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Attachment D <br />City of Roseville <br />Finance Commission <br />Water & Sewer Utility Rates <br />I. Introduction <br />Based on my readings, discussions with Finance Director Miller and other Finance <br />Commissioners, and observations of City Council meetings, there has been discussion about <br />the appropriateness of water and sewer utility rates, as well as subsidizing residents' bills by <br />funding capital expenditures through the tax levy. <br />Below I discuss my thoughts and suggestions, along with comparisons to my professional <br />work at the Minnesota Department of Commerce (Department) as an electric and natural <br />gas utility regulator. This is in no way intended to be comprehensive, nor a replacement for <br />further discussion or the analysis that has been provided by the City's finance staff <br />previously. <br />II. Rate Design Goals <br />There is not an exact formula for setting rates for utilities, but there are several important, <br />and often times competing, objectives that must be balanced. Below are the Department's <br />basic rate design goals for Minnesota regulated investor-owned electric and natural gas <br />utilities (IOUs):1 <br />1. Rates should be designed to provide the Company a reasonable opportunity to <br />recover all prudently incurred costs, including the cost of capital; <br />2. Rates should be designed to promote an efficient use of resources; <br />3. Rate changes should be gradual in order to limit rate shock to consumers; and <br />4. Rates should be understandable and easy to administer. <br />While there are obvious differences between the operation of electric and natural gas IOUs <br />and a municipal water and sewer utility, I see many parallels between the two. Below I <br />address each rate design goal as it applies to IOUs and then in context of the City of <br />Roseville's (the City) water and sewer utility. <br />1. Rates should be designed to provide the Company a reasonable opportunity to <br />recover all prudently incurred costs, including the cost of capital. <br />Electric and natural gas IOUs are a natural monopoly allowed by law. In the absence of <br />competition, government regulation has been used to approximate the results that would be <br />achieved in a competitive environment.2 The City's water and sewer utility differs from IOUs, <br />in that the City has alternatives to utility rates for recovery, such as the tax levy or bonding. <br />While many cities subsidize utility rates by funding capital expenditures through their tax <br />1 Page 2, Peirce Direct Testimony, filed June 5, 2014, in Xcel Electric's most recent rate case in Docket No. <br />E002/G R-13-868. <br />2 Id. <br />Page 1 of 5 <br />