City of San Diego Water/Wastewater Rate Study Snafu

Fixed monthly fees for utilities are all the rage in the City of San Diego. Trash/Recycling came first, then SDG&E, and now Water/Wastewater.

Most utility rate increases and especially fixed fees announcements in the City of San Diego are accompanied by an incantation to the effect of "we are simply passing along what others are charging us and not making a profit." The recent proposed rate adjustment to Water/Wastewater rates in no exception. This approach lets the City off the hook for having its consultants do a defensible study and rate design which passes the Proposition 218 test.

Specifically, not all "fixed" charges levied by San Diego County Water Authority (SDCWA) should be passed along on the basis of meter size. It turns out that SDCWA levies only one charge (Infrastructure Access Charge) that is based on "meter equivalents" aka meter size. Others are based on member agencies' long term average water use and should be passed along as volumetric charges. It can be debated if Customer Service charge should be passed along as a fixed fee. Not by meter size, but a fixed fee nonetheless.

The City's faulty Rate Study, as it currently stands, discriminates against property owners who have meter sizes greater than 1". As an aside, many meters in the City are 1" but they connect to a 3/4" inch pipe on the home side, effectively making the supply a 3/4" one, blowing up the argument that the household "could" use higher amount of water than smaller size meters. In addition, the Rate Study perpetuates the tiered HCF volumetric rate structure which is already a subject of lawsuits where the City is so far losing in the Courts. Not making this up.

While all this requires study of details that are beyond a regular customer's comprehension, high paid consultants doing these studies should be required to do just that. The City's consultants who did the 2026 Rate Study obviously failed in this regard. And the City is poised with the argument that if the majority of property owners don't object/protest (they won't), the City Council will rubber stamp what the consultant did. Predictably, lawsuits will ensue and the City will waste, and pass along, more fixed charges....

At the very least, the consultants and the City of San Diego could have looked at how a sister agency (Sweetwater Authority of Chula Vista) is passing along the same "fixed" charges, They allocated them on a technically sound study without, I suspect, hiring an expensive consultant to muddy up the waters. Sweetwater correctly passed the IAC as a fixed meter charge, scaled by the size of the meter, and clearly shows in their rate design how other charges flow to volumetric (per HCF) charges.

I have sent in my protest and written objection in time (the deadline is September 15) and preserved my right to legally challenge this faulty rate adjustment if passed.