Thursday, October 22, 2020

We will pay for this debt forever


Speech to the Grants Pass City Council, 10-21-2020

               A couple of years ago, Staff asked you to pass a debt payment fee for our new water treatment plant, which they said would not increase by inflation, and would go away when the debt is paid.  This made me happy; it was a fixed payment for a fixed cost, and in 30 years, it would be gone.

            Later I learned that only 60% of that debt payment would be in that fee.  I assumed that 18% of it would be paid by the Urban Renewal District that was passed to help us pay for the new plant.  But that still leaves 22% of that debt to be loaded on our rates, an equal percentage rise in the base rate and the unit rates, where it is set to be compounded every year by 4.5 times the rate of inflation, and will never go away.

            A few weeks ago, I asked our City Manager if this was correct.  He has not answered my question about the URD’s 18%, but we did learn in the Courier that our water rates will be rising by 6% every year for 5 years to cover the debt not paid by the fee.  That is in addition to the 6.78% more we are paying every year for 1.5% inflation plus 5.28% to cover the overhead that we are not paying with our decreasing water use.*

            Staff tries to make it sound like they are saving us money somehow by keeping our base rate too low to pay all the overhead, like we used to before the base started being lowered and part of the overhead loaded onto our unit rates to make us save water.  But each customer has only one base rate; we use multiple units, and as we collectively cut back on those units, both base and unit prices are raised to cover that overhead. 

            We used to pay all of our overhead with base rates because that was the cheapest way for everybody to pay for water, and we could use all we needed for any beneficial use, including watering to keep our city safe from fire.  Rates were stable.  Unit charges were literally pennies on the bill. 

Now we are oppressed by high unit charges into paying more and more to use less and less water.  Please cancel the 6% rate increases and make our debt payment fee and the Urban Renewal District cover the whole debt.  Please do the same for the sewer plant debt, which is all being paid with our sewer rates.

*I was wrong about this because FCS did not say what was being paid for in the expected 6.78% rate increases over 4 years that they put in their March 2020 memo’s rate charts.  Staff said that it does include the debt service of the planned new plant.  If that is all that their expected increase covers, they are not planning for increases to cover overhead that have been happening since 2008.  

Staff said, after this speech, that the Urban Renewal Agency (not District) is picking up 18% of water debt service, and that it can be done for the sewer debt as well.

Comment revised 1/5/21.  Shared to RatePayers for Fair Water and Sewer Pricing: https://www.facebook.com/groups/335132417324336

  Rycke Brown, Natural Gardener        541-955-9040        rycke@gardener.com

Sunday, August 9, 2020

Make a Fermentation Swamp Cooler

This is a fermentation swamp cooler.  I needed something to ferment my Butternut salad in that was cooler than room temperature, which makes fermenting vegetables mushy, but warmer than a refrigerator, which stops fermentation--something about 50-60 degrees F.  A regular swamp cooler for keeping drinks and such cold can get down to 40 degrees, the temperature at which water begins to evaporate.  I figured if I made one that allowed outside air in under the wet towel, it would stay a bit warmer than that, and it does.

It starts with a very large bowl.  This one is never used except to mix vegetable salad for ferment, which was handy.  Put a flat 9" cake pan in the bowl, set the jars of vege salad in the pan, and pour water in the bowl outside the pan until it reaches almost to the top of the pan.

I just happened to have this white-painted metal screen cake cover that has holes big enough for fruit flies and ants to get through, making it fairly useless as a cover, which I thought would be useful for keeping the wet towel elevated above the jars.  (A colander would work as well.)  Looking at the first photo, it works beautifully.  It has a hole in the coverage on each side of the wet kitchen towel that covers it, allowing some room-temperature air in too keep it from getting too cold.  The towel hangs just outside the pan, which keeps it sitting in the water, but not wicking water into the pan.  

It would probably work just fine if the water did wick into the pan, or even if the pan was not there.  But I like that this arrangement keeps the fermenting juice out of the water.  Jars of fermenting vegetables tend to leak their salty, acid juice out under their loose lids, which have to be left loose to keep fermentation from breaking the jars.  You have to open them and press the vegetables down every few days to push the CO2 out of the mix as well.  After a week, tighten down the lids and put them in the fridge to stop the ferment and enjoy.  They keep a long time in the fridge.

