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HomeMy WebLinkAbout1998-042 Wastewater connection rates • . ORDINANCE NO. 98- 4 2 AN ORDINANCE of the City of Yakima relating to wastewater connection charges; amending Chapter 7.58 of the City of Yakima Municipal Code; and providing for related matters. WHEREAS, the City of Yakima (the "City ") is authorized by RCW Title 35 to acquire, construct, own, operate, and provide financing for systems of sewerage, and to establish rates, fees, and charges therefor; WHEREAS, the City Council determines that it is in the best interests of the citizens of the City that ordinances related to such systems of sewerage, wastewater rates, fees, charges, and related matters be amended as set forth in this Ordinance; and WHEREAS, the City Council determines that the rates, fees, and charges contained in this 411, . Ordinance are fair, just, and reasonable; NOW, THEREFORE, BE IT ORDAINED BY THE CITY OF YAKIMA: Section 1, Chapter 7.58 of the City of Yakima Municipal. Code .is hereby amended to read as follows: Chapter 7.58 WASTEWATER. CONNECTION CHARGE Sections: 7.58.030 A. Connection to the wastewater system -- Connection charge imposed. 7.58.050 Base Treatment Plant Charge. 7.58.060 Base Trunks /Interceptors Charge. 7.58.070 Base Collection Pipes Charge. 7.58.075 Maximum Lot Size. 7.58.090 B. Recalculation of Charges. • September 16, 1998 1 7.58.030 Connection to the wastewater system -- Connection charge imposed. A connection charge is imposed on the owner of any facility to be connected to the wastewater system when the owner of the facility to be so connected has not paid a wastewater connection charge for connecting such facility to the wastewater system, subject to the provisions below. Payment of the connection charge does not convey any ownership interest in the wastewater system. Payment of the connection charge authorizes connection only to the designated lot and is not transferable to any other lot. A. Any facility located on a lot that has participated in a local improvement district for wastewater facilities; the Final Assessment Roll of which was passed prior to January 1, 1992, September. 3, 1997, shall be assessed the capital cost recovery charge which was in effect at the time the Final Assessment Roll was passed in lieu of a connection charge; B. A connection charge shall not be imposed against any facility located on a lot that has participated in a local improvement district for wastewater facilities and has paid or is paying the capital cost recovery charge as part of its local improvement district facility assessment; and C. If prior to December 10, 1996, the owner or developer of a lot has entered into an agreement with the City providing for deferral of the payment of the capital cost recovery charge for said lot, said owner or developer may pay on or before June 23, 1998, the capital cost recovery charge that was in effect at the time such agreement was entered. If such payment is not made on or before June 23, 1998, the amount of the connection charge shall be determined by reference. to sections 7.58.040 through 7.58.090. 7.58.050 Base Treatment Plant Charge. The base treatment plant charge includes both an equitable share of the cost of the existing wastevvater treatment plant and a reasonable estimate of the actual cost of connection to the wastewater treatment plant (including costs associated with expanding the plant). The amount of this charge is a function of the amount of water flowing to the facility to be connected and the zone in which the facility is located. The treatment plant charge for single dwelling units (SDUs) is uniform within each zone. The treatment plant charge for a non -SDUs is calculated as a function of the water meter size for the facility. A charge shall be imposed for each water meter, except for any water meter installed for the sole purpose of irrigation or fire flows. The base treatment plant charge for a particular facility shall be determined by reference to the following chart: From Effective Date through Dcc. 31, 1098 -Meter --Size Zone -4 Zone -2 Zone -3 S 8771 .31 $1 ,459.81 $2,780.23 ex ( 4 ) 81,156.07 $2,189.72 $4,170.35 $1,542.62 $2,019.62 $5,560.46 nonresidential 3/4" 8491 .91 $5.67.68 $1 ,081.16 all uses 1" $1,770.86 $2,043.66 $3,802.18 211 esesrl -�" — $5,312:50 _ — $6,13G 98 $11,676.55 all uses 2" $8,264.04 $9,537.09 $18,163.52 all uses 3" —$4- 0,330.04 $11,921.36 $22,704.40 all uses 4" $13,281.49 $15,327.46 829,101,38 4 110 September 16, 1998 2 • all uses 6" 1 1 $20,436.61 $38,921.84 4-49 -9 E,; e,zz . Zone 1} Zone .2 Zone 3 SFD (3/4 ") 3-7-9-44-5 $1,503.60 $2,863.64 duplex (@ 3/4 ") 31,191.67 . 