Showing posts with label City Council. Show all posts
Showing posts with label City Council. Show all posts

Sunday, June 8, 2025

A Proposed Charter Amendment: Utility Bills; Principles of Rate Setting; and Contingency Funds.

 


Our "falling apart" water treatment plant, about two blocks from the place we will be building a new one this year because of lack of maintenance early in the rationing-rate system.

Section 1. UTILITY BILLS: Only water and sewer charges shall be on City of Grants Pass utility bills.  Failure to pay City Utility Bills shall be the only reason to shut off water except for infrastructure maintenance, ordinances to the contrary notwithstanding.

      

Section 2.  PRINCIPLES OF RATESETTING:

 

A.    Monthly base rates for water shall pay all overhead, expenses that do not rise and fall with the volume of cleaned water produced.  Base Rates shall be based proportionally on water service size, per connection.  Base rates shall rise by actual inflation of the previous year’s overhead costs over the year before.

 

B.     A single unit rate for water shall pay for all unit costs, which rise and fall with the volume of cleaned water produced.  Water unit rates shall be total unit cost the previous year, divided by the number of total units produced the previous year.

 

C.     Base rates shall cover all sewage treatment costs, with rates to be based proportionally on sewer service size, per connection.  Sewer base rates shall rise by actual inflation of sewer costs in the previous year over the year before.

 

D.    Bulk water haulers shall pay the ¾ inch base rate per month, plus the city’s unit rate times 1.336 per 1000 gallons, to make all unit rates equal per gallon.

 

Section 3.  CONTINGENCY FUNDS

A.    Overhead and unit cost expenses shall include separate contingency funds to cover actual inflation of expenses during the year for each utility.

 

B.     There shall be a separate contingency fund for maintenance of infrastructure for each utility.

 

-end-

 

 

 

 

Talk or write to your Mayor and City Councilors

About putting this proposed Charter Amendment on a special election ballot ASAP.

 

Mayor Clint Scherf                                                      541-450-6000              cscherf@grantspassoregon.gov

 

Councilor Rob Pell                    Ward 1 NW                451-476-7578              rpell@grantspassoregon.gov

 

Councilor Indra Nicholas           Ward 1 NW                541-450-6000             inicholas@grantspassoregon.gov           

Councilor Rick Riker                  Ward 2 NE                 541-479-7333              rriker@grantspassoregon.gov

 

Councilor Victoria Marshall      Ward 2 NE                 541-450-6000              vmarshall@grantspassoregon.gov

 

Councilor Eric Schoegl               Ward 3 SE                  541-450-6000              eschoegl@grantspassoregon.gov

 

Councilor Seth Benham            Ward 3 SE                  541-450-6000              sbenham@grantspassoregon.gov

 

Councilor Joel King                    Ward 4 SW                541-761-7538              jking@grantspassoregon.gov

 

Councilor Kathleen Krohn         Ward 4 SW                541-450-6000              kkrohn@grantspassoregon.gov

 

Mayor and Council@grantspassoregon.gov

 

