The staff report for Tuesday’s council meeting, the final council meeting prior to the election, includes an update of the URAC (Utility Rate Advisory Committee) discussions and recommendations on water rate design, but that information seems to omit any newly-revised rates and only includes a discussion of the May 8, 2014 URAC motion.
At its last meeting on May 8, 2014, the URAC approved a motion to instruct the rate consultant to compare the following three rate structures with the primary focus on quintiles for residential water use, with additional information. Those include a Bartle-Wells three tiered rate, a seasonal pricing utilizing winter/summer rates, and CBFR.
Staff notes, “All three of the rate designs would incorporate the favorable financial changes discussed during the April 22nd Council meeting: a) reduction in the project costs of the Davis Woodland Water Supply Project (DWWSP) and b) the reduced cost of financing Davis’ share of the DWWSP. Preliminary analyses of these changes were presented to Council on April 22nd and indicate that they could result in a reduction in the revenue requirements necessary to fund the project of up to 8%.”
URAC is scheduled to meet next on June 5 and staff will return to council to discuss further water rate actions on July 8, 2014.
However, that seems to go against the specific requests from two councilmembers. Lucas Frerichs specifically requested, on Tuesday, an item regarding water rates and the discussion of rates.
Brett Lee on Tuesday specifically wrote, “The ability to discuss the rates, the rate structure, and possibly requesting a new 218 process; pretty much the full monty.”
As Mr. Frerichs wrote to Bob Dunning, “As you can see by the emails below, Brett and I have each requested that a water rates item/discussion be agendized for next Tuesday’s Council meeting. We would like the opportunity to discuss, take action on the concerns being expressed by the community re the water rates. Time is of the essence.”
When we published on Thursday, it was believed at least three and probably four councilmembers agreed.
However, what has emerged is a much more limited discussion. As Herb Niederberg, the city’s General Manager for Utilities, Development and Operations wrote to Matt Williams, “The report is limited to the current URAC activity.”
He added that the Council is unaware of the revisions to CBFR and “this path is outside the scope of the direction the Council made to the URAC.”
The Vanguard on Thursday reported on a compromise CBFR that would eliminate the prior year look back, base the supply charge on 12 months of consumption, and reduce the fixed fee on single family residences from $19.68 down to $8.25 from the current model.
Matt Williams, in a comment early this morning, noted that “the real driving force behind this was not the naysayers, but rather a woman who is totally committed to achieving the best for the community … Donna Lemongello. Donna has been tenacious in pursuing a solution to the look-back issues caused by the high percentage of renters in Davis. That tenacity paid off when she came up with an idea that would allow ‘pay as you go’ and at the same time preserve the fiscal resilience that (along with social equity) is one of the cornerstones of CBFR.”
He noted, “Once it became clear to me that her idea was not only feasible but brilliant, then the two of us began to put it through some substantial due diligence using the historical usage database that Bartle Wells used to complete the rate study for the WAC. In the process of that due diligence the additional ‘tweaks’ that are central to this solution emerged.”
“The keys to this proposed solution are simplicity, understandability, fairness, responsiveness, and fiscal sustainability/resilience. It is clearly simpler than the current CBFR rate structure,” he added. “What can be simpler than I receive my bill, and pay it, and am done with it? It is easier to understand. No look back to determine what you pay for the Supply Charge. Your usage for the current month is billed at a $ per ccf rate, and that rate is fixed for each 12-month period. As the graph in David’s article shows, it is even fairer than the current structure because the percentages of total water use and total amount paid for each usage level are incredibly close.”
Mr. Williams added, “One of the criticisms of the current CBFR is that it impairs a consumer’s ability to reduce their bill immediately after taking water conservation steps. Because of the lookback they would need to wait 12 months before the bulk of the conservation savings would hit their bill.
“That problem is 100% gone if these proposed changes are adopted by City Council. Because of the inclusion of the pay as you go feature, if you reduce your water use through conservation this month, the results of that reduction will appear in both the Variable Use Fee and the Supply Charge on the very next bill. If consumers choose to conserve, they will not have to wait 12 months for their reward for achieving that conservation. With that said, let’s give credit where credit is due. Bob Dunning has been asking for that kind of improved responsiveness from the water rate structure for eighteen months. Throughout that 18-month period, Bob was saying ‘this is good policy’ and he was/is right.”
