Save Our Water CT opposes the proposed MDC combined water and Clean Water Project Charge discounts being offered to large corporate super-users.
 
The MDC faces real financial challenges from problems decades in the making: repairs needed for aging water and sewer infrastructure, a consent decree to clean up sewage overflows into the CT River, and an overall decrease in water consumption. For resident ratepayers, especially low-income families, increasing water rates are challenging budgets and forcing families to choose between water and other essential needs.
 
Creating a corporate discount, which applies to one super user- Niagara Bottling of California- is not the solution to challenges faced by the MDC or its low-income customers.

• Let’s be clear:  the discounts proposed add up to an overall 50%: a 20% discount for the water use and 75% for the Clean Water Project Charge (CWPC) for all water use over 600,000 gallons/day on a monthly average. The MDC does not like mentioning the huge CWPC discount, but that’s where “the real money is” for a water bottling corporation. Residents will pay $3.97/ccf for water and $4.10/ccf for the CWPC for a total of $8.07/ccf. Once Niagara hits the discounts, it will pay $3.18/ccf for water and $1.025/ccf for CWPC for a total of $4.205/ccf.
• The MDC is assuring its customers that these discounts will result in a drop in water rates of 11 cents/ccf.  This will happen if (and only if) Niagara uses their full 1.8 M gallons of water/day.  But the MDC is not telling us what the drop in rates would be if Niagara PAID FULL PRICE. These discounts could amount to as much as a $2.2 Million/yr corporate give-away to one environmentally unsound customer. And the Independent Consumer Advocate’s financial analysis indicates that the discount could actually lose MDC money.
• The issue of these corporate discounts is not an “environmental vs. an economic or social justice issue” as the MDC has tried to represent.  Niagara, a privately held, profitable corporation has already expanded without the benefit of discounts and should pay its full and fair share.  Those additional revenues could result in an even larger drop in residential rates- rather than enriching a private corporation. Furthermore, the MDC needs to consider a rate structure which provides for a basic household rate for essential needs, requiring those using high amounts of water to pay more. Access to clean affordable water is a social justice issue.
  
• The environment is a concern for all regardless of income or neighborhood. Plastic production emits pollutants into the air around low-income neighborhoods.  Diesel fumes cause spikes in asthma along truck routes. Plastic micro-particles are now entering our bodies as well as our rivers and oceans. It’s up to us all to protect our shared environment

"The Independent Consumer Advocate(ICA) submits this statement in opposition to the proposed Economic Development Rate (EDR) which is the subject of the public hearing of February 24, 2020. All of the evidence currently available demonstrates that the EDR will not produce additional revenue for the MDC.  In fact, based on the evidence available, the EDR will reduce revenue from the only customer in any position to take advantage of this rate and as a result, increase the revenue which must be raised from other customers.

The ICA agrees that a major driver of the 2020 water rate increase is the decrease in sales.  It articulated the reasons for this decrease in its December, 2019 statement regarding the proposed rates for 2020.  Further, the ICA supports measures, including rate design, which encourages the prudent use of additional water by existing and new customers which increases water revenue.  The current proposal, however, risks existing revenue and if anything, is likely to exacerbate the conditions which led to the 2020 water rate increase.

The current proposal establishes a threshold for a discount at 600,000 gallons a day or 802ccf.  This is an increase from the original proposal set by the Revenue Committee of 500,000 gallons a day.  (The ICA submitted a statement regarding the original proposal indicating that it put over $200,000 of revenue at risk based on consumption in the first 11 months of 2019. Shortly thereafter, this new proposal was submitted to the Public Works Committee). Based on the revised numbers, and with consumption through January 2020 now available, this new proposal puts at risk approximately $115,000 of revenue.  That is, if 2020 consumption mirrors 2019 consumption, MDC will collect $115,000 LESS revenue than it did in 2019, further exacerbating the revenue shortfall.

There is only one customer who comes anywhere close to, or exceeds, the 600,000 gallon threshold.  In 2019, that customer exceeded the threshold in 6 of the 12 months of 2019.  Importantly, for the last 8 months for which data is available (through January 2020), this customer exceeded the threshold in 7 of those months.  Given that the discount for consumption above the threshold amounts to approximately 50% (water rate discount of 20% and Clean Water Project Charge discount of 75% produces a weighted average of approximately 50%.), the MDC will lose $115,000 in revenue if 2020 consumption mirrors 2019.