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


Monday, October 25, 2021

Asking public servants to ignore the law

Yesterday, I got a call from a person who was totally frustrated with the way the City Council doesn’t listen to her and her neighbors when asked to not allow the Sobering Center and now Foundry Village to be built in their neighborhood. She was also upset that the public were told to not speak about the very reason they were at the meeting, not wanting drunks and homeless people in their neighborhood. She was saying that they never listen, so why should she complain about our water and sewer rates?
Land use hearings always have specific criteria that one can speak to, and outside of that, they cannot rule. They give the rules in the introduction and the applicable criteria in the presentation. That you don’t like the kind of people that use a service in your neighborhood isn’t allowed in the criteria.
Last night, there was a delegation of 8-10 people with a couple of speakers who implored the City and Council to enforce the city code against camping in parks, so regular taxpayers can enjoy them. Several Councilors explained that their hands were tied by state and federal law as well as a court order to allow nightly camping in all parks but the All-Sports Park and are not allowed to evict campers for violations of code or camping rules without 72-hour notice. The city is being sued for criminalizing homelessness with camping bans.
You want the Council to listen to you? Don’t ask them to ignore the law. On the few occasions when they have listened to people who didn’t want certain people in their neighborhood, they have been overruled by the Land Use Board of Appeals (LUBA).
In the case of campers in the parks, if the City ignores the court, it will be found in contempt of court and likely lose their case. We will probably have to put up with campers in our parks until the city builds sufficient shelters to meet their need.
One Councilor keeps pointing out that little houses, small pallet shelter campgrounds and a warming center will not meet the need and not get campers out of our parks. All of them will also have restrictions on who can use such shelter beyond being peaceful and law-abiding, because they are limited and people in the neighborhood don’t want those without shelter lining up early to get in.
What can meet the need is a couple of large hostels, cheap places to shower and sleep for $5-$10 per night, one for families and one for adults only, to keep kids separated from sex offenders. Think of a building like a grocery store with a large open space where there would be hundreds of cots, 6 feet apart, surrounded by: bathrooms; showers; lockers; a dog kennels; a meeting rooms for classes; a reading/dining room; and a parking lot planted with fruits and vegetables in planting strips, all fenced for use only by its customers. No food service, and few rules: be quiet and peaceful; don’t show anyone your guns or drugs; don’t litter or make a mess around one’s bed. Violators could be temporarily or permanently trespassed or made to pick up litter for minor infractions.
When it comes to asking the Council to reform our water rates to pay all the overhead with base rates and only marginal unit costs with unit rates, they have the power to do so. There is nothing in state or federal law that requires water-rationing rates.
You can ask by email, phone calls, writing on the city Facebook page, in person when you meet them, or a 3-minute comment at City Council meetings, first and third Wednesdays at 6:00. Control your anger; don’t attack them; and speak nicely if you want to influence them. They are public servants, but they are not only your servants. Don’t expect instant action; they need a lot of people contacting them frequently to be convinced to change a rate system that has been in place for over 20 years and to buck what has been instituted in cities around the world over the last 35 years.
Join Friends of the Restwell Center to support hostels and fill out your City survey to support use of ARPA funds to build them. It’s due October 22nd. https://www.facebook.com/groups/1681019735495611



Join Ratepayers for Fair Water and Sewer Pricing on Facebook and contact the council about water and sewer rates every month.

Wednesday, September 1, 2021

Beavers changed the climate first

 


            Mankind changed the climate of North America three times, twice for the worse.  But beaver changed the climate of the Northern hemisphere before man existed, for the better.

            Beaver evolved from a digging rodent in the flat plains of Nebraska, where spring flooding was common.  They built corkscrew-shaped burrows with a rise at the bottom, which trapped air even when all was water above them.  At some point, they started building dams to keep their habitat safely flooded; to grow trees and water plants for food; and to build lodges in the middle of their ponds.  They spread across the Northern Hemisphere.

When Europeans found North America, they found beaver everywhere.  Their dams, ponds and swamps blocked every stream and most river valleys East of the Mississippi.   West of the Mississippi, they provided water for Plains Indians, their horses, and the buffalo they hunted.  They held running water on and in the land by slowing it down and soaking it in, keeping water tables high.  The trees and plants they grew pumped massive amounts of water vapor into the air, making rain.  The land was full of water and a wealth of trees and wildlife.

The wealth that most excited Europeans was the beaver themselves.  They had about run out of beaver in Europe after they figured out how to make felt from beaver fur, for hats. 

European fur traders bought beaver furs and land from the Eastern and Canadian Indians with blankets, beads, and metal tools and cookware.  As beaver became scarce from the East, it opened the land for European travel and settlement, draining ponds and swamps as beaver dams failed for lack of maintenance, leaving open rivers and flat, rich meadows for farming, travel, and industry. 

West of the Mississippi, Plains Indians would not kill beaver, as they revered them for holding water in their dry land.  So American and British Mountain Men had to do the hard work of trapping and killing beaver and selling it to the traders.

This was an ecological disaster in the West, as dams collapsed and water ran to the sea unimpeded, digging streams into gullies and dropping water tables below the reach of the trees that had grown there.  Rich grasslands turned to desert. The climate became quite dry and hot and the land poor, the first time Man changed the climate in North America.

 

Source: Ben Goldfarb, Eager: the surprising, secret life of beavers and why they matter, 2018.

