7-25-2023
Comment of Ken Kules on the Municipal Services 7-25-2023 Agenda Item 2:
Water Cost-Of-Service Analysis and Rate Design Update
The American Water Works Association Manual Ml is the industry standard for setting water rates. Its Manual M22 is also the standard for sizing water meters and has a rigorous methodology for doing so. The Ml Manual endorses the use of meter sizing as a metric for classifying water customers provided that meter sizing procedures are followed. Those meter sizing procedures for single-family residential customers give great weight to the amount of irrigated landscape area in sizing the meters (larger properties get larger meters and smaller properties get smaller meters).
I've developed the following graphics from data that I got from acquaintances that are Pasadena Water & Power customers:
Poor correlation between meter size and lot size
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40.000
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K 30.000
3 10.000
Bfotk 1 allocation
22 HCf
12 HCF
12 WCf
B 1" meter
12HCF
22 HCF
22 HCF
12 HCF
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1 IV," meter
Observations:
* The largest parcei »n the sample has the smaller meter size The smallest parcel i$ about 5 times smaller than the largest parcel but receives the same block 1 allocation
The graph speaks for itself: there is clearly inequity in meter sizing related to parcel size in Pasadena. In an effort to discover whether this inequity is pervasive, I submitted a Public Records Act request in 2019 to get similar data for PWP's service area and that request was denied.
The meter size inequity affects the existing water rate equity in that the Distribution and Customer Charge and Commodity Charge are both based on customer classes by meter size. That flaw cannot easily be cured by replacing meters that are improperly sized. The inequity in the Commodity Charge can be cured by moving to a budget-based pricing method of setting rates. I urge the Municipal Services Committee to reject a proposal that would "screen out" budget-based pricing in the current rate-setting procedure and give this issue consideration in the establishment of the D&C rates.