32,255.41 3-4 triplex (@ 3/4 ") 31 ,588.30 $3, 35,727.27 fiefifeSiCleft " $584.71 31,1 13.6 0 all uses 1" $1,823.09 32,104.97 $4,008.95 all uses 1.5" 35,471.37 $6,314.91 312,026.85 all uses 2" 38,511.06 $9,823.20 318,708.43 all uses 3" 310,639.95 $12,279.00 $23,385.54 all uscs 4" $13,679.93 315,787.28 330,067.12 all uses 6" 318,239.91 321,040. . 20 Meter Size Zone 1 Zone 2 Zone 3 SFD (3/4 ") 384-88 $1,548.71 32,049.55 duplex (@ 3/4 ") 31 ,227.42 $2,323.07 34,424.32 triplex (@ 3/4") $1,636.57 33,007.42 35,809.09 $521 -.86 376.0 -2.26 31 ,147.00 all uses 1" $1,878.71 $2,168.12 $4,129.22 all uscs 1.5" $5,636.13 36,504.36 312,387.65 all uses 2" 38,767.32 310,117.89. 819,269.68 • all uses 3" 310,959.14 . $12,647.37 324,087.10 all uses 4" 316,260.90. 330,960.13 all uses 6" $18,787.10 321,68.1.20 $41,292.18 From Effective Date through Dec. 31, 1998 Meter Size Zone.1 Zone 2 Zone 3 SFD (3/4 ") $591.31 $591 .31 $1,202.67 duplex . $886.97 $886.97 $1 ,804.01 triplex (@ 3/4 ") $1,182.62 $1 ,182.62 $2,405.34 nonresidential 3/4" $384.72 $384.72 $782.42 all uses 1" $1,384.98 $1,384.98 $2,816.71 all uses 1.5" _ $4,154.95 $4,154.95 $8,450.13 all uses 2" $6,463.26 $6,463.26. $13,144.64 all uses 3" $8,079.07 $8,079.07 $16,430.80 all uses 4" $10,387.38 $10,387.38 $21,125.31 all uses 6" 313,849.83 $13,849.83 $28,167.08 September 16, 1998 3 • For Calendar Year 1999 Meter Size Zone 1 Zone 2 Zone 3 SFD (3/4 ") $609.05 $609.05 $1 ,238.75 duplex (@ 3/4 ") $913.57 $913.57 $1,858.13 triplex (@ 3/4 ") $1,218.10 $1,218.10 $2,477.50 nonresidential 3/4" $396.26 $396.26 $805.89 all uses 1" $1 ,426.53 $1 ,426.53 $2,901.21 all uses 1.5" $4,279.60 $4,279.60 $8,703.63 all uses 2" $6,657..16 $6,657.16 $13,538.98 all uses 3" $8,321.44 $8,321.44 $16,923.72 all uses 4" $10,699.0.0 $1 0,699.00 $21 ,759.07 all uses 6" $.14,265.32 $14,265.32 $29,012.09 For Calendar Year 2000 Meter Size Zone 1 .Zone 2 Zone 3 • $627.32 $627.32 $1 ,275.91 _ (@ 3/4") $940.98 $940.98 $1,913.87 $2,551.83 nonresidential $408.15 $- 0 : $830.07 all uses 1" $1,469.33 $1,469.33 $2,988.25 all uses 1.5" $ • ' $4,407.99 $8,964.74 all uses 2" $6,856.87 $6,856.87 $13,945.15 all uses 3" $8,571.09 $8,571.09 $17,431.44 all uses 4" $11,019.97 $11,019.97 $22,411.84 all uses 6" $14,693.28 $14,693.28 $29,882.46 Base treatment plant charges for water meter sizes not listed above shall be established by the wastewater superintendent based upon the same methodology and data as the charges listed above. September 16, 1998 4 } • 7.58.060 Base Trunks/Interceptors Charge... • The base trunks /interceptors charge includes both an equitable share of the cost of the existing trunks /interceptors and a reasonable estimate of the actual cost of connection to the trunks /interceptors (including costs associated with expanding the trunks /interceptors). This charge is a function of the size of the lot to be connected. The base trunks /interceptors charge shall be determined by multiplying the lot area (measured in square feet (sf)) by the following rate for the appropriate zone in which the lot is located; PROVIDED that the Future element of the base trunks /interceptors charge may be waived if the lot owner or developer extends a trunk/interceptor from the existing trunk/interceptor through or along the entire length of the lot as required by the sewer comprehensive planning analysis for the area: Zonc 1 Zene -2 Zonc 3 1997 a $0.032 $0=1 -7 g 4-9-9-9 $-0 = 833 $0.176 4 2 -0-0 -0 $-0 -0•4 $-9 - 4-8-1 _ $0,-2-9-0 Zone 1 Zone 2 Zone 3 1 9 9 8 $0.036 $0.195 $0.262 