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HomeMy WebLinkAboutVII (A) First Reading of Ordinance No. 97-33, relating to the schedule of monthly charges for water services Agenda 11-18-97 \ Ocoee Item VII A 4 q o r��•s° a JAMES W. SHIRA, P.E. CrrY ENGINEER/UTILITIES DIRECTOR ISO N.LAKESHORE DRIVE•OCOEE.FLORIDA 34761 PHONE(407)656-2322 EXT. 142•FAX(407)656-7835 MEMORANDUM DATE: November 14, 1997 TO: The Honorable Mayor and Board of City Commissioners FROM: James W. Shira. P.E. City Engincer/Utiliti Director SUBJECT: Proposed Water Rate Change Attached for your review is a proposed ordinance establishing a revised rate schedule for water and wastewater service in the City of Ocoee. As mandated by the St. John's River Water Management District, we prepared this proposed rate schedule to encourage conservation of potable water resources. The narrative in the attached study report prepared by Professional Engineering Consultants, Inc. explains the method used to arrive at the various rate components. This is presented at the November 18, 1997 City Commission meeting for first reading with an anticipated second reading and adoption at the December 2, 1997 meeting. Mr. Ken Hooper and I will both be present at the December 2n4 meeting to answer any questions you may have regarding this proposed rate restructuring. J W S/jbw Attachment THE PRIDE OF WEST ORANGE ORDINANCE NO. 97- 33 AN ORDINANCE OF THE CITY OF OCOEE, FLORIDA RELATING TO THE SCHEDULE OF MONTHLY CHARGES FOR WATER SERVICES; AMENDING SECTION 173-4 .A OF CHAPTER 173 OF THE CODE OF ORDINANCES OF THE CITY OF OCOEE WITH RESPECT TO THE MONTHLY CHARGES FOR WATER SERVICE; PROVIDING FOR SEVERABILITY; PROVIDING FOR CODIFICATION; PROVIDING AN EFFECTIVE DATE. BE IT ENACTED BY THE CITY COMMISSION OF THE CITY OF OCOEE, FLORIDA, AS FOLLOWS: SECTION 1. The City Commission of the City of Ocoee has the authority to adopt this Ordinance pursuant to Article VIII of the Constitution of the State of Florida and Chapter 166, Florida Statutes . SECTION 2 . Section 1.73 -4 .?. of Article I of Chanter 173 of the Code of Ordinances of the City of Ocoee, Florida, is hereby amended to read as follows : S 173-4. Charges and Billing A. The following shall be the schedule of monthly rates and charges for water and sewer service provided by the city. Meters containing two (2) register units shall be billed based upon the base facility charge for the larger of the two (2) nominal diameter flow paths, plus the sum of the volumetric charges as determined by the current readings of both registers. (1) Water. (a) Base facility charge (zero consumption), effective (October) anuaryj 1, 44494 f 19981. Meter Type Charges 1chh $ 1-inch • f17.5111l 1 t/2-inch !i�}i S 135.001 2-inch 156.00 3-inch 112.00 4-inch •• inmimi 6-inch sniiiituasam 350.00 8-inch 10-inch 80,5.00 12-inch {1,Fii2.G0 1,505.001 (b) Plus: volumetric (gallons); charge of [fifty one cents ($0.51) per one thousand (1,000) gallons.' sixty cents ($0.60) per one thousand gallons up to 12 000 gallons plus ninety-two cents ( 0.92) per one thousand gallon tor use over 12 001 gaflons up to 25,000 galIons,p us One Do1r and Twenty-Five Cents ($1.25) per one thousand-gallons tor use over 25 001 gaflons.l (2) Sewer. (a) Base facility charge (zero consumption), effective October 1, 1991. Size of Meter Charge (inches) s/a $ 13.81 1 34.53 1 1/2 69.05 2 110.48 3 220.96 4 345.25 6 690.50 8 1,104.80 10 1,588.15 12 2,969.15 (b) Plus: charge per one thousand (1,000) gallons of one dollar and forty-seven cents ($1.47), provided that, for those residential consumers with a five-eighths-inch meter, the maximum sewer service charge shall be calculated as the base facility charge plus the current charge per one thousand (1,000) gallons up to a maximum of twelve thousand (12,000) gallons. (3) The schedule of monthly rates and charges for water and sewer service provided by the city as set forth in this Subsection A shall be applicable only to consumers located within the corporate limits of the city. The schedule of monthly rates and charges for water and sewer service