“All of the above is achieved while preserving the fiscal sustainability/resilience that has always been a central feature of CBFR,” he concluded. “One of the keys to the emergence of this proposed solutions is that it has been a collaborative effort … and another key is that there has been a lot of due diligence applied to it in order to ensure that it is an even better solution than the one we currently have.”
However, it appears with City Hall closed today and with Memorial Day on Monday, it would be difficult to amend the item to enable the council to hear about this new rate proposal prior to the election.
At 1:35 pm on Thursday, Mr. Williams and Ms. Lemongello attempted to submit their report as a “this Citizen Submission for Inclusion in the Staff Report for the water rates item on Tuesday’s Council Meeting.” At press time, there is no such submission.
—David M. Greenwald reporting
“At 1:35 pm on Thursday, Mr. Williams and Ms. Lemongello attempted to submit their report as a “this Citizen Submission for Inclusion in the Staff Report for the water rates item on Tuesday’s Council Meeting.” At press time, there is no such submission.”
don’t understand. what do you mean attempted? and did Herb not accept it?
It’s not in the staff report right now
If Donna had suggestions regarding rate revisions, her best bet would have been to present those suggestions to the URAC that was established by the Council for that purpose. There has been much criticism directed at the Council for unrealistic agendas, poor prioritizing of topics, and inefficient use of time. To develop a parallel rate structure and expect to present it separately to the Council is an inefficient use of their time. The URAC was unaware of these proposals, per the Enterprise:
I think Donna is learning that process matters. What has been done here has led to sufficient confusion that Mark Siegler felt compelled to publicly state that he was not part of the process, implying that his participation (limited, by his description) was being misrepresented:
The Council’s agenda is full. If these suggestions have merit, the URAC can consider them and report back to Council.
Agree in principle Don but it would seem there is a time crunch with the election of new CC and Measure P…unfortunate that the URAC schedule is such that this proposal couldn’t be made to them time wise it would seem or did they try?
If Elaine Roberts Musser “knows nothing about any water rates being drafted by Williams or others” then it’s safe to assume this was not brought to their attention in a timely or effective manner.
Personally I don’t believe there is any time crunch. Candidates standing for re-election might disagree with me.
Don, your comment above again ignores the very fundamental fiscal risk of a $100 million liability.
there is serious time crunch IF you believe that measure p might have some trouble passing. there is also more serious risk of litigation here as well.
btw, how do we constantly end up with elaine roberts musser in a position of influence? did no one read her empty blather for years on this site?
Members of URAC were appointed by the council (one by each council member, then two by the council as a whole). The members of the commission elected Elaine Chair of URAC. So presumably those who work with Elaine felt she would lead the deliberations effectively, perhaps based on their observation of her in that role on the WAC.
which leads me to question their judgment
SODA, any time crunch that exists has nothing to do with the Council election. It has to do with the very clear actuarial risk that the City of Davis will take on if Measure P passes. Passage of Measure P will almost surely (in my opinion) begin a legal process that either forces Davis to withdraw from the surface water project, or Davis to incur tens of millions of dollars of increased interest expense, or both. If Davis is legally forced to withdraw from the project, the contract with Woodland and CH2MHill specifies that Davis will be liable for all the redesign costs for a Woodland-only plant, all the construction change order costs, and all the change in annual plant operations costs. That will amount to tens of millions of dollars. The lending institutions will see massively increased fiscal risk if Measure P passes and the interest rate on any borrowing by Davis will skyrocket, which will lead to significant recurring annual cost for Davis ratepayers.
If Measure P truly is about accomplishing “fair rates” then the fact that we have accomplished “fair” rates should be a cause of celebration.
JMHO
“If Measure P truly is about accomplishing “fair rates” then the fact that we have accomplished “fair” rates should be a cause of celebration.”
i get that you take that plank from them, but measure p is about killing the project. you know it. i know it. the davis people know it.
DP, based on my extensive canvassing as part of the City Council election I have had the opportunity to talk with thousands of Davis residents, and for many of them Measure P is not about killing the project, it is about fairness, and they are not at all convinced that the rates as they currently exist are fair. The reasons expressed by those many voters have fallen into the following categories:
— The “look back” means people will be paying for water that they didn’t use personally themselves.
— The “look back” is confusing.
