the indoor component of their budget, and the outdoor budget would be based
on their irrigated area-as is done for single family customers. This would eliminate the
CI prohlem.
Authority of the Manager to Make Water Budget Adjustments
There are several default values used for setting budgets that were recognized to be
variables. These include the number or residents, irrigated area, presence of a pool or
garden, type of business, process uses present, etc. Instead of trying to anticipate each of
these the decision was made to allow customers to have the right to obtain adjustments
based on their special circumstances. That is why an adjustment process was written into
the description. The adjustment process is clear: any budget may be adjusted by staff to
accommodate large families, special health requirements, and other unforeseen
circumstances. Outdoor budgets may be adjusted to accommodate errors in the
calculation of property size or adjusted area.
We believe that the problems of the CI customers should have been dealt with as budget
adjustments the same way that customers with special health needs may obtain an
adjustment without going to city council. In effect the adjustment would be based on the
fact that the original budget assumed the wrong irrigated area-zero. The actual irrigated
area would be used to determine the budget. Note that the details of setting the budgets
are not written into the ordinance, but are included only in the rules.
It will help if Council could reaffirm the importance of granting adjustments in a timely
basis in order to arrive a accurate water budgets.
Irrigated Rights-of-Way
In many cases customers are responsible for maintenance of irrigated rights-of-way, but
their water budgets did not include these areas. While the rules clearly state that
irrigation of right-of-way is a basis for obtaining an adjustment, we understand that the
process has been slow. The main reason for this is that the city wants to check every
adjustment against its GIS data, which requires a lot of time. We suggest that a simpler
way is to accept the information submitted by the customer, subject to later review by the
City. This would eliminate the delay but still assure that errors would be found.
Customers who hire a competent engineer, architect or irrigation technician to make the
determination will be unlikely to submit erroneous data since these professionals will not
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Diswssion Gom WRAB for Council Study Session on Wa[er Budget DraR: Sep[ember 21, 2007
want to submit work with errors over their signatures. Customers who do the work
themselves will lrnow that they will be checked.
We also recommend that the City continue its efforts to reach out to notify customers that
they should check to be sure that their budgets include any irrigated right-of-ways.
Complaints from Multi-family Customers
We have had complaints that the 4000 gal per month per unit budget for multi-family
accounts was insufficient. While we do not doubt that there may be some multi-family
accounts that need adjustment the fact that 88% of all water delivered to the multi-family
category has been in blocks 1 and 2, and only 5% has been in blocks 4 and 5 is strong
evidence that there is no real systematic problem. We recommend that these problems be
dealt with as adjustments based on whatever data is necessary.
Making Retroactive Bill Adjustments
If customers have been given incorrect budgets (and, as a result have been impmperly
forced into higher blocks), we believe it is only fair that the full amount of their over-
payments be refunded to them at the time that the matter is resolved.
Capabilities of t6e Billing System
The billing system software was totally revised to accommodate the new water rate
structure. We were assured that it would be able to accommodate any type of customized
water budgets that were deemed most appropriate for each customer. When we asked
about this in relation to making adjustments to the CI customers we were told that to do
so would require a significant amount of programming effort by consultants. Since this is
a fairly minor change we were taken back by the news and question whettter the billing
software has successfully included sufficient flexibility to meet the changing needs of the
system. For example, if the system rigidly allows only one method of determining water
budgets for CI customers (annual use/12) it could never accommodate any adjustments.
At the minimum it should be possible to manually enter a table of 12 monthly budgets for
any customer based on special circumstances. This should be a minor problem, and
council needs to investigate why the system is stumbling over it.
Summary
In summary, we believe that the water budget rate structure represents the first real
innovation in water rates since the invention of the water meter. Our experience is that
the vast majority of customers like it, and we have received very few complaints. The
information that the billing system now generates can actually be used to determine
which customers are wasting water. In the future, as more accurate budgets are
developed these capabilities will increase. In drought times the water budget system will
provide the city with a fast, reliable way to accomplish specific needed emergency
conservation, while providing maximum flexibility for customers. Water budgets can be
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Discussion from WRAB for Council SNdy Session on Wa[er Budge[ Dra& September 21, 2007
used to encourage customers to implement permanent water conservation measures by
offering the discounts in the conservation block (block 1). These long term water savings
can be used to reduce the impact of future droughts.
Based on the information we have reviewed, we believe the following conclusions can be
drawn:
• The City Manager should provide water budgets to CI customers with single
inside/outside meters that include irrigation allocations determined in the same
manner as is used for single family accounts.
• The city manager should be given discretion to make water budget adjushnents
based on the special circumstances of each customer as long as the resulting
budget complies with the overall goal of reasonable water use without waste.
• The adjustment process could be expedited by accepting data provided by
customers for immediate action, subject to review and verification by staff. This
should include azea adjustments for irrigated rights of way.
• It would be beneficial to continue the public education efforts to inform customers
of the availability of the adjushnent process.
• It is important to obtain the best available data on water demands so that
appropriate adjushnents (both upwazd and downwazd) can be made to reflect new
technologies and encourage their adoption.
• All billing enors need to be adjusted retroactively.
• The actual capabilities of the billing system aze uncleaz, and it is not clear if it has
met its original specification.
• The water budget rate structure needs to be integrated into the overall water
resource and drought contingency planning by the city
Thank you for taking the time to consider our thoughts on this important matter.
Prepared by Jim Knopf (Chair) and Bill DeOreo, as requested by WRAB at the August
WRAB monthly meeting.
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