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CFGFOA Meeting Orlando, Florida March 29, 2019 Nick Smith, CGFM 1 Some Questions 1. What is Affordability? 2. How is it Measured? 3. Why Are We Discussing It? 4. How Do We Address It? 5. Will It Be Easy? 2 3 What Is Affordability? Ability


  1. CFGFOA Meeting Orlando, Florida March 29, 2019 Nick Smith, CGFM 1

  2. Some Questions 1. What is Affordability? 2. How is it Measured? 3. Why Are We Discussing It? 4. How Do We Address It? 5. Will It Be Easy? 2

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  4. What Is Affordability?  Ability to pay water and sewer bill  “Can they pay?” not “will they pay?”  Typically not referring to an individual, but a grouping of customers 4

  5. Affordability Measurement  Annual water and sewer bill compared to income  Median Household Income (MHI) is the common income measurement  Environmental Protection Agency (EPA) Guidance of 4.5% 5

  6. Measurement – Rating Agencies  Fitch – MHI, 2.0% combined water / sewer bill  Moody’s – No quantitative measurement  Standard & Poor’s (S&P) – Market Position Assessment  Uses Median Household Effective Buying Income (MHHEBI)  Takes MHHEBI and poverty level into consideration  Scores from 1 to 6 (strongest to weakest) 6

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  8. Issues with Current Measurements  The issues are not at the median  Most rates are affordable when compared to MHI  Various income distributions and poverty thresholds  Some customers do not receive a water bill directly  “Hard to Reach” customers  Typically passed on through rent  Does not take other factors into consideration  Housing  Healthcare  Other essential services 8

  9. Other Measurements  Affordability Ratio at the 20 th income percentile (AR20)  Dr. Manny Teodoro, Texas A&M  Takes into other essential household expenses, persons per household, income, and essential water and sewer service  Minimum Wage Hours  How many hours does it take to pay for essential service?  Poverty Level Income 9

  10. Issues Facing the Water Industry % Ranked Critically Ranking Issue Important Renewal and Replacement of Aging 1 Infrastructure 64 2 Financing Capital 55 Public Understanding of Water Systems and 3 Services 50 Long ‐ term Water Supply 4 50 Public Understanding of the Value of Water 5 44 2018 State of the Water Industry Report. AWWA 10

  11. Aging Infrastructure 11 Source: American Society of Civil Engineers (ASCE)

  12. Government Spending Source: Public Spending on Transportation and Water Infrastructure, 1956 to 217 . Congressional Budget Office 12

  13. Stagnant Purchasing Power Source: For Most U.S. workers, real wages have barely budged in decades. Drew Desilver 13

  14. Increasing Rates Source: For Most U.S. workers, real wages have barely budged in decades. Drew Desilver Source: 2017 Cost of Clean Water Index . NACWA 14

  15. Views on Water “The human right to water entitles “…the right to safe everyone to sufficient, safe, and clean drinking acceptable, physically water and sanitation as accessible and a human affordable water for right that is essential for personal and domestic the full enjoyment of uses.” life and all human rights.” ‐ 2010 United Nations General Assembly Resolution 15

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  17. Customer Assistance Programs  EPA defined CAPs  Bill discount  Flexible terms  Lifeline rates  Temporary assistance  Water efficiency 17

  18. Who Benefits from CAPs?  Typical customers targeted by CAPs  Low ‐ income (most common)  Customers Undergoing Hardship  Senior citizens  Disabled  Military 18

  19. Opportunities of CAPs  Ability to retain customers  Consistently collecting lower sales revenue as opposed to infrequent collections  Cost avoidance  Collection of bad debt, arrearages, etc.  Shutoff costs, labor, etc.  Addresses potential political opposition  Rate increases less likely to disproportionately affect low ‐ income customers with a program in place 19

  20. Challenges of CAPs  Process may be confusing for customers  May need additional outreach and education  May reduce signaling for water conservation pricing  Balancing revenue stability with eligibility and targeting  Increased social burden for utility staff  Funding 20

  21. Legal Pathways  2017 study completed by the Environmental Finance Center at the University of North Carolina at Chapel Hill  Navigating Legal Pathways to Rate ‐ Funded Customer Assistance Programs  Created as a roadmap to help utilities navigate the legality of funding CAPs through rates 21

  22. Noncommission‐Regulated Utilities Source: Navigating Legal Pathways to Rate ‐ Funded Customer Assistance Programs: A Guide for Water and 22 Wastewater Utilities

