MSR G2 6 London Apr06

CHAPTER 6 – LONDON CSD MUNICIPAL SERVICE REVIEW EXECUTIVE SUMMARY This section provides an overview of the written determinations of the London Community Services District Municipal Service Review (MSR). As part of its review of municipal services, the Tulare County Local Agency Formation Commission (LAFCO) is required to prepare a written statement of its determination with respect to each of the following: 1) Growth and population projections for the affected area; 2) Infrastructure needs and deficiencies; 3) Financing constraints and opportunities; 4) Cost avoidance opportunities; 5) Opportunities for rate restructuring; 6) Opportunities for shared facilities; 7) Government structure options; 8) Evaluation of management efficiencies; and 9) Local accountability and governance. These requirements are established by AB 2838, the Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000. The London CSD MSR identifies the following written determinations: Written Determinations 1) Growth and Population 1. Between 1990 and 2000, London experienced an average annual population growth rate of approximately 1.2%, compared to 0.6% for the unincorporated areas of Tulare County. 2. Assuming no development constraints, it can be expected that London will experience growth at an average annual rate between 1% and 2%, indicating the community would reach a year 2025 population between 2,400 and 3,000 residents. 3. Consistent with the Urban Boundaries element of the Tulare County General Plan, the London UAB is, for the most part, coterminous with the District’s SOI. 2) Infrastructure Needs and Deficiencies Domestic Water 1. The London CSD operates a water supply and distribution system under the jurisdiction of the California Department of Health Services Division of Drinking Water and Environmental Management, which is responsible for the administration and enforcement of the Safe Drinking Water Act involving those systems in California with more than 200 connections. 2. London CSD staff has indicated that there are approximately 430 connections to the District’s water system, which consists of three active wells and one hydro-pneumatic pressure tank. The water system has no permanently installed treatment at this time. 3. District staff has indicated that the water system was constructed in 1952 and experiences minor leaks. Water system leaks have the potential for causing cross contamination problems. The London CSD received Proposition 13 funding in the amount of $98,156 to prepare an infrastructure rehabilitation feasibility study to detect and evaluate leaks and determine the feasibility of replacing the distribution system. The District is currently pursuing funding through the State Revolving Fund Program for construction of a new domestic water well and hydro-pneumatic tank, along with distribution system improvements. London Community Service District MSR Page 6-1 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 4. The London CSD water system is currently un-metered, which does not promote water conservation. The District should consider evaluating the potential water savings and the projected total cost to water users in the community resulting from the installation of water meters. The District would likely need funding assistance through state and/or federal grant/loan programs to install water meters. User fees would also likely need to be increased. A fully metered water system could serve as a water conservation measure by minimizing over usage and/or wasting of water. 5. Assuming 430 equivalent dwelling units (EDUs), in order to meet Tulare County Improvement Standards the London CSD water system would need to be capable of delivering a combined flow rate (from all source and storage facilities) of 1,120 GPM (500 GPM fire flow, and 620 GPM domestic demand) for a period of two hours while maintaining a minimum pressure of 25 PSI to each lot served; 6. The total pumping efficiency of the District’s water supply sources is unknown. Prior to granting any SOI expansions, it is recommended that LAFCO verify that there is adequate water system capacity to meet any anticipated increased demands. 7. It is likely that the District would need to expand its water supply and improve the distribution system to support any significant development projects proposed within its SOI. Sanitary Sewer 1. The London CSD is also responsible for providing sanitary sewer service to residents within its Boundary. London CSD staff has indicated that there are approximately 430 connections to their sewer system. 2. The District owns and operates a WWTF southeast of the community, which is operated under the provisions of Waste Discharge Requirements Order No. 96-172, issued by the RWQCB. 3. Order No. 96-172 prescribes that the monthly average discharge flow shall not exceed 0.3 MGD. Available data indicates that the current flow at the WWTF is 0.20 MGD. The District’s Engineer noted that improvements completed in 2000 with USDA Rural Development funding increased the plant’s capacity to 0.50 MGD. The London CSD should work with the RWQCB to get the District’s WDR Order updated. 4. According to WDR Order No. 96-172, the London CSD has not assessed growth in the community and has not predicted future flows. As such, the London CSD has not made any plans on increasing the capacity of the WWTF for future flows. 