provided by the city to consumers outside the corporate limits of the city shall be as provided in § 173-5.1 of this chapter. SECTION 3 . Severability. If any section, subsection, sentence, clause, phrase or portion of this Ordinance is for any reason held invalid or unconstitutional by any court of competent jurisdiction, such portion shall be deemed a separate, distinct and 2 independent provision and such holding shall not affect the validity of the remaining portion hereto. SECTION 4 . Codification. It is the intention of the City Commission of the City that the provisions of this Ordinance shall become and be made a part of the Code of Ordinances of the City; and that sections of this Ordinance may be renumbered or relettered and the word "ordinance" may be changed to "chapter" , "section" , "article" , or such other appropriate word or phrase in order to accomplish such intentions; and regardless of whether such inclusion in the code is accomplished, sections of this Ordinance may be renumbered or relettered and the correction of typographical errors which do not affect the intent may be authorized by the City Manager, without need of public hearing, by filing a corrected or recodified copy of same with the City Clerk. SECTION 5 . Effective Date. This Ordinance shall become effective on January 1, 1998 . PASSED AND ADOPTED this day of , 1997 . APPROVED: ATTEST : CITY OF OCOEE, FLORIDA Jean Grafton, City Clerk S . Scott Vandergrift, Mayor (SEAL) 3 FOR USE AND RELIANCE ONLY BY ADVERTISED November 20 , 1997 THE CITY OF OCOEE, FLORIDA READ FIRST TIME November 16 1997 APPROVED AS TO FORM AND LEGALITY READ SECOND TIME AND ADOPTED this day of , 1997 , 1997 UNDER AGENDA ITEM NO. FOLEY & LARDNER By: City Attorney CAW P51\IXXS1pLp 6pR 01N AryC:9J1I I/I]/T W,KENNA:PE0.v 4 OR Di-NI FNCE NO . 611 - 33 0RLGLNAt. kll C. o0.RG cY EO it gat 53 The Odend0 Santa,T17a1day.NOVeMber 2O 1997 L15; Friday, November 21, 1997, • • NOTICE OF PUS PUBLIC HEARING d• IC giv to en pursuant the Common 3the S No,, OFOF OF OCOEE HEMING a Rota and Section 18QOF1.FMge Note u Two HEARING danua l suv1e,that the Ocoee City Cornea to Mee Wn Me Conpegm willsion hold a Public Coring l e d M Sete p Ronda set Sep ed at 150 N Chamber,City Nell,b21. INn 1�.M1, Ronda Stables, ad at ISO N.Lakeshore One. to oe pip of Lye Uy Ronda during a regular seam al 71 to w Bill Mk a Publican,Commission Ise held as monDecember t9T p Les p.m.. Commission at ISO n. City thereafter aa I da the a- Nell located c 150 N. Lake. or • to consider me maomt a fee snore Onve.Ocoee.Florida cur. g RDINANCE NO.9T31 0 D.cemwpata R 195�. at i:ls AN ORDINANCE OF THE CITY P.m, Loan p,0 consi er OF SCHEDULESCFLORIDAOF�MONM Pa i woman d the to comia.t Lr CHARGES FOR WATER WA. avunce: Manes°' TER SERVICES: AMENDING AN ORDINANCE N0.OF TH SECTION A OF OF OR . ORDINANCE THE 33 T] OF THE CODE OF OPOF Cm OF OCOEE,FLORk NANCES OF THE CITY OF OA RELATING TO THE OCOEE WITH RESPECT TO THE SCHEDULE OF MONTHLY MONTHLY CHARGES FOR WA- CHARGES FOR WATER TER SERVICE;PROVIDING FOR SERVICES; AMENDING SEVEPASILITY PROVIDING SECTION 173-4.A OF FOR COOIFlCATIOM PROVIDING CHAPTER 173 OF THE AN EFFERNE DATE CODE OF ORDINANCES Interested pamee may appear as the OF THE CITY OF OCOEE r, ha m meting and be wan respect to I WITH RESPECT TO THE the reread sake A cop/y yet pro- MOMONTHLY CIMPGES FOR poea ptinaice may be maenad at WATER SERVICE' PRO- Wiry Hal, ISO N. Lakeshore Drive, WOING FOR SEVERARIU- Ocoee,Florldu.between the noun W TY FOR PROVIDING FOR 5:00 a.m. and 5:00 p.m., Monday CODIFICATION;PPOVID- rppA ING AN EFFECRVE DATE NOTICE i�parson who dawns to the reereMed Pates maY Neerbe heard at cows tan MOWon made w Commis- a am to Io Gamed p g any rnM a record A Copy of the imposed oidProPMed . of the proceedings and for such par- P ose nonce may be pes_h a.M liOty mayneed to ensure tat a coma Hoe, 150 N. Lakeshore Dr recorde. tim the of me proceeding ie made. Clem*. Florida, between the which the appeal n based . Persona hours of WOO am. and 5:00. with disabilities needing awpance toParticipate n 1o1 these 1 0.m.ou CMEmMy Wmpn