— The “look back” prevents me from being immediately rewarded for any water conservation steps I take.
— Basing the proportional sharing of capital infrastructure costs on 12-month usage is fairer than 6-month usage.
— Using 6-month usage is confusing. Using a whole year’s usage is not confusing.
— If I am using X percent of the water, I should pay that same X percent of the fees (revenue).
— It would be fairer if responsible water users who use lower amounts of water also have lower fixed fees.
— Basing fixed fees on meter size seems unfair … but I’m not sure what method for billing fixed fees would be fairer.
Do you think those issues do a good job of defining the rates fairness challenges?
Please note that “Fairness means killing the plant” is nowhere to be seen in that list.
I agree with Matt here. I think the “killers” are exploiting this other reasonable complaints to stop the entire project. So, if these reasonable complaints can be resolved quickly, the killers will lose that exploitation lever.
Matt, it’s very hard for me to judge whether something is “fair” without knowing what it is — and with all due respect to you and the rates creator (Debra?), I have yet to see a detailed description of how those rates work. I get that there is a fee based on usage, and a supply fee (the numbers of which I saw elsewhere; I don’t remember them offhand), but the phrase “base the supply charge on 12 months of consumption” confuses me. If you are not basing the rates on last year’s usage (which you and David G. have made clear you are *not*; see the clause previous to the one I quoted), how *exactly* do you calculate this portion of the fee? Can you point me to a description of the new proposed rates detailed enough so I can take my past few water bills and see what the change in rate would be? If I can do that, then I will understand the formula for computing rates well enough so I can decide if I think it is “fair”. But as of now, I don’t find the new proposed rate formula transparent at all, so I have no data to agree with that claim (not conclusion) that you make.
Polly Ticks: I have posted the report that Donna and Matt sent to council. hope that helps:
https://davisvanguard.org/citizen-submission-for-inclusion-in-staff-report/
David, nope — thanks for posting it, but it glosses over the computation of the Supply Charge completely. Examining the first two bullet points, which discuss the Supply Charge, the document says “if you used 5 ccf of water then your bill would include a Supply Charge for 5 ccf of water”. Great. Now, is that charge $5 or $500? What you posted does not make that clear, and it’s critical for me to understand the rates. I can’t work with them if I don’t know how much one part of them will cost!
And it’s actually worse than that. The second bullet point says “The Supply Charge will be annualized based on each month’s consumption rather than the six summer months of consumption.” What does “annualized based on” mean, exactly? How will this be done?
It’s quite aggravating to be told a proposal is “fair” and everyone should be happy, when the proposal is not made clear. I think that’s what has me so annoyed. If there is a “fair” proposal, state it clearly, please.
Polly, right now “that charge” is $0.32 times the aggregate summer usage billed twelve times in arrears the following year. So, 3 million ccf times $0.32 times twelve billing periods = $11.42 million in total. The new computation will be 4.5 million ccf times $0.22 times twelve billing periods = $11.42 million in total.
At the account level, since the pay as you go concept has you pay all 12 billing periods in one payment, the “charge” you pay per ccf will be $0.22 times 12 ($2.64 in total).
——————————–
The aggregate Variable Use Fees currently are 4.5 million ccf times $0.86 per ccf = $3.87 million
In the proposal, all monthly usage up to and including 20 ccf per month is proposed to be billed at $0.50 per ccf = $2.25 million.
All the monthly usage at the level of 21 ccf and above is proposed to be billed at $1.90 per ccf = $1.62 million (2.25 plus 1.62 = 3.87)
Low water use (20 ccf per month and lower will save $0.36 for every ccf they use. That means an account that uses exactly 20 ccf per month each month will save $7.20 per month under the proposed rates when compared to the current rates.
Matt, I still do not understand. As I read the above, the Supply Fee is $2.64 per ccf. Now, do I pay that each month for that month’s ccf usage? If so, where do the 12 billing periods come in? Your explanation is confusing to me because you are conflating the cost to *all* people with the cost to an individual (unless you mean each water user will pay $11.42 million, which gives me a huge problem!). Can you explain clearly what the formula is, *for an individual*?
Polly, I used aggregate for a reason, so that the method of calculation of the reduction of the $ per ccf amount from $0.32 to $0.22 would be clear. In addition it made it clear that the Revenue Requirement in both cases is equal to the amount of the supply infrastructure costs.