 

Speech to the Josephine County Commissioners and the Grants Pass City Council, 9-1-2021

 published at GardenGrantsPass.blogspot.com

Like Ratepayers for Fair Water and Sewer Pricing on Facebook

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


Thursday, July 22, 2021

Council: Don’t waste our federal funding

 

Our old water treatment plant, still going strong, but slowly falling apart.  The new plant will produce the same amount, but will have room to expand, about 3 blocks behind that big red roof.

            In the July 13th Daily Courier, we are told that the Council is thinking of using 3 million dollars, a good third of our federal Covid relief funding, to pay for two years of rate increases for the new water treatment plant, an average of $8 per month that would not be added to our bills.  Since we use more water than average, my family would benefit more than most. 

            But such a small benefit would be hollow and temporary, compared to reforming our rate system to pay for all our overhead with base rates and charging only marginal unit costs to our unit rates, the way we used to pay for water when this city was clean, green, beautiful and safe from wildfire.  It is better to take the debt payments off our rates entirely and charge us all but the 18% paid by the Urban Renewal District in our debt payment fee.

We were told, when the debt payment fee was passed, that it would never increase and would go away when the debt was paid.  We were not told that 22% of it would go onto our base and unit rates, where it increases by inflation every year and will never go away.

Some councilors, the Courier said, want to thank essential workers for staying on the job by giving them some federal money.  This is problematic.  Which jobs are essential and who holds them?  How do you find out?  Do the relative few who are paying attention apply and prove it?  It would only cause resentment, dividing residents into classes and paying only some. 

Any money you would give to essential workers would be little compared to what they would gain when you reform water and sewer rates, making it cheap to use water and free to use sewer, like we used to.  A lot of those essential workers are sharing housing and paying more than they should for water and sewer because of water-rationing unit rates.

Housing is what you should spend all that federal money on, starting with two cheap places to shower and sleep for those without secure shelter.  With a few million dollars, you could build a couple of large hostels that can house all our unsheltered residents.  They would be sustainable, because they would be cheap to use, not free.  When you reform our water and sewer rates, they will be more sustainable.

 

Speech to the Grants Pass City Council, 7-21-2021, published at GardenGrantsPass.blogspot.com

Like Ratepayers for Fair Water and Sewer Pricing on Facebook

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

Wednesday, January 6, 2021

We may not need a new water plant


 

Honorable Council, Mayor and Manager,

            I was wrong.  I apologize to the ratepayers, Copeland, and all other businesses on their property.  I was wrong to support taking any part of their property to build a new water plant before all options for fixing the old plant are exhausted.

            I was taken in for years, until last week, by Staff’s assertion that the old plant cannot be fixed because the only clear well is falling apart and we can’t fix it in the time it would take for us to run out of clean water.  But how big is a clear well?  Can we not build a new one outside the present footprint of the building and use it while we fix the old one?  Then we can have two and be able to maintain each as needed.  We can proceed to fix the rest of the failing masonry while doing seismic retrofitting and then keep it maintained.  We can certainly do it for less than $81 million. 

            At Monday’s workshop, Staff went over the history of the planning for a new water plant.  A second clear well at the old plant apparently has never been considered. 

Staff did say that they considered taking several properties next to the plant to rebuild parts of the old plant while operating it, but that it would be too complicated to have to negotiate with several landowners.  As though negotiating with the Auslands, helping them and their multiple dependent businesses relocate, and paying for all that is simple or cheap?  We have been negotiating for well over a year, and now we will have to go to trial of the need to build a new plant, with full discovery, to justify taking their property.

Staff also said that they were looking at the possibility of eventually expanding the new plant to use all of our 45-million-gallon-a-day water right.  That can also be done by expansion of the old site and plant as needed.

Staff said that, of the three water-cleaning technology options for a new plant, the conventional system that we already use is the most expensive to build but is cheapest to operate.  We already have it; we don’t need to build much more of it right now. 

Operations go on forever.  Ratepayers would thank you to keep the technology that will cost us less in the long run, in that historic building that only needs to be expanded, fixed, seismically retrofitted, and maintained to last into the next century and beyond.

 Speech to the Grants Pass City Council, 1-6-2021

Like Ratepayers for Fair Water and Sewer Pricing on Facebook

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

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

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