JOHN A. MAYER

UTILITY RATE CONSULTANT

 

MEMO

 

To: Ed Nokes

From: John A. Mayer

Subject: PSC Approved Rates

Date: Wednesday, June 13, 2007

 

I spoke with Dave Sheard of the PSC today and asked him the questions in your email. He discussed this with the PSC’s legal counsel and with PSC staff member Kathy Butzlaff who performed the financial review for the rate increase. Dave called me back and basically said the following.

 

1. Your question as to “From a legal standpoint, what if they (Oshkosh) don’t approve them (the rates)” was answered by stating that the PSC has the legal authority to set rates, not the City. From the PSC’s perspective the rates approved in the official Rate Order dated May 7, 2007 are the rates currently in effect. The PSC grants municipalities some discretion in terms of when the newly approved rates are implemented; however there is no option on IF they are to be implemented.

 

2. There is no option to phase-in the increase over two or three years.

 

3. Since the new rates are considered to be in effect, Oshkosh could petition the PSC for a rate reduction; however Dave indicated a number of concerns and cautions. The staff feels that the approved rates are appropriate and needed for adequate debt service coverage. There is no guarantee that staff would support a rate reduction because of the very large amount of outstanding debt and the responsibility the PSC has to make sure that the approved rates are adequate for the financial health of the utility.

 

4. IF the City petitioned for a rate reduction (which would be accomplished by reducing the rate of return) the preliminary review by Staff indicated that they would not accept anything lower than a 5.75% return on rate base. That translates to an 11% increase versus the 15% approved.

 

5. Dave said that if the City is that concerned about the magnitude of the increase, the City should reduce the $650,000 tax equivalent it charges the utility to zero and include that with the petition to reduce rates.

 

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My feeling on the tone of the conversation is that the PSC staff does not feel lower rates are warranted. They consider it strange that the City approved the filing in December for a 15% increase and now that it has been review by the PSC and determined after staff review to be needed, that the City feels it should be reduced.

 

I feel that the Council does not understand the need of the utility to generate cash to pay for normal and ordinary capital replacements with cash generated from rates. Failure to do this will result in continued increases in debt and continued increases in rates to pay for the new debt.


OSHKOSH WATER & SEWER – FINDINGS & FACTS

 

• 28 years assisting municipalities with water & sewer rates. Water & sewer rate studies for Oshkosh for the last 21 years (1985)

 

• Recommending a water rate increase of 15%; Recommending a sewer rate increase of 18%

 

• To keep this increase in perspective, average residential customer 1˘ more for every 11 gallons of water – delivered, and 1˘ more for every 12 gallons of sewage removed

 

• 6 yrs since the last rate study. Frankly the size of the increase is not surprising to me. 3 major factors

 

• #1: Water and sewer volumes are decreasing, they are not offset by population growth, and this trend is not temporary. 2001 - present: water customers +6.5%; water sales -7.5%. Sewer customer +5.3%; volumes -9.3%

 

Aging of the population fewer people in each home. Usage per household is decreasing. Remodel w/ low flush toilets, low flow shower heads, water saving laundry appliances. Price elasticity

 

• Basically water and sewer utilities are facing a scenario of a slow but steady decrease in number of volume units sold.

 

• #2: Increases in labor and non-labor costs will continue. Merit / longevity increases. Prices for electricity, natural gas, pipe, and all other items will increase. Federal Reserve target 2%-2˝% inflation rate. No money saving technological breakthrough likely. No electronic chip to fix water main break. Can’t outsource water or sewer mains repairs nor send our water tower out for painting to some developing country with cheaper labor. Basic industries - not changed since Romans except on the treatment side.

 

• #3: EPA continue to tighten restriction on pollutant levels. Un-funded mandates will continue to drive local water and sewer rate increases.

 

• Given decreasing number of units sold (i.e. revenues) & increasing expenses, water and sewer rates will need to increase so utility can pay its bills.

 

I cannot recommend strongly enough the wisdom of a program of small, annual increases in both water and sewer rates. Delaying the increase only makes it larger and less understandable by the customer, and each year of delay makes it financially more difficult for the utility.

 

Annualized increase in net cash requirements from the last time rates were reviewed until now is 3.03% for water and 2.39% for sewer. That is why I said I am not surprised at the level of increase. No unusual changes other than industrial revenue decrease of $285K water and $250K sewer. Ponderosa Pulp & 7-Up Bottling.


