| At the Nov. 27 Fall Town meeting, specific comments were presented to the Board of Selectmen to correct the detrimental water and sewer (W&S) rates that went into effect on July 1. Many residents, businesses and non-profit institutions were severely affected; many people reported W&S bills dramatically increased well beyond the 15 percent increase that was quoted by the community postcard in July; many residents stated that their bills increased by 50 percent -200 percent while other residents received increases of 18 percent - 25 percent. To be fair, everyone should pay a proportionate increase to pay for their fair share of utilizing the W&S system; clean drinkable water, sanitary sewer service and fire protection come at a price. As a rebuttal to a recent editorial letter stating, "I am writing in support of the recently implemented Longmeadow water and sewer rate system." "Higher usage customers require higher infrastructure (delivery) costs than do lower usage customers." The truth is that higher usage customers should be fairly billed proportionate to their use, not disproportionately; the ascending rate format for W&S fees is unjust and without merit. Our surrounding communities: Springfield, East Longmeadow, Agawam and Ludlow all bill W&S fees based a constant rather than an ascending rate format. The traditionally and properly accepted practice is to establish a cost-based approach and calculate water/sewer tariff components that are constant, not ascending. This new policy is inappropriate and in fact is a textbook example of undue rate discrimination. The letter went on to state, "If all the customers in Longmeadow were low volume users, the system would have been designed for a much lower capacity than it is." "Without these larger users, the costs of the water infrastructure would be much lower." The truth is that much of the pipe sizing and cost of the water piping infrastructure has everything to do with code requirements based on the number of connected plumbing fixtures and for providing fire protection and have very little to do with actual volumetric water consumption. As an example: the largest commercial water user in town may have a design peak water flow rate of only 50 gal/min while the fire protection piping requirements for a typical home could be 500-1500 gal/min. It is further stated that the infrastructure system costs are essentially constant for each customer and do not vary with increased use; the incremental volumetric use costs are actually only the marginal wholesale costs of water and sewer from the Springfield W&S Department. Since Springfield charges Longmeadow only $0.56/ccf (1 ccf = 746 gal) for water and approximately $0.55/ccf for sewer, while Longmeadow officially charges an average of approximately $1.57/ccf for water and an average of $2.10/ccf for sewer, a larger use customer provides far more revenue and actually subsidizes low use customers; there is no reason to further subsidize lower use customers by issuing sharp ascending rates to higher use customers. A constant rate format is therefore a conservation rate in its own right. An ascending rate creates an unfair level of subsidization and would not be consistent with MGL c. 41: 69B and MGL c. 83: 16 that require that water and sewer charges be "just and equitable." Furthermore, as Longmeadow's W&S accounts were recently approved at Town Meeting to be established as "enterprise funds," we are required by law to abide by the Massachusetts Supreme Judicial Court decision: "Emerson College v. Boston (1984)," that mandates that our W&S sewer fees be fairly substantiated; the revenue from one customer cannot unfairly subsidize the costs of the utilizing the system for another customer. The judges ruled that an unfair subsidization effectively becomes a "tax" and no longer a "fee" and would be illegal and contrary to Massachusetts law. As a short term solution to the W&S charge problem, it was recommended that based on the increases approved at the April '07 Town meeting, that water charges be increased from $1.33 to $1.57 (+18%) and sewer charges be increased from $1.60 to $2.10 (+31%) along with the same ANNUAL 170 ccf sewer cap to provide full funding for FY'08. Additional recommendations: 1) Correct the 28 percent+ unaccountable water consumption by fixing leaks and replacing old slow water meters (28 percent of our present total water use, over 310 million gallons per year is either leaking or not being fully metered); 2) Install radio dispatch water meters to facilitate meter reading; 3) Read meters quarterly to improve cash flow and allow customers to have feedback on their seasonal water use; 4) Implement a voluntary odd-even outdoor watering schedule policy; 5) Allow all residential customer to have irrigation water meters; the present policy only allows commercial and select residential customers to have irrigation water meters; 6) Upgrade and repair infrastructure based on sound engineering and financial practice; 7) Hold public hearings to present any proposed changes in policies or rates. As an economic good, our water/sewer system must be managed and maintained properly and remain financially accessible for maximum utilization to minimize cost. Professor Curt M. Freedman, PE, CEM Longmeadow |
