HomeMy WebLinkAboutMemo - Mail Packet - 8/4/2020 - Memorandum From Gretchen Stanford And Abbye Neel Re: Allotment Administration Interpretation - Policy City Code Section 26-149(E)
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222 Laporte Ave.
PO Box 580
Fort Collins, CO 80522-0580
970.212.2900
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utilities@fcgov.com
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M E M O R A N D U M
DATE: July 23, 2020
TO: Mayor Troxell and Councilmembers
FROM: Gretchen Stanford, Interim Deputy Director- Utilities Customer Connections
Abbye Neel, Water Conservation Specialist
THROUGH: Darin Atteberry, City Manager
Theresa Connor, Interim Utilities Executive Director
RE: Allotment Administration Interpretation - Policy City Code Section 26-149(e)
Bottom Line
The purpose of this memo is to create a process for how a key Water Utility Code, related to water allotments for
non-residential customers, is interpreted and applied. The proposed interpretation will impact approximately 450
non-residential customers annually.
Background
All non-residential water taps issued after March 1, 1984 have an annual water allotment based on the water
supply requirement that was met at the time of development. Non-residential taps installed prior to this date do
not have an annual allotment. Currently, 40% of Utilities non-residential customers have an allotment.
Customers with allotments receive Excess Water Use surcharges in the event their allotment is exceeded in any
calendar year, however those customers who do not have an allotment are not subject to these charges. This
disparity limits Utilities’ planning ability and resources used to support water supply infrastructure needed to meet
water demands.
Section 26-149(e) was enacted in Ordinance 116, 2017 to rectify the disparity between the number of non-
residential accounts with and without allotments. Section 126-149(e) states that “[i]n the case where existing
water service to a property is being changed or a new water service permit is being issued, the utility shall assign
an annual allotment and credit the nonresidential user towards the new water service permit.”
Based on this section of code, allotments can be assigned to customers when the “property is being changed” or “
a new water service permit is issued”, however questions have arisen regarding how to interpret this section of
code to fairly, consistently, and equitably assign allotments in these scenarios. This administrative policy provides
guidance for:
What constitutes as a change to a property that results in an allotment assignment?
What constitutes as a new water service permit that results in an allotment assignment?
Interpretation
In coordination with the Planning, Development, and Transportation Department the impact to current processes
and customers were assessed to define an equitable policy interpretation. Based on this analysis the following
scenarios will trigger review of an account and potential assignment of an allotment:
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7/27/2020
Acting Deputy Director
7/29/2020
7/29/2020
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What constitutes as a change to a property?
o A property that is associated with, requires, and/or results in any development review process
under the Land Use Code;
o A property that is associated with or results a need for any Commercial General Alteration permit
under City Code or the Land Use Code where there is an increase in fixture units or water use; or
o A property that results in a change of the Fort Collins Utilities’ classification from residential-to-
commercial billing use type.
What constitutes as a new water service permit?
o New construction, i.e., the property or premise previously did not have water service;
o Re-development, i.e., the property or premise has existing water service and is being redeveloped
pursuant to any development review process under the Land Use Code;
o A customer is changing a water meter size;
o Additional Water Supply Requirement for a meter is purchased;
o A customer adds additional water meter(s) to an existing building;1 or
o A change of the Fort Collins Utilities’ classification of the type of the water service from
residential-to-commercial.
Benefits and Impacts
This policy interpretation benefits customers and the Utility by creating a more universal and equitable
assignment of allotments. It also allows the Utility to better plan and meet water supply infrastructure needs that
are critical to ensuring a sustainable water future for Fort Collins. Based on this policy interpretation staff expects
a maximum of 450 customers to undergo review annually. Of the 450 some will not be assigned an allotment
because they:
1. Fall outside of the Utilities Water District or;
2. They already have a water allotment.
Impacts to any customers who are assigned an allotment will be mitigated via a outreach and communications
plan, in addition to Water Conservation programs to help manage water use. Specifically:
1. Allotments and Excess Water Use surcharges will be delayed until the following calendar year to allow
ample time for customers to implement strategies to mitigate impact (e.g. if assigned in Feb 2020,
allotment and Excess Water Use surcharges will not be implemented until Jan 2021).
2. Staff has created a process to allow ample communications to customers about water management, water
efficiency opportunities and the chance to reduce impacts from any Excess Water Use surcharges in the
event the allotment is exceeded. As part of this plan, customers severely impacted by Excess Water Use
surcharges will be able to take advantage of the Allotment Management Program to receive a temporary
waiver from their Excess Water Use surcharges while a water efficiency project is implemented.
The process will be reviewed annually, with other allotment efforts, to make any needed updates are process
changes.
CC: Lisa Rosintoski, Utilities Deputy Director
Liesel Hans, Water Conservation Manager
Mark Cassalia, Key Customer Accounts Manager
Carol Webb, Utilities Deputy Director
1 See generally City Code Section 26-94.
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