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can defend using them as proxies for the relative burden of costs imposed on the system by different <br /> user classes. <br /> 2. When costs increase, either because new infrastructure is needed or the costs of upkeep of the <br /> assets in place have increased, under normal conditions (like a uniform increase in demand across the <br /> user types), using the same standard cost allocation method would be fair. <br /> 3. However, under such normal conditions, using the same algorithm correctly would lead to <br /> proportionate increases in the additional costs across user classes. Just like the mayor, almost none <br /> but few believed bill increases for different customers would differ widely from the 30%total targeted <br /> revenue increase for the first year. Common sense intuition and rigorous math align with this expected <br /> outcome. <br /> 4. Since we have confirmed that the city's proposed rate increase plan using the same standard <br /> method of cost allocation is leading to a significant disparity in customer impacts across different <br /> segments, there are only three logical explanations: <br /> a. The previous rates were erroneously calculated. <br /> b. The new rates are erroneously calculated. <br /> c. The logic of using the same cost allocation method used in the past for justifying differential <br /> rates does not apply to allocating the marginal costs, driving the need for revenue or rate <br /> increase. <br /> 5. Without due diligence, I assume that Raftelis' calculations using the standard allocation algorithm <br /> were not in error. Then, we must consider why using the same allocation algorithm to address the <br /> city's needs could be flawed. Below is the 11-year data on the city's water revenues, expenses, and <br /> consumption obtained from the city's 2021 and 2022 Annual Consolidated Financial Reports. <br /> LL.POtl FOP <br /> $35.TP CLP <br /> 534,Lo ttiP <br /> �MgtMPM CALLd,I>HroSP`A,PAY �wA+(#iP!!H1L —.vATM f19HtF <br /> As you can see, the city's need for rate increases is not by a significant rise in its operating costs but by <br /> a sharp recent decline in revenues, which are caused by a significant drop in water consumption by its <br /> residents. The city's decision to rely on volumetric charges to dominate its revenue share (85%) <br /> exacerbates the problem. <br /> As you described, the peaking factor calculations are based on consumption data. Whether you use <br /> the old peaking factors based on earlier consumption data as proxies for the new cost allocation or the <br /> new data is unclear. But in either case, applying the old cost allocation method based on peaking <br /> factors, etc., doesn't make any economic sense. Filling a revenue gap using rate increases when the <br /> 2 <br />