I also enjoy the salad when they are freshly mixed with salt.  Salt and lack of oxygen is what make fermented vegetables safe to eat, killing all the salt-sensitive bacteria and those that need oxygen.  Germs that like high-salt environments and are killed by oxygen just happen to be the lactic acid producers that are safe to eat, which is why sauerkraut works with just salted cabbage, well pressed and weighted down into its juice.  Salt also pulls out some water from the vegetables, keeping them crisp as they ferment and providing the juice to keep out oxygen.

Too little salt or too high fermentation temperatures will both tend to make a mushy ferment, which is not enjoyable.  I find that one and a half percent salt by weight is perfect; under one percent is not safe.  You'll need a good digital kitchen scale to figure out how much for each batch.  Weight the salad in grams, and multiply by 1.5% or 0.015.  I use Himalayan pink salt for its milder flavor and its minerals.  It is important to work the salt in with gloved hands, squeezing the vegetables in your hands, to help the salt and bacteria penetrate them.  Press the salad into the jars hard to exclude the air as you fill them until they are 1/2 inch from the top and covered with juice.  Press a plastic baggy into the top to keep air off the mix.  A Brie's salad dressing bottle with the label removed works very well for pressing it into jars.

These three quart jars of Butternut salad were made with a very long Butternut squash, peeled, seeded and grated with the large grater on the Saladmaster salad maker I got last year; two red and yellow sweet peppers, seeded and chopped; and a large white onion, peeled and chopped.

Swamp coolers, from large desert air conditioners down to a pan of water with a jug of drink in it covered with a wet towel draping into the water, works by wicking water up wet cloth and evaporating it down to 40 degrees F.  This is a trick I picked up while living in the Arizona desert; it comes in handy anywhere the summers are not humid.  

During monsoon season in Arizona, swamp coolers become fairly useless, but not in Southern Oregon, because we don't have real monsoons.  Southern Oregon used to regularly get wet summer thunderstorms from irrigation humidity when water was cheap and nearly everyone in the city watered their yards, which doesn't compare to true ocean moisture sucked into the interior by hot mountains from a warm ocean.  Our ocean is cold, and we have a coast range to stop the coastal fog from getting this far inland, so our hot mountains cannot bring us summer rain from our ocean, creating high pressure instead that blocks ocean storms.  

Over the last 15-30 years of high water unit prices increasing far faster than inflation all over the nation and the world, we haven't been irrigating our cities enough to make many summer rainstorms, making dry lightning and wildfires instead, so swamp coolers and misters can work really well to cool houses and yards.



Monday, June 22, 2020

Answer to City Memos

Answer to City Memos with attachments. Click on attachments to see full size.

Rycke Brown, Natural Gardener
1415 SW Bridge Street
Grants Pass, Oregon 97526
541-955-9040

Memo Regarding Petitions to Reform City Water and Sewer Rates
                    
Submitted 5/22/2020, revised 6/12/2020

Mayor, Council, and Manager:

A reminder of what your staff was supposed to be evaluating and calculating:

Price Water to Sell. 
We, the undersigned, want our city water to be priced to sell it, not to ration it, so we can use all that we need for all beneficial uses at a low price that stays low.  We would assign all fixed overhead costs into fixed base rates.  Only marginal unit costs would be assigned to a single unit rate.  Base and Unit Rates would rise only by actual inflation of costs of the previous year from the year before, not the Consumer Price Index.  Debt service would be paid by a fixed fee and sunset when the debt is paid. 

Price Sewer Fairly.
We, the undersigned residents and business owners of Grants Pass, want our sewer service to be priced fairly, as a subscription service, without unit rates.  Debt service would be a separate, fixed fee and end when the debt is paid.  Rates would rise only by actual inflation of the previous year’s expenses from the year before, not the Consumer Price Index.

In this memo, “Petitioner” is the chief petitioner, writing this memo. “Petitioners” are the over 1000 people who signed onto the above Petition, as well as Price Sewer Fairly, including circulators. Petitioner prefers to use the term “unit rates” when talking about the unit price of water, because “usage rates” can easily be confused with the amount of water customers use, collectively or individually. 
           
Staff did not calculate any rates; they asked FCS Group to do it for them.  FCS begins with “Issue,” “The City of Grants Pass is interested in evaluating the impact on the water utility’s rate structure if fixed utility costs were fully recovered by fixed meter ‘base rates.’…” 

Staff apparently did not ask FCS to evaluate the actual water petition, only the first sentence of it: “We would assign all fixed overhead costs into fixed base rates.”  The next sentence says, “Only marginal unit costs would be assigned to a single unit rate.”  On page 2 of FCS’ memo, “Exhibit 1: Current and Alternative Rate Schedule (Inside City),” “Usage Rates per Unit (100 cubic feet)” they show a rate schedule with all the unit rates of the present system for various customer classes and use amounts, under the existing rates and under “fixed cost structure” rates for the same classes and tiered use allowances. 