Frdry, shoue .act ore 011ie d me G 1 NM Io my oereM cold M Clew,150 N.Lakeshore Dee,Ocoee. mete by teen Mesa/ a/ Rona]981.IWT16S6- 3.Ea 1b. I spent Mary owner cwlMNre. Ora. Clerk metre emeethe t awe meting van need en asin 9E7cold P ceeeM end b Ms e OISIy1V1Narenter�1 NOV.2 lPP! per proceeding Is mad..wipr record etude the teedmony eennpdeeyd*ice upon whey the is based.Pawns with dl IIseMlpee needing assistance to pt.NwM In any of thee• WndIns should contact the Lk�Me that D Cey Clete ISO .Ocoee Ronda S2101.HOR e;s-22a.ed.M& se inWent aoI�we Yr advance ON of the 4 m1WT� 0tS1639W1 Nava men n y r 4. r t. L•!.. , ,,•.riff 0, f•T+ F 1 9 Ol� T. yJ-d f, '! i,• • • .� L.f.. +•' t i 'tit' } J' r .V-i,+�+&Y. r r r':•1' 13i n� a.� 4 r' • \ \ 1 , • i� ; • • I. •.• ' , 4' 4 . / ... — • ' . ' •- • '\ • t '. ...7 - ' N•e ' \ • ` Li lr' f 1 y • $, • ' 4.�� r s n ,.%a 4'�4 :!s c ,}. �Sjt�+ f •z '. ••' • . ' •: t wtt•' i. v l• 't ' Y 'Mr*•, :1 I:+f'YTi +j, tT •4 •FJ:5 •:-x"v 4rt► „ �. • • 4 •4 r •t+•'r11- • ,i`t r`'' ..� •iit{4; i!7 i't-..;" Mp . _ ,, •,'-1'••-9z �r i�' .,rt - I (: r 4� • .! ) a' 1' 1c ,° • f:t r- ✓ S' �.G 4Yd r.-` t ,� )y }'' .•• •: ,,,r t+ }� '1 Pr`t- , :, •. .9 : '' F • +vM 4 tY�` •,�(ui: R 'f� r 4..4• 7 `,Jy}• z s I;t t, i ' '�1�h.ti fi!... �,� L � r r+.a..fpyr:1,'ry r,,,� +1r .. 1{f106 7 i� • -S �'a `:�1, • ,.r• 'i,:• .ti -. • ••r 1 • , r,. 71'a • +;�,ifq •.y.,.. -. r. -• 'T�' 4 tr. .. f �Y'.'ilT'R -'1'. '� >l+ 'i r M v ,+y • .....4...... r••. • i i:'� •t. htkr Y i ? t r '..4 w 1+`-,' ;,i µ f1'"'• c it tT g +r {rti1' t1C k*154, r Y 16 es • I bk ,. s c s 1. �i r• 4 ` • PEC Professional Engineering Consultants, Inca 200. E. Robinson Street,' SultE...,1560, Orlando, FL 32801 CITY OF OCOEE WATER RATE STUDY TABLE OF CONTENTS SECTION PAGE I. INTRODUCTION 2 A. PURPOSE 2 B. STUDY 3 II KEY ISSUES 4 Ill. REVENUE REQUIREMENTS 7 IV RATES ANALYSIS 8 V. RATE COMPARISON 12 I OE-65\waterstudy I. INTRODUCTION A. Purpose The purpose of this potable water rate evaluation is to recommend a modification to the methodology used by the City for determining monthly water user fees. The City presently uses a base rate fee plus a flat rate volumetric fee to charge for the monthly volume of water consumption. This type rate structure is generally described as a "flat rate" system and does not encourage the conservation of water. This method of calculating water user fees has been historically used by many local governments but is currently not promoted due to the need to conserve the potable water resources. The City currently charges a base rate of $7.64 per month plus $.51 per 1,000 gallons of consumed water. The City renewed its Consumptive Use Permit with the St. Johns River Water Management District as of November 27, 1996. The purpose of the Consumptive Use Permit is to provide the District with a means to regulate and measure total water withdrawal from the Floridan Aquifer. Over the last few years, the District has mandated all public utilities to encourage water conservation through an "inclined rate" structure. An inclined rate structure results in water users with higher monthly consumption paying a higher water rate thus providing a financial incentive for the conservation of potable water. A condition of the City's new Consumptive Use Permit mandates a change to an inclined rate structure by November 1997. 2 OE65\waterstudy The objective of this water rate evaluation is to develop a recommended inclined rate structure that ensures a fair and equitable recovery of the cost of providing water service to the residents of Ocoee. This water rate evaluation is not intended to provide an increase in the overall water revenues but is recommended solely to provide the City with an incentive plan for the conservation of the water resource. It should be noted that any change in the calculation of monthly water user fees may create changes in the overall consumption of potable water and the overall annual revenue collected from users of the water system. 