1 9 9 9 $0.037 $0.201 $0.270 2 0 0 0 $0.038 $0.207 $0.278 ' III 7.58.070 Base Collection Pipes Charge. The base collection pipes charge includes both an equitable share of the cost of the existing collection pipes and a reasonable estimate of actual cost of connection to the collection pipes (including costs associated with expanding the collection pipes). This charge is a function of the size of the lot to be connected. The base collection pipes charge shall be determined by multiplying the lot area (measured in square feet (sf)) by the following rate for the appropriate zone in which the tot is located; PROVIDED that a collection pipes charge may be waived if: (a) the lot is within a collection pipe system installed and paid for by the developer of the lot; (b) the lot owner extends a collection pipe from the existing collection pipe system through or along the entire length of the lot as required by the sewer comprehensive planning analysis for the area; or (c) the lot is connected to a collection pipe system originally financed by local improvement district assessments to which contribution was made for the lot: Zone- Zone -2 Zone-3 1 9 9 7 $ $-0-.-0-8-8 $0=2-8-0 $0 1 9 9 9 $-9-0 91 $-9 -288 $-0.3-86 -0-0 -9 $-0-.49-4 4 $ 0.2 97 • • . $0=8-9-8 Zone 1 Zone 2 Zone 3 1 9 9 8 $0.078 $0.283 $0.376 1 9 9 9 $0.080 $0.291 $0.387 • 2 0 0 0 $0.083 $0.300 $0.3.99 September 16, 1998 5 7.58.075 Maximum lot size. A maximum lot size of 20,000 square feet may shall be utilized in calculating charges under 7.58.060 and 7.58.070 for Single Dwelling Units. -when the entire lot is currently . - : - - - - - - • - e - 7.58.090 Recalculation of Charges. A Improvement, change in use. In the event any facility, lot, tract or parcel is improved, or the use thereof is changed or intensified so as to increase the number or size of water meter(s), then the amount of the connection charge is subject to recalculation and increase according to Sections 7.58.040 - .075. Credit shall be allowed for the size of any existing meter(s) removed by virtue of this change or intensification, PROVIDED that, in no case shall the credit exceed the cost of the charge. Any such increase shall be paid in the time and manner specified by Section 7.58.080. B. Additional subdivision of Tots. At such time that any existing lot connected to the wastewater system is subdivided, a wastewater connection charge shall be assessed against each new lot formed. No additional charge shall be imposed upon the lot where the facilities that were originally connected are located, unless an increase in water meter size is involved. Any additional charges due as a result of subdivision shall be determined as set forth in paragraph A of this section and shall be paid in the time and manner specified in Section 7.58.080. C. As an additional and concurrent method of collection of any such delinquent wastewater connection charges, the customer service manager may suspend the water service or supply to the premises under the same authority provided in Section 7.60.100. Section. Effective Date; This ordinance shall be effective thirty (30) days after its adoption and publication as provided by law. `_ PASSED BY THE CITY COUNCIL, signed and approved this Co day of OCT -IEW , 1998. CITY OF YAKIMA, WASHINGTON / By C John Puccinelli, Mayor ATTEST: • • City Clerk Publication Date: /6-9 Effective Date: 1 ) September 16, 1998 6 4110 CERTIFICATE I, the undersigned, clerk of the City of Yakima, Washington (the "City ") and keeper of the records of the City Council (the "Council ") DO HEREBY CERTIFY: ,rr 1. That the attached ordinance is a true and correct copy of Ordinance No. cis8- 4a of the Council (hereinafter called the "Ordinance "), duly passed at a regular meeting thereof held on the Cp day of C Tc 6 R , 1998. 