Staff did not ask FCS to configure the sewer petition at all and had not evaluated it themselves at the time of their memo.  But Staff says, “We stand ready to provide additional information or provide revised scenarios as needed.” 

Both are needed, and the whole thing needs to be done by Staff.  FCS has a conflict of interest in configuring the rates for either of these petitions.  The calculations for both water and sewer rates in these proposals can be done by any competent bookkeeper.  We need not pay hundreds of thousands of dollars to rate consultants like FCS for basic bookwork. 

Price Water to Sell calls for only “a single unit rate” for all customers to end price discrimination between customer types, locations and amounts of use.  Customers feel put upon when they must pay more or higher unit rates than others.

“Issue” continues, “Currently, approximately half of the water utility revenues are generated from base rates while the remainder is generated from consumption-based usage rates (this excludes revenue generated by the Water Plant Replacement Fee, Additional Unit Charges, and Fire-Standby Charges).” 

The Water Plant Replacement Fee is included in the petition and is supposed to cover all of the debt service for the plant, excluding only the 18% that can and should be charged to the Urban Renewal District (URD).  We were told by Staff, when that fee was instituted by Council, that it would not be increased by inflation and will go away when the debt is fully paid. 

We were not told, but Petitioner since learned from our recently retired Finance Director while circulating these petitions, that only 60% of that debt service would be covered by that fee when it is fully implemented.  With 18% paid by the URD, that leaves 22% being loaded equally onto our base and unit rates, where it will rise yearly by the CPI and whenever costs outstrip revenues and will never go away until the rate system is reformed.

Petitioner wants 82%, all of the debt service but what is paid by the URD, to be in that Water Plant Replacement Fee.  Such fee would be applied to sewer debt service as well and such debt service would be taken off the base and unit rates of both systems.  The fee therefore should be figured into the mock-up of the proposals in these petitions.

Those “Additional Unit Charges” that FCS didn’t bother with are extra unit rates paid only by some people in some locations and situations in both water and sewer.  They should be folded into the single unit rate for water and the base rate for sewer as called for by Petitioners. 

“Fire Standby Charges” are listed on the City website as “Standby Meter Charges” on the Comprehensive Fee Schedule, page 17. It is an extra base rate for certain businesses for fire suppression that requires an extra meter and is a separate service, which justifies its own base rate.  But we notice that there are Standby Charges among the unit rates in Appendix B in the FCS memo, and they are higher than any rates but the 4th tier for single family homeowners, although customers required to have Standby meters have no control over how much water is used to put out a fire.

Under “Considerations,” FCS begins:
Most of the water utilities costs are fixed, especially in the near-term planning horizon (e.g. staffing, supplies, maintenance, debt service, etc.). Aligning base rates with fixed costs would increase base rates and decrease usage rates. This would increase stability for the water utility, but it would also reduce the amount of the water bill that customers have control over – the usage rate portion of the bill.  This change may reduce a customer’s incentive to conserve water, especially during seasons of peak water usage, since the usage rate would be much lower than it usually is.

This is mostly true enough.  Petitioners’ proposal would provide stability for the plant finances, and likewise, though not stated, for customer finances.  The bill would vary little from summer to winter, would stay that way, and would not increase faster than inflation of actual costs of the plant. 

That it would reduce the high cost of using the water and increase use thereof is a feature that is most attractive to Petitioners, allowing everyone to water their yards for beauty, growing food, humidity, coolness, easier maintenance and fire safety and suppression and not worry about using so much water that the bill rises drastically.  With a single unit rate, we would also be able to house many people in our single-family homes without paying more per unit for water than those who can afford to live alone or as a couple.

The present “control” by the customer of the larger portion of their water bill by not using as much water as they would like is a mirage, a constantly moving goal that is never reached, because the half of overhead costs that are presently paid by use do not go away when that use drops, a drop which our present rate structure is designed to create, rationing the use of water by price.  Anyone’s rationing is paid for by all customers, with future raises in both the base and unit rates, which causes more drop in use.  It is better for each customer to fully pay their full share of the overhead up front in the base rate than to have to pay for it piecemeal and have higher rates every year imposed on all because some people, even themselves, cut use to save money. 

