...irrigate? ...shower? ...drink? ...ration?
I am enjoying On The Public Record blog and got motivated by some comments in a post titled "It's almost like we're all connected somehow" to go back to an issue I raised with my local water provider in early summer. This post expands on the interchange in the comments at OTPR.
Earlier this year I raised with the CPUC some basic rate fairness issues about the proposed water rationing* scheme that would be imposed upon us, noting that there was no "floor" water usage below which rationing and penalties would not be imposed. Adding insult to injury, the rationing methodology of forcing cutbacks based on historic usage penalizes those who have been conserving all along as well. See CPUC Correspondence and Water rationing upon us.
Here's where my local water district is with conservation: Right now we're in an advisory 10% cutback phase. We've also had rate and tier changes recently to encourage conservation with price signals.
Knowing that we had recently had such changes, I went looking for the impact of my letter on the rationing policy and I found Section E of my Mandatory Water Conservation and Rationing rate schedule, effective Sept 1, 2009, does indeed have a 5 hundred cubic foot (HCF) usage floor below which there is no penalty or rationing.
Perhaps it was put there after my recent response letter to the CPUC made during the public comment period in which I noted the absence of a rationing floor.
5 HCF seems pretty far afield from reasonable given that the revenue-neutral point for my urban water district with respect to recent rate changes is 18 HCF and the upper limit of Tier 1 billing (the lowest rate) is 13 HCF. I conserve aggressively and if memory serves I'm mostly under the 13 HCF Tier 1 limit, but I'm still not very close to 5 HCF.
I suspect that 5 HCF exemption is only there to placate people who pointed out its previous absence.
And there are still deficits and inconsistencies in the rationing scheme:
1) Mandatory rationing is based on average usage between 2004 and 2006, penalizing those already conserving.
2) There is no provision for low flow watering systems such as drip. All watering systems are treated as if they are flood/sprinkler irrigation.
3) There is an inconsistency in the rationing plan in section G, where flow restrictor charges are set forth: Section G is not referenced anywhere else in the document that I could find. Maybe later stages of penalties were originally designed activate installation of a flow restrictor, but they were edited out**.
4) Penalty rates are scaled from Tier 2 rates***, not from the base rate at which the rationing violation occurred. Again, this unfairly impacts those already conserving: If you already conserve enough to be at Tier 1 rates, and don't conserve additionally per requirements, then you take a greater percentage penalty hit than someone who has to conserve within the Tier 2 rate.
So, a Pyrrhic victory at best against institutional inertia. Maybe more like a Sisyphean victory.
* As noted elsewhere, the word "rationing", as applied in the field of California water doesn't mean that you can't have more, just that you'll suddenly pay a lot more (a fine plus a quantity charge) if you cross a usage threshold.
** G. FLOW RESTRICTOR CHARGES
The charge for installation of a flow-restricting device shall be:
Connection Size Charges
5/8" to 1" ..... .. , . .. . ... .......... ... .. ........ $100.00
1-1/2" to 2" ... ... .. .. .. ..... ....... ...... '" ... $150.00
3" and larger ....... .. .... .. ... .. . ... ... .. .. .. $200.00
*** Allocation Penalty Charges for Stage 2 - 7
1. Usage within allocation ...... .... .... . .. . ....... .. .. . ....... ....... . .. ... $0
2. Usage over allocation up to 15% above allocation ... 1.5 x Tier 2 qty rate on ME-1-R Tariff
1.5 x qty rate on ME-1-NR Tariff
3. Usage over allocation by more than 15% ..... . .... .. ... 2 x Tier 2 qty rate on ME-1-R Tariff
2 x qty rate on ME-1-NR Tariff