2. That said meeting was duly convened and held in all respects in accordance with law, and to the extent required by law, due and proper notice of such meeting was given; that a legal quorum was present throughout the meeting and a legally sufficient number of members of the Council voted in the proper manner for passage of said Ordinance; that all other requirements and proceedings incident to the proper passage of said Ordinance have been duly fulfilled, carried out and otherwise observed; and that I am authorized to execute this certificate. IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the City this day of , 1998. • City Clerk • September , 16, 1998 . 7 0 BUSINESS OF THE CITY COUNCIL YAKIMA, WASHINGTON AGENDA STATEMENT Item No. ,7 3 For Meeting Of 10/6/98 ITEM TITLE: Consideration of Resolution Adopting Revised Wastewater Connection Charge Study Update and Approving Ordinance Revising Wastewater Connection Rates and Charges. SUBMITTED BY: Dick Zais, City Manager Glenn Rice, ACM Doug Mayo, Utility Engineer CONTACT PERSON /TELEPHONE: Doug Mayo /575 -6077 SUMMARY EXPLANATION: The Wastewater Connection Charge Ordinance ( #97 -38), approved in June of 1997, consolidated the then existing Capital Cost Recovery Charge and Sewer Connection Charge provisions of the Yakima Municipal Code into a single charge. During consideration of and since adoption of that ordinance, City Council has been very • clear in its stated position that City staff should closely review its work, entertain serious public comment and, where adjustments are merited, directed that those changes be (...continued...) Resolution X Ordinance X Contract _Other (Specify) Revised Wastewater Connection Charge Study Update. Funding Source Revenues from this program would be allocated to either the wastewater collection system project fund (476) or the wastewater facilities project fund (478) APPROVED FOR SUBMIA f \ Z City Manager STAFF RECOMMENDATION: Staff respectfully requests City Council adopt, by attached resolution, the Revised Wastewater Connection Charge Study Update and approve the attached ordinance revising wastewater connection rates and charges. BOARD /COMMISSION RECOMMENDATION: 0 COUNCIL ACTION: (...continued. from front page...) brought before City Council. Wastewater staff, with valuable technical assistance by Gary Saleba, EES Consulting, Inc., and legal review by Preston, Gates and Ellis, have,, at City Council's direction, revised the Wastewater Connection Charge Study Update and Rate ordinance. This review and revision process was deemed appropriate because of the following circumstances: A) the City received its new National Pollutant Discharge Elimination System (NPDES) wastewater discharge permit in October of 1997 -- with its attendant capital obligations discussed previously under a separate report; B) the City recently adopted its Comprehensive Plan required under the Growth Management Act (GMA); and C) two years additional data was available to supplement the data set which the original report was based upon. In summary, items reviewed which affected revisions in the report submitted in February of this year and remain pertinent in the attached report and rate ordinance included: 1) revised capacity of existing treatment facility per new NPDES permit; 2) updated future "Treatment" expense due to NPDES mandates and expansio requirements; 3) updated projection of new accounts based upon adopted City Comprehensive Plan; 4) updated projection of future connected area based upon adopted City Comprehensive Plan; 5) re- allocation of future and existing trunks due to most recent GMA population projections; 6) allocated portion of existing trunkage to Zone 3; 7) update of number of existing accounts per current information; 8) update of estimated historic cost (projects not closed in 1995 at time of original report) with actual costs; 9) transfer of some 1995 future costs to 1997 historic costs (projects completed since 1995); and 10) inclusion of 20,000 square foot "cap" on residential lots for the purposes of calculating the trunkage and collection elements of the charge. At the February 3, 1998 Council Meeting, concern over the proposal was raised by Yakima County. At the County's request, the Council delayed action on the proposal to lower charges. Over the past several months, the City has held a series of meetings with County