There seems to be some belief that by giving this discount and putting over $100,000 of revenue at risk, consumption will increase sufficiently to offset this revenue loss and in fact add additional revenue.  The ‘bet’ is that if MDC gives up $100,000, it will get this much back and more by enacting this rate proposal.  The data indicates that this ‘bet’ is ill advised.

The customer eligible for the discount has been steadily increasing its consumption, without any discount.  In January 2020, for example, it increased its consumption by approximately 50% over its January 2019 consumption—711,000 gallons a day in 2020 as compared to 475,000 gallons a day in 2019.  Given that there appears to be some seasonality in consumption by this customer (based on 2019 data), it makes sense, before betting $115,000, to at least get data from the summer months in 2020 to determine if this level of  increase in consumption continues without the discount.  For example, if there were an increase in August consumption comparable to the 50% increase in January, the result would be an average consumption of over 1.3 million gallons a day—about the capacity of the currently installed production equipment. 

The data that currently exists strongly indicates that this customer’s consumption of water is not price sensitive.  That is, its consumption is not based on price.  Of course, this doesn’t mean that other customers are not price sensitive and that there are not rate designs that could encourage prudent, increased water consumption.  The data simply indicates that for this customer, price does not appear to affect how much water it uses.

Before betting $100,000 of revenue that will have to be made up by other customers, the MDC needs some data, some evidence, that the bet will prove worthwhile.  The available data for the current proposal indicates just the opposite.  The MDC should reject the proposal at this time."
 
Respectfully Submitted
 
David Silverstone
Independent Consumer Advocate

1. Reality of Drought Regulations: Last week (2-3-2020), the M.D.C.'s C.E.O. tried multiple times to sidestep a question of mandatory reduction in Niagara water use during drought. MDC could TALK with Niagara and could PLAN for shutdowns, but it has no authority to prioritize water use during drought triggers. MDC’s own Water Supply Plan indicates that mandatory industrial limits would not occur until its reservoirs are at 10%!  So, while residents will be asked to conserve, lawn watering will be prohibited, and municipal use curtailed, bottles will be leaving the watershed and the state. If the MDC is SO sure that there will NEVER be drought restrictions, why did it furiously lobby against sensible state regulations state regulations to require a renewable permit based on safe yield and to limit water bottling once residential restrictions went into effect? In CT, all water transfers of more than 250,000 gallons/day of water out of watersheds in pipes require permits- but not those done by trucks!

2.  Realities of the Rate Discounts: The M.D.C.'s C.E.O represented- at last week’s board meeting and in the press -that an increase of Niagara’s water use to its max of 1.8M gallons/day would result in a water rate decrease of 10 cents per ccf to all customers & therefore, be a very good deal. It assumes that Niagara’s water usage would increase 1.2M gallons/day or 1604 ccf/day (1 ccf = 748 gallons) for 363 days/yr.

If Niagara were to increase its water use by THAT much (1604 ccf/day for 363 days = 582,354 ccf/yr), here’s what MDC revenue would be WITHOUT DISCOUNTS:

• 1,200,000 gallons/day= 1604 ccf/day for 363 days of operation =582,354 ccf/yr
• Water at $3.97/ccf + CWPC at $4.10/ccf= $8.07/ccf * 582,354ccf/yr = $4,699,697 or nearly $4.7M/yr

 
If MDC offers Niagara BOTH a 20% water rate discounts and a 75% CWPC discount (based on sending out 75% of its water in bottles and only ~25% into the sewer), here are the figures:

• 1,200,000 gallons/day=1604 ccf/day for 363 days of operation = 582,354 ccf/yr
• Water at $3.18/ccf + CWPC at $1.025/ccf =$4.205/ccf * 582,354ccf/yr  = $2,448,798 or nearly 2.5M/yr

The corporate “give=away” to Niagara could be $2,250,899 or $2.25 Million PER YEAR! This to a corporation that permitted its 3rd line in Oct. 2018 and already runs it profitably without discounts. There has been no application for a 4th bottling line.

And, if there is NO increase of water use and discounts are given for water over 600,000gallons/day, MDC could stand to lose $116,000/year ($116,000 - $23,000 from water, $93,000 from CWPC).

The additional income MDC is expecting from ordinance changes for their one super-user are at best speculative.  These discounts, narrowly constructed for just one industry, are not economic development rates and are not the solution to long term rate increases.  They will not offset the ever-increasing bills MDC’s projects into 2060.  Revenue generated by the sale of Class A water to bottlers should be fully used to subsidize residential rates or water assistance programs, not corporate profits.