6. Study Procedures The rate evaluation was conducted in two (2) phases. The first phase included a review of the documented cost of providing water service to the City of Ocoee residents. This review included an analysis of the sufficiency of water revenues to fund the following: • Operation and maintenance Expense of the Water System • Debt Service of the Water System • Administrative Costs • Renewal and Replacement Costs The second phase of the Study included a review of the current water rate structure and a recommendation concerning the modification of the water rate structure to fairly and equitably recover the cost of providing service and provide a financial incentive for water conservation was developed. 3 OE-65\waterstudy II. KEY ISSUES There are several important issues that must be considered in a potable water rate study. The key issues which were considered in this study include but were not necessarily limited to the following: • Revenue Sufficiency - Water rates must generate sufficient revenues to cover not only operations, maintenance and capital cost requirements, but they must also provide sufficient net income to meet the debt service coverage requirements of the utility's outstanding water revenue bond issue (Series 1997 Water and Sewer Revenue Bond Issue). • Fair and Equitable Cost Recovery - Properly designed water rates and charges should recover the cost of service in a fair and equitable manner from the users of the water system in proportion to their usage. • Cost of Service A detailed cost of service evaluation is necessary to identify and estimate all costs incurred by the City in provision of water services including direct costs, indirect and departmental costs, indirect City-wide costs and interdepartmental or central services costs which benefit the provision of water service. '['his was completed as part of the Engineer's Report for the Series 1997 Water and Sewer Revenue Bond Issue. • Cost Allocation - In a viable cost allocation methodology, the costs of service must be allocated to functional categories of service, and further, to cost elements or objectives, related to the ultimate user charge rate schedule to the rate schedule in 4 0E-65\waierstudy such a way that they are distributed to the users in a fair and equitable manner based upon usage. • Conservation Incentives - The continued demand upon the water resources caused by growth in Central Florida has caused most public utilities to closely examine rate structure alternatives that encourage conservation. In the development of the rate structure components which promote conservation, it is important to: O Develop rational criteria for the level(s) of usage by customer class at which the higher consumption rate(s) become effective, O Develop a rational basis for the amount of increase at each consumption "step" in the rate structure, and O Recognize the potential revenue deductions (elasticity of demand) due to conservation and factor those potential reductions into the revenue requirements to be recovered at the expected level of consumption. • Level of Services Standards - The Growth Management Act of 1985 require that all cities and counties in Florida establish level of service (LOS) standards in their Comprehensive Plan for the provision of potable water service. The City has adopted a LOS of 300 gallons per ERU. "Me St. Johns River Water Management • District (SJRWMD) has issued the Consumptive Use Permit based on a consumption rate of l50 gallons per capita. It is important to establish rates and capital cost recovery fees to provide sufficient funding for the facilities necessary to meet the level of service standards adopted in the City's Comprehensive Plan. 5 0E-65\waterstudy • Automation - It is important in developing a water rate system that it be automated so that subsequent rate adjustments can be cost effectively determined and implemented. Our recent preparation of the Engineers Report for the City's Bond Issue and annual evaluation of the City's water budget has assisted in the development of the revenue sufficiency analysis. • Customer Classification - It is important to thoroughly analyze the customer constituency in