Under Petitioner’s proposal, no one has to use any water to pay the overhead.  If the plant goes down for an extended period due to a breakdown (not out of the question with our breaking-up plant during the building of our new one), as long as customers pay their base rate, we would keep the overhead paid.  Nobody’s use or lack of use affects other customers’ bills.

Under “Considerations,” page 1, FCS tells us,

The City’s water rates are based on the cost-of-service methodology defined in the American Water Works Association’s (AWWA) M-1 Manual, Principles of Water Rates, Fees, and Charges.  Recovering fixed costs in the base rate, while intuitive, is inconsistent with such cost of service principles, which assign cost recovery in rates by functions and causation, not by the fixed or variable nature of the cost.

Staff begins their memo:
Calculating water rates is a complex and often mysterious exercise.  The City of Grants Pass, like many cities in the US has elected to follow the American Water Works Association (AWWA) Manual of Water Supply Practices M1: Principles of Water Rates, Fees, and Charges.  This manual is the standard most utilities use when developing their water rate charges.

This is why calculating water rates has become so complex and mysterious that we hire consultants like FCS.  “Most everybody else is doing it” is not a defense of overpricing a monopoly product or service.  If cleaned, pressurized water and sanitary sewer was not a monopoly, cities wouldn’t be able to charge their customers like they do under AWWA principles.   

What differential base and unit pricing does is remove some of the burden of the overhead from some customers, while loading it onto others, dividing the people against each other.  Most cities these days ration water by price, and they can do so without following AWWA principles, simply by having a relatively low base rate and one high unit rate, like Redding, which burned when their single unit rate was only 2.5 cents higher than our top rate was at the time.  (It’s still $1.425.  Maybe enough customers decided that watering is necessary, regardless of price.  Or maybe the city raised the base rate instead of the unit rate, to stabilize the price.)  See Exhibit A, “City water and sewer rate comparisons.”

Following AWWA principles requires hiring consultants like FCS to configure water rates to take responsibility from Staff for discriminatory charges.  The AWWA is probably composed of such rate consultants.  But our City Council is the regulator for our water rates, regardless of whether Council or Staff understand them.  It is better if Council and Staff understand them.  AWWA and Staff are not accountable to city voters. 

In paragraph two, Staff says, “The balancing act that utilities must overcome is ensuring that their fixed costs adequately cover the non-variable costs while not punitively pricing low water  users out of the ability to afford their service.” 

The service we are selling is both the availability and use of the water.  Overpricing use makes people unable to afford to use the water as they wish, which can make them low water users, but not by choice.

There is no kindness in giving people cheap access with a low base rate and then charging them through the nose to use the water and jacking up both rates to cover overhead.  Water is life, cleanliness, health, fire safety and quality of life.  It should be priced to use it freely; we should not be forced to pay more for use than it costs to pump, clean and pump more of it.

Since the tiered rate system was first implemented in 2006, dropping the base rates and creating much higher unit rates, tiered for single family homes only, our base rate has climbed from $8.30 to $20.20 in 2020.  Unit rates have risen by a similar proportion, but unit charges by a much higher amount, for those who use the water to water their yards, and for those who live many to a house and use a lot of household water. 

Looking at other cities that changed to water-rationing rate systems before we did shows how ridiculously high unit charges can get over time because of chasing the overhead.  Look for cities paying more than us in Exhibit A.

Under “Impacts on Customer bills,” FCS says,

A single-family customer that uses 10 units of water is currently billed $29.60; $20.20 for a ¾” meter and a usage charge of $9.40 (5 x $0.63 + (5 x $1.25).  A single-family customer that uses 4 units of water is currently billed $22.72 because their usage charge is only $2.52.

However, under the “fixed cost” rate structure, the 10-unit customer would be billed $37.02 and the 4-unit customer would be billed $35.59.  They both would pay $35.07 for the ¾ inch meter charge and the 10-unit customer only pays $1.43 more despite using 6 more units of water.

It is interesting that FCS only talks about low-use water customers, who are well below the 16 units that Staff has determined is the point at which higher users would save money over the present system because of low unit rates and lower users would pay more because of a higher base rate.  They will likely be closer yet and more customers would save more money under a single unit rate system.

This comparison is an example of how a system of low base and high differential unit rates plays off water and sewer users against each other, with the assumption being that some people should pay more than others for the overhead costs.  Just because you have been overcharging everyone for use, some more than others, and undercharging for the base rate for nearly 15 years doesn’t make it right to have changed to that system in the first place and doesn’t mean that we can’t change it back.