Bringing that aggregate your monthly bill will arrive for January usage, and if you are a household that is the same as the “median” your actual usage will be 8 ccf. To get your Supply Charge you would multiply the 8 ccf times $2.64, which equals $21.12. In the “median” example, February, March April, November and December would also be 8 ccf consumption and $21.12 per month. May through October would have 17 ccf of consumption and the monthly Supply Charge would be $43.52. The total for the year would be 150 ccf (the median for all SFRs) and $396.00.
In the current structure the January through December monthly bill would be the sum of the May through October period (6 times 17 = 102 ccf) times the $0.32 per ccf rate which equals $32.84. After paying that amount each month your total Supply Charge for the year is $391.68. The difference between those two numbers is due to the inclusion of the Meter Replacement costs in the Supply Charge rather than in the fixed fee Distribution Charge.
I hope that helps.
Polly, let me try and address your last to sentences by describing what would happen each month when you receive your bill.
1) The reduced fixed fee of $8.25 (assuming you have a 3/4-inch meter) will be due and payable by the current period due date. Other than the 19% reduced amount, that pay-as-you-go process is unchanged from what exists now for the fixed fee (officially called the Distribution Charge) and the Variable Use Fee.
2) The Supply Charge that is due and payable will be calculated by taking the current month’s volume of water used and multiplying it by the $ per ccf rate. That Supply Charge amount will also be due and payable by the current period due date under the same pay-as-you-go process that exists now for the fixed fee and the Variable Use Fee.
3) The Variable Use Fee that is due and payable will be calculated by taking the current month’s volume of water used and multiplying it by the $ per ccf rate. That Variable Use Fee amount will also be due and payable by the current period due date under the same pay-as-you-go process that currently exists for the Variable Use Fee.
That is the billing process in a nutshell. Is it transparent and non-confusing?
Matt, not quite. From what you have written, I gather the “fair” proposal is to simply double what people pay for water used each month. As I read this, the Supply Charge will be equal to the Variable Use Fee. Note that paragraphs 2 and 3 are almost identical, and they are identical if you change “Supply Charge” in paragraph 2 for “Variable Use Fee” and change “that exists now for the fixed fee and” to “that currently exists for”. If that is your intent, why not simply have paragraph 2 say “The Supply Charge will be the same as the Variable Use Fee each month” and say the rates will be $1 per ccf for the first 20 ccf and $3.80 for every ccf above that? Why not be simple and direct?
Polly,
Simply doubling what people pay for water used each month would not work for two reasons.
First, right now (in aggregate) the $0.32 per ccf charge is multiplied by the 3 million ccf summer month volume, which covers the supply infrastructure costs of $0.96 million per month. If you simply doubled that you would generate $1.92 million in Supply Charge revenue each month, which is 100% higher than what is required. Similarly, if you multiply the 12 month aggregate volume of 4.5 million ccf times the $0.32 per ccf charge you generate $1.44 million per month, which is 50% higher than what is required. The correct monthly rate to generate $11.52 million is $0.22 per ccf. So each month you would multiply the actual ccf times 12 and then multiply that by the $0.22 per ccf.
Second, the reason you can not simply double the Variable Use Fee rate of $0.86 per ccf is because the variable use costs of the system as a whole are only 20% of the total, while the supply infrastructure costs of the system as a whole are 70% of the total. If, instead of doubling the Variable Use Fee you multiplied it by 4.5, you would get the correct mathematical relationship.
Donna and I are going to publish a simple, easy to understand description shortly. The dialogue here in the Vanguard thus far has been focused on the elements of “fairness” that the supporters of Measure P have put on the table … said another way they have focused on a description of the problem. Do you feel the problem is sufficiently delineated at this point? Are there any other elements of “fairness” that haven’t been articulated?
Matt, I am glad to hear that the plan you posted, which seemed to say you would be doubling the water fees (*not* supply charge) is not what you meant. But your third paragraph still has me confused. You said “If, instead of doubling the Variable Use Fee you multiplied it by 4.5, you would get the correct mathematical relationship.” Does that mean you and Donna believe the Supply Charge should be 4.5 the Variable Use Fee? That seems to contradict the second paragraph.