order to properly identify customer classifications, their characteristics, and the type of system statistics and billing frequency analyses necessary to support the recommended rate structure and cost allocation methodology. • Irrigation Considerations - It is important to consider the effects of water usage for residential lawn irrigation in developing an inclined rate structure. This includes considerations such as a cap on total sewer charges. As the City's reclaimed water program is expanded to residential properties, the water rate structure will need to be reviewed. • Fixed Base Charge - The recent emphasis of water conservation has rendered minimum consumption allowances less and less popular because a minimum consumption allowance does not promote water conservation. Most rate structures being implemented today include a fixed readiness-to-serve charge (base rate) with no minimum allowance for consumption, and the consumption charge is applied beginning with the first unit of consumption. These issues were all considered in the development of the rate structure recommendations presented herein. 6 OE-65\wateamdy III. REVENUE REQUIREMENTS This section presents an analysis of the revenue requirements that are necessary for the City to fund the Water System Operation, Maintenance, Repair, General Fund and Administrative Services and Dept Service Costs for FY 97/98. O WATER SYSTEM OPERATION $449,370 O WATER SYSTEM CAPITAL 27,950 O WATER SYSTEM DEBT SERVICE 853,645 O WATER SYSTEM ADMINISTRATIVE COST 346,680 O WATER SYSTEM GENERAL FUND CONTRIBUTION (12%) 236,170 0 WATER SYSTEM TAXES l52 000 TOTAL $2,065,815 7 OE-65\waierstudy SECTION IV RATES ANALYSIS This section presents an analysis of the City's current water rate structure and recommended modifications to the water rate structure. A. CURRENT WATER RATE STRUCTURE WATER - The City's current rate structure was adopted in 1989 based on a rate study prepared by Rachlin and Cohen, Certified Public Accountants. The rates were gradually increased through 1993 and have not changed since 1993. The rate structure includes a fixed monthly charge (base rate) per equivalent residential unit (ERU) and a water usage charge (volumetric rate) per 1,000 gallons of water consumed. Water rates are the same for residential and commercial users. CURRENT RATES ARE: $7.64 (base rate) / ERU plus $.51 volumetric charge per 1,000 gallons B. RECOMMENDED RATE STRUCTURE WATER - There are several components of the City's existing water rate structure that are recommended for modifications. It is important to understand that whatever water rate structure is adopted, the revenue requirements of the Water System will remain constant and the revenue must be recovered from the 8 OE-65\waterstudy rates and charges of the water rate structure. The overall goal of these modifications to the City's water rate structure is to promote water conservation through financial incentives. To the extent that a change in the water rate structure increases the relative cost burden of a specific customer classification (higher usage), commensurate decreases will occur in the relative cost burden of other specific customer classifications (lower users). The net result of the modified rate structure is to ensure the total water revenue is sufficient to fund the water system expenditures and to maintain the current total water system revenue to the maximum extent possible. The recommended rate structure modifications are described below: 1. Monthly Base Rate Analysis - The City's current rate structure assesses a monthly base rate of $7.64 per ERU. The purpose of the base rate is to recover the cost of providing water service independent of the volume of water consumption. These costs include items such as debt service, administrative costs (billing, collection, meter reading, management), general fund contribution, renewal and replacement. These costs include all fixed costs associated with providing water service to meet potential demands of the water customers of the system and should be allocated to all customers based on