representatives and their consultants during which their concerns with the Study were discussed. In response to their concerns, the following revisions were incorporated into the attached report and rate ordinance: • • • 11) adjustment of rates to accommodate the City's current Wastewater debt service equity position; 12) update of average consumption of Inside and Outside retail residential customers per current information. In addition to the adjustment to the charges, the proposed Ordinance also address: 1) a modification to the date which cuts off Local Improvement Districts (LID's) from the old charge system (see section 7.58.030.A.) This affects a very few potential customers within some newly formed LID's.; 2) section 7.58.060 clarifies that only the future element of the Base Trunk Charge may be waived; 3) section 7.58.075 limits to 20,000 square feet the parcel size to be utilized in calculating charges for Single Dwelling Units; 4) finally, section 7.58.090. C. clarifies language. Please note that in every case, in every Zone, for each lot size illustrated, a reduction is proposed. The reduction ranges from 1.3% to 32.1% depending on Zone and lot size. However, the reduction for an average sized lot is about 10% for each zone: These revised rates represent a significant and substantial decrease while still preserving the City's objective of requiring growth to pay its own way. HISTORY: The 1987 Comprehensive Plan for Sewerage System recognized the shortfall of the existing Capital Cost Recovery Charge. That report recommended the charge be; 1) extended to "all properties connecting to the sewer system ", and 2) the rate be adjusted to accommodate trunk sewer construction to future sub basins. Neither of these recommendations was acted on at that time. The adopted 1994 Cost of Service and Rate Study proposed and, subsequent to Council approval in December of 1994, implemented a rate setting philosophy which reduced existing City Retail customer subsidies of other user classes. This updated study continues that philosophy by assigning, where appropriate, the capital costs of necessary system growth to new customers. The Wastewater Connection Charge Ordinance ( #97 -38), approved in June of 1997, consolidated the existing Capital Cost Recovery Charge and Sewer Connection Charge systems codified in the Yakima Municipal Code, into a single charge based on 1) the volume of wastewater estimated to be generated by a new connection, and 2) the area of the lot connecting the wastewater system. Rates were established for each of three geographical zones. • The intent of Ordinance #97 -38 was to ensure that new customers shoulder a more equitable share of the cost of the system and reduce City retail customer's current and future subsidy burden. Those revenues not sufficiently recovered from a connection charge program will ultimately come from another source -- monthly City user rates. City Retail rate payers had historically borne the burden of the financial under - performance of the past CCRC and Connection Charge systems. In a previous transmittal memorandum, dated June 1, 1995, staff estimated, for comparison purposes only, that City Retail rates would need to be increased 15 percent to recover the same annual revenue which this program identified it would generate given connection trends at that time. We believed, and still believe, a rate increase of this size for new growth would not be acceptable to existing customers. The conclusion, therefore, was that without the Wastewater Connection Charge program to recover the cost of new growth, we would not have sufficient resources to build the pipe and treatment facilities necessitated by growth. Current City policy directs that there be minimal subsidy of future growth by the citizens of Yakima: While we pursue funding for capital needs, these sources are very limited and uses restricted. Accordingly, growth must find a way to pay for itself. . Previous Wastewater Connection Charge proposal transmittals to City Council and th City Mangers Office have included estimated connection