You asked me what element of “fairness” hasn’t been articulated. To me, a key element of “fairness” is having as complete information as possible and time to evaluate that information. The last paragraph makes clear you and Donna have not yet posted a complete, easy to understand description yet. To me, that is blatantly unfair, as unfair as presenting a new formula a week before an election involving the rates so voters do not have time to evaluate it properly. Just say what the darn formula is, so I can evaluate it!!
Calculation of monthly Bill without tiers:
Distribution Charge by meter size … plus
$2.64 per ccf Supply Charge … plus
$0.86 per ccf Variable Charge = Total Water Bill
Calculation of monthly Bill with sample tiers:
Distribution Charge by meter size … plus
$2.64 per ccf Supply Charge … plus
$0.50 per ccf for water less than 21 ccf … plus
$1.90 per ccf for water greater than 20 ccf = Total Water Bill
NOTE: You won’t fall into the second tier unless you use much more than the state standard of 2.25 ccf per person per month.
Donna, thank you for stating the formula. I will point out that this is just like the formula we used to used, except that it has 2 tiers rather than 3, and the multiplier for each tier is higher than for the 3-tiered system.
Now, to speak to Matt Williams’ question about what is “fair” to me: what is going on raises several fairness questions in my mind.
(1) Matt Williams, one of the experts who developed the CBFR, was either unable or unwilling to state the formula precisely and directly, the way you did. For that matter, no-one else did. This raises huge concerns about Matt’s, and others’, credibility in my mind. Either they didn’t have the formula or they didn’t want to disclose it. Why should I trust them when they say these rates will be adopted? Voting yes on Measure P will force the adoption of new rates, and given that a designer of the CBFR (Matt Williams) supports your scheme, it seems to me it will be. But if I vote no on Measure P, what’s to prevent Matt, the URAC, and the City Council, from saying no to your scheme, and leaving the “fair” CBFR rates in place?
(2) The No on Measure P folks argue that CBFR is the fairest water rate system (for example, “The fact of the matter is that the most fair way to go about this is by going to CBFR”, see “Commentary: Lost in All of the Fuss, CBFR Remains the Most Fair Rate Structure”, by David Greenwald, Feb. 18, in the Davis Vanguard; “Everyone pays their fair share, both for the water they use, and for the system that brings it to them”, see “Ballot Arguments Submitted on Measure P, the Water Initiative”, by Vanguard Administrator, Mar. 8, in the Davis Vanguard). Now the designer, Matt Williams, says of your proposal “it is even fairer than the current structure” (this article, about halfway down) and “Bob Dunning has been asking for that kind of improved responsiveness from the water rate structure for eighteen months. Throughout that 18-month period, Bob was saying ‘this is good policy’ and he was/is right” (this article, 2 paragraphs later). This to me also undercuts the credibility of the No on Measure P folks, because if CBFR is the most fair way to do rates, your proposal is less fair — yet now they are saying it’s more fair?
(3) I have been told that a yes vote on Measure P is unnecessary because the Yes on Measure P folks could simply propose a new rate to the URAC after the election, have it thoroughly and openly vetted just the way the supporters of the CBFR say the CBFR rates were, and then have the City Council vote on the new proposal. But you and Matt Williams are apparently saying that the right way to fix the rates is to go to the City Council, bypassing the URAC, presenting the formula *and* having them approve that formula one week before an election — at least, that’s what your actions look like to an apolitical person like me. Which is it — go through the URAC, as others are insisting the Yes on Measure P folks should do, or go directly to the City Council, as you and Matt are doing? Sounds like a double standard to me — and that’s very unfair.
Lest what I have written above be misinterpreted, I am speaking only for myself, and not anyone else. With the points above, I am responding to Matt’s request for what “fair” means to me. And I do appreciate your stating the formula directly — of all the folks in this discussion, only you did so.
Polly, your constructive criticism is accepted in the spirit that it is given … constructively. In your initial request I heard you ask for a comparison of the existing rate method to the proposed rate method. In my answers to you I tried to provide that comparison. Donna heard your request as I think you intended it. She provided no before-after comparison, just a simple description of the “after.” Your comment above says that no comparison was needed, only the formula. That was my failing in listening to your request, and in seeing a level of complexity in it that from your perspective didn’t exist.