 

Water Utility

 

• Regulated by the Public Service Commission of Wisconsin (PSCW or PSC). Our rate increase request will undergo a detailed financial reviewed by PSC Staff.

 

• Utility-financed water plant investment in 2001 was $71.8 MM. Now $88.5 MM. $16.7 MM in added water facilities (23.3% incr.) but no increase in water rates to pay for them.

 

• Goal - level of rates so that utility can pays all of its bills, all of its debt service, and still have a net cash flow sufficient to cash finance a “normal level” of capital expenditures without having to borrow.

 

• Excluding large construction projects in 1999, 2001 and 2005, normal level of capital is about $2 MM each year. Generating this level of cash may not be possible due to oversight by the PSC since their definition of adequate rates based on a “fair rate of return” on utility assets.

 

• PSC typical ROR of 6.50% provides cash flow that is reasonably close to the level of net cash flow that I deem appropriate. Using ROR of 6.50% the recommended increase for the water utility is $1,536,000 or 15%. This will provide a net cash flow for construction of about $1,983,000. [ROR 6.75%, rev. +$166K or 1.65%; ROR 7.00%, rev. +$332K or 3.3%]

 

• Utility needs $2 MM per year for capital projects. Recommended rates will generate that amount, but for the next 5 or so years $700,000 of that will be going for meters. Leaves only $1.3 MM for typical projects.

 

• Water debt service in 2007 = $5.1 MM; 48˘ of every dollar taken in from water bills goes for debt service. The best way to contain future rate increases is to keep new borrowing to a minimum.

 

• If utility had been able to cash-finance all water utility additions since the 2001 rate study, P&I for 2007 would be $3.6 MM vs. the actual amount of $5.1 MM. The difference of $1.5 MM is just about the entire increase recommended. Utilities with the lowest rates are those with the least debt. If revenues inadequate for capital projects, utility forced to borrow more money.

 

• The only thing to reduce increase is to request a lower ROR from the PSCW. Not recommend. Lower ROR reduces utility’s cash flow & forces more borrowing. ROR = 6.00% lowers revenues by $332,000 or 3.3%. Avg. Resid. Bill lower by $0.65 per month, 2.1˘ per day.

 

• Recommended increase will raise the avg. resid. bill $3.42 per month; 11.2˘ per day; $10.25 per quarter.

 

Switching to WASTEWATER


 

Sewer Utility

 

Not regulated by PSC. City Council action is all that is needed.

 

• Utility-financed sewer plant investment in 2001 - $57.7 MM. Now - $72.7 MM. Added $15.0 MM in sewer facilities (25.9% incr.) but no increase in sewer rates to pay for them.

 

• Not unlike water, the $15 MM over 6 years computes to $2.5 MM per year of capital additions.

 

• If I use same PSCW criteria of a 6.50% ROR, recommended increase would be 23.6%. That would provide a $654,000 cash flow + replacement fund for a total of $1 MM for capital projects. This is still short of recent historical capital project need. [In 2001 the rates provided a $542,000 cash flow + replacement fund for a total of $816,000.] [For xtra $500K, rates +6.5%; for $100K, rates +1.3%]

 

• Sewer debt service in 2007 = $4.0 MM; 51˘ of every dollar taken in from sewer bills goes for debt service. The best way to contain future rate increases is to keep new borrowing to a minimum.

 

• If utility had been able to cash-finance all sewer utility additions since the 2001 rate study, P&I for 2007 would be $2.9 MM vs. the actual amount of $4.0 MM. The difference is $1.1 MM. [79% of the entire increase].

 

• While I feel that 24% increase is the better financial choice and might be too low, concerned about the “sticker shock” of a 24% increase resulted in somewhat of a compromise recommendation.

 

• Suggesting that Oshkosh consider reducing the net cash flow target from $654,000 to $239,000 (decrease of $415,000) with the understanding that rates be reviewed in 2 years and most likely increased to a more appropriate level. “Bare bones” increase, but OK in the short run due to the existing cash reserves ($7.2 MM in unrestricted cash).

 

• Recommended sewer revenue increase of $1,400,000 or 18%. Cannot reduce any more do to concerns about meeting bonding agreement coverage ratio.

 

• Recommended increase will increase avg. resid. bill $3.12 per month; 10.3˘ per day; $9.36 per quarter.

 

• Combined water & sewer avg. resid. bill $6.54 per month; 21.5˘ per day; $19.61 per quarter.