meter size or ERU allocation as a representation of potential demand. The City bonded its water 9 OE-65\watersuuiy revenue in January of 1997 to expand the water treatment and distribution system and provide water capacity for future growth. A review of the City's current fixed costs, including debt service, indicates an annual cost of approximately $850,000. The City has approximately 10,050 ERUs. Thus a fair and equitable base rate is $7.00 per month. The decrease from the existing base rate of $7.64 is due to the capitalization of long- term debt based on the 1997 Series Revenue Bond. 2. Volumetric Charges Analysis - The City's current water rate structure assesses water usage charges uniformly for all water consumers. The cost per 1,000 gallons of water usage is uniform at low usage volumes as it is at high usage volumes. The City currently charges $.51 per 1,000 gallons for water usage. Recommendation - Due to the increasing need to conserve the water resources, we recommend the establishment of an inclining Block Rate Structure for water usage. The Structure should include an Essential Domestic Usage Rate Block for water consumption. The Rate Block's first threshold should coincide with the City's existing Sewer Rate Structure of 12,000 gallons for the maximum amount of Sewer charges. The structure should include a Discretionary Usage Block (second tier) with an increased volumetric rate for usage within the range of 13,000 gallons to 25,000 gallons. The structure should also include a 10 OE 65\watersrudy Conservation Surcharge Rate for usage above 25,000 gallons per month. The recommended rate structure is as follows: Base Rate: $7.00 per ERU/month Volumetric Rate: $.60/1000 up to 12,000 gallons (Essential Rate) $.92/1000 up to 25,000 gallons (Discretionary Rate) $1.25/1000 greater than 25,000 gallons (Conservation Surcharge Rate) The modified rate structure will directly benefit low-volume customers using less than 8,000 gallons of water per month. This is approximately 50 percent of the City's water customers. The two (2) Discretionary and Conservation Surcharge Blocks are essential to provide a financial incentive to conserve water. 1 I OPr65\waterstudy SECTION V - RATE COMPARISON TABLE 1 - CITY OF OCOEE WATER RATES - EXISTING RATES COMPARED TO PROPOSED INCLINED BLOCK RATES Consumption Current Rates Residential Commercial Proposed Rate (per thousand) $7.64 + $.51 Customers✓ Customers $7+$.60(0-12) Current\ Current/ +.92(13-25) Cumulative. Cumulative +1.25(26+ 0 $7.64 0/0 0/0 $7.00 1 8.15 3/3 15/15 7.60 2 8.66 5/8 9/24 8.20 3 9.17 7/15 6/30 8.80 4 9.68 8/23 5/35 9.40 5 10.19 9/32 6/41 10.00 6 10.70 6/38 4/45 10.60 7 11.21 8/46 5/50 11.20 8 11.72 7/53 3/53 11.80 9 12.23 6/59 2/55 12.40 10 12.74 4/63 2/57 13.00 11 13.25 4/67 3/60 13.60 12 13.76 4/71 3/63 14.20 13 14.27 3/74 2/65 15.12 14 14.78 2/76 2/67 16.04 15 15.29 2/78 2/67 16.96 16 15.80 2/80 1/70 17.88 17 16.31 2/82 2/72 18.80 18 16.82 1/83 2/72 19.72 19 17.33 1/84 1/75 20.64 20 17.84 1/85 2/77 21.56 12 OE-65\waierswdy Consumption Current Rates Residential Commercial Proposed Rate (per thousand) $7.64 + $.51 Customers Customers $7+$.60(0-12) Current\ Current/ +.92(13-25) Cumulative Cumulative +1.25(26+ 21 18.35 1/86 1/78 22.48 22 18.86 1/87 3/81 23.40 23 19.37 1/88 2/83 24.32 24 19.88 1/89 0/83 25.24 25 20.39 1/90 1/84 26.16 26 20.90 1/91 0/84 27.41 27 21.41 1/92 2/86 28.66 28 21.92 1/93 1/87 29.91 29 22.43 1/94 1/88 31.16 30 22.94 1/95 0/88 32.41 GT30 5/100 12/100 13 0E-65\warerstudy TABLE 2 - COMPARATIVE WATER RATES FOR 10,000 GALLONS ENTITY WATER CHARGE INDIAN RIVER COUNTY 32.70 DAYTONA BEACH 23.21 MELBOURNE 20.76 TITUSVILLE 20.55 LAKE MARY 19.80 BREVARD COUNTY 19.49 SANFORD 17.14 ORANGE COUNTY 16.51 COCOA 14.72 CASSELBERRY 14.00 OVIEDO 13.75 OCOEE (PROPOSED) 13.00 WINTER SPRINGS 11.85 WINTER GARDEN 11.73 SEMINOLE COUNTY 11.70 ORLANDO 8.93 WINTER PARK 7.75 14 GE-65vwatersmdy Water Rate Comparison Cost per thousand gallons Existing and proposed rate structure 35 30 25 Existing 20 o Proposed 15 10 5 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 Thousand Gallons