On the other hand, under Petitioner’s proposal, 4-unit single-family-home customers would likely start watering their yards and use at least 10 units in summer, wouldn’t be scrimping on water the rest of the year, and both may well be more satisfied with their water use and cost.  If this example is a winter bill, the single-family-home customers who use 10 units because of more people in their homes wouldn’t be paying more for household use than their 4-unit neighbors and would also be able to water their yards in summer.  Single family homes and PUDs come with yards, and all of them need to be watered and gardened for weed control and fire safety.

After “Considerations,” FCS asks, “What Costs to recover from Usage Rate vs. Base Rate?” They answer,
It is assumed that the following costs are ‘variable’ for this analysis:
•           All electricity used at the water treatment plant;
•           All chlorine and chemicals used at the water treatment plant;
•           One-fifth of water treatment plant staff.
… Considering this profile, this analysis will result in fixed rates that generate about 90% of the rate revenue target and usage rates that generate 10% of the rate revenue target.” 

FCS does not explain why one-fifth of water treatment staff should be considered variable.  Staff says, on page 3 of their memo, “Current plant staffing only allows for double coverage (I.E. two people per shift) for 10 hours a day in the wintertime. Winter production only allows the plant to run at 5,500 gallons per minute or 3.3 million gallons in a 10-hour shift.” 
If another worker needs to be hired because we suddenly start using more water in winter as it costs less to use it, that use is unlikely to go back down and that worker should be considered overhead, just like the rest of plant staff.  Changing the rate system removes an artificial impediment on water use. 

What is utterly neglected in the memos by FCS and Staff are the benefits of using water, and the costs to quality of life that result when people cut back on use.  In the ‘80s, nearly every occupied property was watered, mowed, hedged, weeded, and many of us grew food and flowers and shared produce with neighbors and friends.  This was a clean, green, beautiful and orderly city.

In 1985, we had rain nearly every weekend of the summer because water vapor from millions of gallons per day going through sprinklers and transpiring plants caused clouds and rain to form, particularly thunderstorms.  The ‘80s was a wet, cool decade, the height of sprinkler irrigation around the world.  

In 2013, Petitioner did an analysis of summer weather in Grants Pass over 30 years, from 1983-2012, attached, that shows midsummer rainfall fell 0.09 inch on average per decade in the ‘90s and the 2000s, as water unit rates climbed and use dropped.  It would be interesting to continue that study for the years since, as we have only dried out more in the last decade.  See Exhibit B, “Statistics Show Our County is Drying.”

In the ‘80s, one could tell the poorer parts of town only by the condition of houses rather than by ugly, littered, dangerously dry yards.  We didn’t have yard and weed fires in the city. We had wet thunderstorms, not dry lightning.  We didn’t have forest fires anywhere close to our city, because our irrigation humidity was spreading out all around it.  The forests near town were full of greenery and life, and we didn’t have to cut the brush to prevent forest fires.

These are only the effects of watering on landscape maintenance, rain and fires.  Water’s role in health and hygiene is critical, too, and forcing large households to scrimp on water for cleaning and toilet flushing is not good for health, hygiene and quality of life.

Staff created two charts on page 2 from FCS’s charts.  It is clear that those who use 16 units or less of water in summer, about half, would pay more for water service in the summer, and all but about 4% would pay more in the winter. 

These charts are one of the best arguments for reforming the water rates fully, as they show that the customer’s bill will vary little from winter to summer under FCS’ hybrid “fixed cost system.”  It will vary even less under Petitioner’s proposal of a single unit rate, both within the year and between customers. Under the present system, about half the people pay higher unit charges in summer to cover overhead, both for other people who use less than 16 units in summer and for the 96% who use less than that in winter.

The charts leave out the top tier of water, 26 or more units, cutting off at 25 units, which 27.5% of single-family home customers use more than, in summer, creating a nicely symmetrical graph.  It would be interesting to have the full graph, in which the “present rates” line curves sharply upward in cost to the consumers and it isn’t so nicely symmetrical.  

Staff concludes that most single-family-home customers will pay more for water under FCS’ hybrid “fixed cost” system than the present system, apparently relying on winter use to make that argument.  But it is an irrelevant argument.  If there were only a small percentage or a huge percentage paying higher unit charges to cover overhead for other people, the city would still be overcharging them greatly and undercharging the rest.  The system would still be in a vicious pricing spiral, chasing the overhead and never catching up as long as customers keep cutting use. 