  23. What Are Our Options?  Introduce legal language that expressly allows rate ‐ funded CAPs  Argue why a CAP is not affected by limitations / challenges  Use another funding method  Donations, round ‐ up policies, etc.  Tax revenues / general fund 23

  24. “Express Language” Example  DC Water and Sewer Authority  D.C. Code § 34 ‐ 2202.16(b ‐ 1)(1) ‐ (2)  “…shall offer financial assistance programs to mitigate the effect of any increases in retail water and sewer rates on low ‐ income residents of the District, including a low ‐ impact design incentive program” 24

  25. “Not Affected” Example  City of Atlanta Department of Watershed Management  Atlanta City Code §6 ‐ 306,  Authority to “annually appropriate and donate money, derived from taxation, contributions, or otherwise, for and to any corporation, company, association, or institution for purely charitable purposes.”  Georgia Supreme Court case law supports business case 25

  26. 2018 Federal Poverty Level (FPL) Number of Children Family Size None One Two Three One Person $13,064 N/A N/A N/A Two People 16,815 17,308 N/A N/A Three People 19,642 20,212 20,231 N/A Four People 25,900 26,324 25,465 25,554 Five People 31,234 31,689 30,718 29,967 Source: U.S. Census Bureau 26

  27. Case Study #1 – Detroit  Water Residential Assistance Program (WRAP)  Assistance up to $1,000 per household  $25 monthly bill credit  Home water audits  Home repairs up to $1,000  Must be at or below 150% of poverty threshold 27

  28. Case Study #2 – Philadelphia  Tiered Assistance Program Upper Limit Monthly Percent of FPL Bill (TAP) 50% 2%  Water bill based on income 100% 2.5% compared to federal poverty 150% 3% levels  Various other programs  Zero interest loans on repairs  Conservation assistance  Payment agreements 28

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  30. Types of Charges  Account Charge  Billing and customer service related charges  Base Charge  Accounts for fixed costs associated with capacity, peak flows, etc.  Variable Charge  Accounts for costs that vary based on quantity of water used and other costs not included above 30

  31. Fixed Charges  Fixed charges promote revenue stability  Does not fluctuate with consumption  Rating agencies view higher fixed charge recovery as a strength  Some utilities use minimum charges and include a flow allowance within the base charge  Higher fixed charges may disproportionately affect low ‐ income customers 31

  32. How Utilities Respond to Cost Recovery Needs Rank Category Response ‐ % 1 Shift more of cost recovery to fixed fees 33 2 Change in growth related fees 25 3 Shift to increasing block structure 16 4 Increasing financial reserves 14 5 No changes 11 5 Implement rate stabilization reserves 11 6 Revenue diversification 6 7 Incorporating seasonal rates 5 8 Shift to decreasing block structure 2 Source: 2018 State of the Water Industry Report. AWWA 32

  33. Typical Rate Structures  Decreasing block  Uniform volumetric  Increasing block  Increasing ‐ decreasing block  Flat rate 33

  34. Rate Structure Survey Rank Rate Structure Response ‐ % 1 Increasing block 50 2 Uniform volumetric 29 3 Decreasing block 16 4 Increasing ‐ decreasing block 4 5 Flat Rate 1 Source: AWWA Water and Wastewater Rate Survey 34

  35. Increasing Block Structure  Promotes conservation  Lower priced initial block  Certain levels of use are quasi ‐ fixed so a portion of fixed charges may be allocated to variable  High consumption customers contribute to increased fixed costs over time  Allows low ‐ income and low use customers to affect their bill  May reduce revenue stability if conservation signals are followed 35

  36. Water Budget Rates  Form of increasing block rate structure  Based on estimated water needs of the particular customer’s efficient use  Charged based on efficient and inefficient use  Two customers could pay different amounts for same use  Requires more customer data  Often more costly to implement 36

  37. Lifeline Rates  Another form of increasing block structure  Subsidized first block to cover basic water needs  Often priced below marginal cost  Low income does not necessarily mean low use  Can apply to all of the residential class  Not targeted to low ‐ income customers 37

  38. Using Data – Detroit  Shutoffs have an inverse relationship to income  Inability to pay increases, but at a decreasing rate when comparing total bill to income  Link between income and usage  Low income customers had low usage  Case to be made for increasing block structure  Lower first block rate directly reaches low income customers 38

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