Regarding the point you make in (2) once upon a time we thought the world was flat, but armed with better information we recognized that there was a better way. What has happened in this case is that Donna came forward with her own unique perspective on the problem, and as a result of a collaborative effort, we have an even better solution. On February 18 Donna and I hadn’t begun our collaboration, and Yes On Measure P hadn’t put forward its “fairness” solution at the LWV forum, and David Greenwald couldn’t see into the future. That was also the case on March 8. Now in May we have the benefit of Donna’s efforts.
Regarding the points you make in (3) if the water ratepayers like you and me were not faced with the high probability of a $20 million to $100 million fiscal liability if Measure P passes, then neither Donna nor I would be taking this to the Council. However, I believe we do have that $20 million to $100 million liability. It is written into the terms of the contract(s) signed by the City in 2013 with the City of Woodland and CH2MHill. If the Davis withdraws from the surface water plant it has to pay for all the redesign costs incurred by Woodland in order to redesign the plant as a Woodland-only project and also pay the change-order construction charges incurred by changing the project design. I believe that Davis’ fiscal liability doesn’t stop there. I believe that Davis’ lenders will see Davis as a greater fiscal risk and raise the interest rate on Davis’ borrowings to higher interest rates than they are now. Depending on what those rates end up being, then the cost to Davis ratepayers/citizens will be millions of dollars per year in increased interest expense. I also believe that if Michael Harrington will sign a legally binding contract that he will not file, nor help file, a performance under the terms of Measure I lawsuit if Measure P passes, then I would see those financial risks in a very different light. However, I do not believe that Michael will make that kind of legally binding pledge, so Donna and I are working hard to get the Council to make a legally binding decision instead.
Regarding the question you ask in your last sentence of (3) the most recent meeting of the URAC was on May 6th, and the URAC does not meet again prior to Election Day. That constrains our options considerably between now and June 3rd. We are trying to reduce the community’s risk and maximize the community’s reward and honor the electoral process all at the same time. Donna and I are not telling anyone how to vote on Measure P, we are just trying to give the voters the most robust possible information on which to base their final voting decision. I believe a binding decision by Council on Tuesday will also be useful input to each individual’s voting decision. That is why it is worth fighting for.
Thank you for your thoughtful engagement on this important issue. I apologize to you if sometimes I don’t listen as well as I ideally could/should.
Polly, see my response at the end so it’s not so skinny and long
Yes, I realize it is more Measure P as I stated. Did you and Donna not have the plan in place to present to the URAC at one of their meetings? Couldn’t it be presented within their committee via email and a list serv if necessary? Are you not on the URAC as you were on the WAC? I applaud Elaine for her service for what must have been a tough chairmanship (WAC) but am surprised that she was selected as chair again.
No SODA, I am not on the URAC, and Donna’s and my plan only was able to take form once the Measure P supporters put their definition of fairness on the table in the League of Women Voters forum and in the Enterprise OpEd. Trying to satisfy an unarticulated objective is kind of like poking the Pillsbury Dough Boy or the Jet Puffed Marshmallow Man. Those events took place after the last URAC meeting, which was on May 8th.
Don, your points have merit in the abstract; however, those do not exist in a vacuum. You are ignoring very fundamental fiscal risk. Is waiting for the next URAC meeting worth taking on a $100 million liability?
i want to disband the urac.
Matt, what is going on? Seems all reasonable options should be offered for discussion at CC?
They will be heard on Tuesday, May 27th
They will be heard on Tuesday, May 27th at the CC meeting. Be there for some real water rate fun.
Polly and everyone, what I set out to do is exactly one thing, find a solution. It was not ready in time to send to the URAC right now because of their meeting schedule. So we will present it to the CC and the PEOPLE (including anyone on the URAC who is listening). The CC can not adopt it in just 1 night and may send it to the URAC.
The formula for the rates about to start in Jan. was published in the 218 notice every rate payer received last year. As for Matt not simply putting the proposed one here (no disrespect Matt) he always thinks it needs more explaining instead of answering the actual request (just give me the darn formula) and the basic answer gets lost. And what I published here would be the new formula if adopted, the tiers shown are for residential (per household unit).
As for fairness; you think what you’ve got is the best you can do, until you realize there is something better, but until then you just don’t see it. A lot of people worked really hard for us to have the information so we could see it. And of course there still might be something else out there. But I don’t know that we have the time to start from scratch with the demands of the timing of getting the loans and such for the project.
I think that now whether P passes or not, we will get an improved rate structure.