Staff’s separate graphs for winter and summer use show how many of us irrigate, and how much we depend on those who continue to irrigate under our present system, in which we punish people for using more water.  They show that our present rate system is designed to pay most of the year’s overhead in the summer, which requires the City to save money from the previous summer and borrow against next summer to pay winter, spring and fall overhead. 

Paying for all overhead in the base would obviate the need for such saving and borrowing.  It would give the city and customers much more even bills year-round and lower rates overall than the present system would, over the years into perpetuity, which most people would appreciate.
Staff follows the two charts with:

To put this volume of water into perspective, 16 units of water is 12,238 gallons.  A swimming pool that is 12x24x5 holds 10,800 gallons (14.4  units).  A typical large water tanker that you see on the road holds less than 5,000 gallons (6.68 units).  A yard sprinkler running at 2 gallons per minute 24 hours a day would use 3.8 units of water.  A typical shower is around 20 gallons.  It would take 598 showers to equal 16 units of water.

This does not provide perspective on how people really use water at home.  Let’s take another look.  Petitioner has 8 people in our house.  The neighbor to the East has 7.  The neighbor directly across the street has 8.  The neighbors on each side of them have similar numbers.  The neighbor to the West of us has 7 or 8 people living there.  All but the neighbor to the East have children in their houses; that one is an adult foster care home. 

Single family homes in lower-class neighborhoods are often full of people sharing housing and utility costs: families with children; multi-generational families; families made up of friends living together to share expenses, businesses like foster care and day care.  These are customers drinking, cooking, washing dishes, cleaning indoors and out, showering, doing laundry, and maybe even watering their yards.

Petitioner used an average of 12 units of water per month last winter, which only about 8% of single-family-residence customers used as much or more than.  We used 13 the year before.  We are now in tier 3 year-round, except for late spring, summer, and early fall, when we are in tier 4.  We are paying more per unit than 92% of customers in winter, close to 100% in summer at over 50 units last July.  Our summer use was left off staff’s graph.  Last month’s use was 37 units, as watering season started early.

This brings us to the second to the last paragraph of the Staff memo, which begins:

At the time of this memo, staff has not evaluated the impacts on the sewer rate of conversion to a complete flat rate.  The [current] rate was designed to appropriately charge those customers who impact the system and reward those who do not….

So it rewards those who are dead?  Everyone alive who uses the toilet, sinks, showers or bathtubs impacts the sewer system.  We have no control of how much waste we send down the pipes; we have some control of how much water we put down the pipes to carry that waste to the plant.  It is interesting how often we are told about sewage clogging the pumps these days. 

Under the present rate system, customers who ration water in the house to save money on sewer service impact the system and other customers more than those who don’t by making the sewage more concentrated and harder to pump, as well as bumping up the rates for everybody to cover the overhead. 

Sewage collection and treatment are a mandated service for public health, not a commodity like clean water.  No one gains anything by use of the sewer system.  The city collectively avoids the evil of pollution and sickness, for everyone in the city and downriver, by collecting all the sewage, cleaning it to drinking water standards, and putting it back into the river.  Every bit of it has to be cleaned, and we have no choice about how much waste we produce. 

It is not appropriate to charge any customer any more than any other for such a public service.  Charging unit costs for sewer is a recent development in water-rationing strategy, and several cities listed in Exhibit A do not do so, including Medford, Portland, Santa Rosa and Redding. 

Lastly, the second paragraph on page three of the staff memo begins:

The City’s current rate structure does encourage a certain level of conservation.   This is a condition of the city’s water rights that are so important to the long-term growth of the City….

Petitioner was told in 2018 by Staff that our water rights can be taken away if we didn’t charge unit charges for water.  I asked where in state law that is stated.  He was unable to tell me and asked me to look for it.  I read both water law and the Aquabook and could find no conditions on rates.  On page 36 of the Aquabook, it says that, if the city saves a lot of water, wants to use that part of its water right for something that is not currently within its permit and the Water Board disagrees, it can take that part of that water right.  That is the only reason mentioned to take away part of a water right, besides complete non-use of a portion of it over at least 5 years. (page 35) Our water right is in danger only from not using part of our water right for too long.  Using only up to 15 million gallons a day when we used to use 20 million, we are in danger of losing 5 million gallons per day.

There is no requirement in law to price water in any particular way.  On page 37, it mandates that cities that sell water file a conservation plan, but there is no penalty for non-compliance, unlike long-term failure to use part of the water.  It does not say that the Water Board would even have to approve the plan.

The City of Grants Pass has filed water conservation plans that features water rationing by price.  But we are in charge of our plan.  We can change it to reflect what is best for the City and its customers.  The City Council is the only political body that regulates our water rates, providing accountability to City voters. 