charges for discussion purpose The following Attachment 1 provides the latest estimates of average connection charge for the three zones when the developer constructs the collection system. The dollar amounts shown will change over time with construction cost indices (CCI) and the actual costs of facilities projects for growth related expansion. The enclosed . table "Attachment 1; Wastewater Connection Charge Comparison" provides a comparison between 1997 adopted rates, the February 1998 proposed rates arrived at through the update analysis of items 1 -10 discussed above, rates which include the debt service credit (City equity position) listed as item #11 above, and rates which include adjustment for a usage ..factor of 1.0 between Inside and Outside retail residential customers, listed as item #12 above. • • • Attach"! • • • f Wastewater Connection Charge Comparison • 1 1 1 1 1 1 1 1 1 1 1 I 1 _ The purpose of the Wastewater Connection Charge Rates Is to ensure that new customers shoulder an equitable share of the historic cost of the sum, - as well as the actual cost of the connecting. ZONE 1 ZONE 2 • ZONE 3 lot size _ Adopted proposed osed > rGi .:Equit ; ::::.::::Usage; : ::::: Adopted proposed :; City ; ;! ige? Adopted proposed ! lrqul sag P : IY Y (square feet) Jun -97 on 2/3/98 debt senn F gt;tor_ (1 0) Jun -97 on 2/3/98 d ebt'servico: Focit : (1 0 } Jun -97 on 2/3/98 debt ffiervMC9 1* idr. (1 >0) • 13' ':::::$4::•:246- . L. . ... 5 183. 77 4 740 • 8,000 51 .249.38 $1, 148.24 `:5'1;�.3�_;8�j`;�1:080 :17:: $ 3,419.92 $ 2.930.02 :;:;$2';$9 :5',60,_., 7,. S5, S . .. ,.. .:.::: ::: . : 4....:. : . • .:: » : :.: " s;z le ..:' 4:8."/0 » >; -14.3% ^'» . �8r1°1'0:: < >;;' -8.2% ::`: >'1'Q:8 ?` > : ...: % change -8.1 % . .:.: . . ..:. % chan a from proposed :0::: 0..i...1%:1-....:-...:: 5 9%;;;; : ::: :- ; 1..°/b; 1:1::(19'0::::;: 10: ::;': -1:6 O :. 9 P P� is 2<.2`Yo ' °!a'< 1 '12 . 1 !..7*........:, :. > chan a Iron adopted : . . . 4ii :396 i3 5%:.:: : : .:: 1 : : ..;: :: ;.: k : -: :23 ' :::: : :;:- change 031.85 ";::>:`:::'!>:' »' : ' 1;81k$ . 5 .. ,.:.24,..1. 0.. . 85.01 6 50 12 000 51.398.71 $1,335.44 $,.l O R >aT:' : :5'1:x252; 34 $3.933.22 :$.36d�80$3;34257: 58.0 $ 55 .. ;: >:;::.:: �• % change -4.5% • 1 % d,3% - 7 8 % 2 3% : -0.5% 8 8% : -4,S °, : 1. 6. :2 r7 9o- /<: 5:5 >i 6 . 8q % change from proposed 0 . 470 :: : :: ':'. 1 4. 5"!a< ><' -s>:. 1 55C:: : >:: >::a: 9 3%.; :; :::; .,.;-:1.3x3. %. ;. . . % a from ad x.1:9 <1 ;:._: 1 0.. : . . 9 adopted P x 7 2 0 . 4 $8,614.25 . ... ::,_0 7. $8 0 1 ... .. . 20,000 $1.897.48 $1.709.83 :::: 53fi8 $4598c57 55.884.83 $5.939 2 : $ . :487 - . _ �.:. , - $ ± :. .. * >:..4 0*:i: 0.9% >:: :.7.696:.1 .::. ` 113% ii 9.5% 6 9% '. >`:: ! >::' :: % chance 0.7% "' ..: . : ;47 ; �' >:: >. ' 89/. <::> <:::>�u 9%: >:: :; ':.:iii:;10:0 °7► • 9'. change from proposed :: �: :1Oi %:::'` >;�6. �>: 8 ; :.. ;; : : - • 8 X6..0%: rs:.';::;8 ;0% , ::::: :;: : >I:4*::: ::1 % change from adopted : >:' > 5'ib ::z:::> - ::..: : :.: - :. 9 °P - : - 7 7 0 5 :::::8 :0 1' 01 6.2 : . 1 0.5 8 814.2 801 ::..$ ' ' 10 2 9 S S 30,000 52.070.90 51, 709.83 ;;3�tg388�;;�1;598;57;: $7.938.57 $5.939.62 - $ , ... : .i ., "%:;: : g'::':: :;:;: ! : :': 1 -1 4.9% :0:'-6:9"10 _< :: -''S i - > <-- - %Cha a -17.4% :::'�j01% >'. »::;::;4,0;IP.;.; - 25.2% `s'`T:BIu:; >:._1 %. .::::.. ...: % change from propose d 10 a:�a ; :: : ..: .:: 2 0:.: >';:::; - ': >: >:; 7.89(;:: ``::'.''g ?8 %::::::: >: • - 9 P P� • */. change from adopted :' > :' X5;8 % ::s>::: 7 :6'14:;: '. " :X360.4::;>. : ::33 % >:: >:: r' ° ; :<::z.:<:::. % >;:> • Maximum lot size of 20,000 per SDU proposed. _ I F _. . . As explained In the report, parcel sIze was the criterion used to distribute costs ohs. The length (cost) of the pipes is directly related to the size of parcels served. _ Adjustments following CIty!County discussions. ` _ t _ _,- " Rates for all Zones credited for City Debt Service Equity Position. _ _1_ . _ _ _ __ _ ___ _ "' SDU usage for all Zones considered to be equal; this shall be reconsidered with each update per consumption records. I • . 9129198 •