Indeed, conservation by water rationing in West Coast states has only resulted in drought.  When Petitioner lived in Grants Pass for two years in the ‘80s, we had wet thunderstorms nearly every weekend of the summer of ’85, when nearly everyone was watering their properties, and the town was clean, green and beautiful. In 1986, we had little snowpack in our mountains come spring and were told not to water our yards or wash our cars.  That rationing was on everyone, not by price, but it was still counter-productive.  We had 104 days without rain that summer, because we weren’t watering enough to make rain.  The next year, we had 98, likely for the same reasons.  (See Exhibit C, “Days Without Rain in Grants Pass,” courtesy of The Daily Courier, 9-28-2018 with side notes added by Petitioner.

Real conservation of fresh water doesn’t let it run out to sea without using it a few times along the way; storing part of it in soil and lakes and ponds; evaporating it with sprinklers and misters; transpiring it by growing plants; and letting it humidify the area and sharing it with other places as it blows on the prevailing wind, uphill and upstream, keeping it in circulation over the land, sending it across the continent on the prevailing western wind, causing rain along the way.

Beavers are prime water conservationists.  They do it with dams, ponds, and canals, storing water in ponds and soil that trickles out over the dry season and keeps creeks and rivers running and plants growing.  When the first European trappers came, beaver swamps dominated every creek and rivulet.  By the time they were trapped out, the inland West had become a gullied desert.  Where they have been restored, they increase water in creeks and fish survival due to increased flow and decreased water temperature.1

We do it with big, cement dams like Lost Creek Dam, keeping river levels up and temperatures down for fish and for watering our properties, growing plants and, like beaver, holding part of that water in the soil in the process.  We did it a lot more when water was cheap to use, and we used it freely.

Staff continues,

The Pacific Northwest has traditionally had a large amount of water, but one doesn’t have to look far to see that drought is not something that is unknown to us.  Encouraging responsible use of our precious water is key to the long-term health of the Rogue River and the flora and fauna that call it home… 

So how is that working out?  Grants Pass has been rationing water by price for over 20 years, seriously for nearly 15.  California has been at it since the late ‘80s or early ’90s.  California cities started burning first and most. We’ve had to cut our brush in the forests to keep fire danger down, which is not good for the plants and animals that live there.  We’ve been getting increasingly smoked out since 2000 and big fires have gotten closer over the last decade.

In the mid-eighties, we were first told that fresh water was a “precious” commodity; that only 2 percent of water on earth is fresh; and that we must conserve it, in all times and places, apparently, regardless of supply and our need to use it.

Water is not precious; it is vital, a necessity of life and living well.  “Precious” things are not necessities, they are rare and expensive luxuries, like gems and gold.  Water is among the most common and naturally recycled of resources and rationing its use by price only makes our customers poorer in health and wealth.  People used to grow food all over this city and share it with neighbors.  Now we have a food bank growing food on a city farm using unclean water because not enough people are growing it at home.

Look at Exhibit A and check out the water rates in cities where drought is uncommon, like Seattle, Washington and Portland, Maine.  Goshen, Indiana is interesting, in that its top tier rate is on the lowest use, targeting household use and reserving lower prices for industry in a city that gets many monsoon thunderstorms, needs no irrigation most years, and doesn’t need to ration water. Youngstown, OH has their top tier in the middle, along with a negative base rate to give a modicum of relief.

Portland, Oregon is no slouch when it comes to high water unit rates.  A friend of my daughter moved to Portland, eventually rented a house, and started gardening.  Portland bills their water customers every two months.  Her first bill after watering her yard for two months was over $800! 

Portland has a negative base rate for those who can prove their poverty, to offset the high cost of using their water.  The links at the end of Exhibit A can help you explore the variety in some water rate systems around this country, but so far, every one of them is rationing by price in some fashion, which only shows how fast and far a bad idea can be spread.

Since water that goes down the drain is cleaned to drinking water standards and put back in the river, there is no need to conserve household water.  The state’s interest is in providing sufficiently cold water for fish.  The only water that we use indoors that doesn’t go down the drain is what we breathe out, and the breath and waste of our animals, but that doesn’t mean that it is lost to the river.  It goes into the air, like the water that evaporates or transpires when we irrigate.

Irrigation water is hard to waste. We were told in Landscape Management at RCC in 2000 that sprinklers evaporate half of what they throw and “Evaporation is waste.”  But evaporation is not waste; it is the first step in the water cycle, without which we get no clouds or rain. 

The Pacific Ocean is cold on this side, as are the eastern sides of all oceans outside the tropics.  It doesn’t evaporate readily in summer and often sets up high pressure in winter that causes sometimes weeks of fog in our inland valleys.  The western sides of continents outside the tropics tend to be naturally dry. 

Irrigation water goes into the soil, where some of it is pulled up by plants and transpired through the leaves, a form of evaporation.  Evaporation can cool objects and air down to 40 degrees F, the temperature at which it starts evaporating.  What isn’t used by plants is stored in the soil, providing more evaporation as it wicks to the surface. Some of it leaches down into the water table and raises it.  Higher water in the water table flows to creeks and rivers, seeps into them and raises their level.  Many of our creeks that ran all year in the ‘80s go dry now because that extra water isn’t there.

Sprinklers are particularly efficient in creating evaporation, as they throw water not only in the air but on plants, soil, and pavements, from which it evaporates and cools wet objects and the air as they dry.  We live where rivers run to the West, into the prevailing wind, which sends our watering vapor uphill and upstream, making rain and filling our creeks, rivers, and aquifers. After cooling things down, vapor can share water with other places downwind and upstream, even over the Rockies, where it can make clouds and fall as rain.  See Exhibit D, “Watering fields in California boosts rainfall in Southwest.”
The easiest way to share water with other places is by using it first.  When it doesn’t blow away, it can create wet thunderstorms right where it was generated.  This happened frequently in the ‘80s, since most watering occurs when air pressure is high.

2019 was an exception that proves the rule that constant rationing of water creates drought.  Congress legalized hemp growing in late 2018, which changed our weather in 2019, as hemp was planted all over Josephine County and Oregon, often in places that had not grown more than hay for a long time, due to Oregon’s land use laws that left a lot of farmland fallow or nearly so after 30 years.  A lot of marijuana farms were also converted to hemp and watered their whole property instead of the small canopy allowed for marijuana in Oregon.

Out of that, we got a few good, wet thunderstorms and no fires in Josephine County caused by dry lightning.  The last storm, in September, looked like an irrigation-season-ending rain with the look and feel of fall in it, and irrigation abruptly stopped as the combined cannabis harvests commenced.  The rest of September, October and November were clear and dry. December and January brought us winter rains, but low snowpack.  February and March were dry.  We finally have been getting some rain in April, May, and now June, likely again because of hemp growers. But irrigation season started in March this year, and the city sold a record amount of water in March and April, despite high unit rates.

Against the background of water-rationed cities around the world, our county’s increased irrigation made a difference in this county and we could tell when it stopped last year by the effect on our weather.  Vapor travels, but it first makes a big difference where it is generated.

Staff continues,

Removing the impediment to unhindered water use could have the effect of increasing the city’s consumption.  While not an immediate problem, increasing consumption will require the treatment plant to be constructed larger to meet the increasing demand that the revised rate could place on the system.

Last I heard, we were using up to 15 million gallons per day in mid-summer, and the plant has a capacity of 20.  The new plant is supposed to be at least 20 million gallons as well.  It can probably handle what we would do under a pricing-to-sell system for quite a few years.  It will take time to get people back into the watering habit.  The more infill we build, the less property is available to water, as more is taken up by pavements and buildings. 

Preventing the need for a new plant was probably on the minds of the Manager and Council when the change to tiered rates was started in 2005, just before the Great Recession hit.  But it started falling apart before ten years had passed, and now we will build a new one.

The eventual need for expansion is why we are supposed to be planning for easy expansion with the new plant.  Under a system that pays the overhead only from base rates, we can do it without making customers go dry or go broke.  Under a system that has only one unit rate, we will once again pay the same unit price for the water we use, and the same within our service size to have a water plant.

So, let us write a new water conservation plan for our new water plant that features using our water, keeping it circulating in and over the land, rather than losing so much of it to the ocean.  Pass water and sewer rates that price water to sell and price sewer fairly so everyone can afford water their yards and everyone again pays the same charge for sewer within their service size.  And build a new water plant that we can easily expand as needed.
                                                                                                                                         

1.       Ben Godfarb, Eager: the surprising, secret life of beavers and why they matter, Chelsea Green Publishing, White River Junction, VT, London, UK, 10, 103, 110-114, 165, 170-171.

Exhibit A, page 2
work down the page to Utilities and Sanitation>Sewer rates>Sewer rates
https://www.pwd.org/rates
https://www.cityofredding.org/home/showdocument?id=10304