3) Financing Constraints and Opportunities 1. It can be expected that the District would have opportunities to work with the development community to help finance infrastructure improvements that would increase the District’s infrastructure capacities in order to accommodate new development projects within its current District Boundary or SOI. London Community Service District MSR Page 6-2 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 4) Cost Avoidance Opportunities 1. The District avoids excessive overhead costs by operating with a part-time staff, which provides adequate levels of service to the small community. The District also avoids unnecessary costs by contracting out professional services including engineering, legal services, and other consulting services. 2. It is recommended that the District work with the development community to fund the construction of water and sewer infrastructure improvements that would serve new development sites as a way of avoiding unnecessary costs. 3. Master planning could help the District avoid unnecessary costs by allowing the District sufficient time to set aside funding needed for future capacity improvements that would allow for development within the community. 4. The District could also avoid unnecessary costs associated with the maintenance of capital infrastructure by promoting development in infill areas, and areas where infrastructure is already in place. 5) Opportunities for Rate Restructuring 1. The London CSD charges monthly user fees and connection fees for water and sewer. The District currently bills its customers under a flat rate system for both water and sewer service. 2. The monthly user fees and connection fees charged by the London CSD for water service are below average compared to other domestic water service providers in the County, while the District’s sewer rates and connection fees are above average in comparison. 3. The District should periodically review its monthly user fees and connection fees to ensure that quality service will continually be provided to existing and future residents. Any rate increases should be substantiated and adopted through a public hearing process. 4. Generally, user fees should be used for the operation and maintenance of existing infrastructure while connection fees should be used for the construction of new infrastructure to accommodate new development. 6) Opportunities for Shared Facilities 1. Since the location of the London CSD Boundary is immediately adjacent to existing rural lands, the opportunity for sharing infrastructure does not readily exist. 7) Government Structure Options 1. Prior to development within its SOI area the District should complete master planning to address the infrastructure needs of affected areas and funding mechanisms to meet those needs. 2. Any change in organization should be completed in accordance with LAFCO policies and procedures. London Community Service District MSR Page 6-3 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 3. The District should continually expand and improve its domestic water and sanitary sewer infrastructure to accommodate development within its current District Boundary and SOI areas zoned for development. 8) Evaluation of Management Efficiencies 1. Based upon information made available, it appears that the provision of domestic water service and sanitary sewer collection are managed in an efficient manner that meets the needs of the community and ratepayers. 2. The London CSD is governed by a three member Board of Directors elected at large from within its boundaries that is responsible for setting policy and general administrative procedures. The District is pursuing an increase in the Board to five members. 3. The District operates with a part-time staff, and is open Monday through Friday between 10 a.m. and 4 p.m. Board meetings are held on the second Monday of each month at 6:00 at the District office located at 37835 Kate Road in Dinuba. 4. District representatives can be contacted by phone. District personnel should be available to respond to emergencies during non office hours. 9) Local Accountability and Governance 1. The District complies with the Brown Act open meeting law by holding regularly scheduled meetings in which the public is invited. Regularly scheduled meetings are held on the second Monday of each month at the District office located at 37835 Kate Road in Dinuba. 2. The District should work with the Tulare County Resource Management Agency (RMA) and/or Tulare County LAFCO to have information regarding District affairs posted on the Tulare County RMA and/or LAFCO website. The District could provide information such as meeting times and locations, budgets, rates, ordinances, agendas, completed/upcoming projects, and other District affairs to Tulare County for posting on the County’s (RMA and/or LAFCO) website. London Community Service District MSR Page 6-4 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 6.0 LONDON COMMUNITY SERVICES DISTRICT 6.0.1 Background The requirement for LAFCO to conduct reviews of local municipal services was established with the passage of AB 2838 known as the Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000. The bill passed the legislature, and was signed into law by Governor Davis on September 26, 2000. MSRs provide LAFCO with an additional tool to fulfill their statutory responsibilities of promoting orderly growth and development, preserving the States finite open space and agricultural land resources, and working to ensure that high quality public services are provided to all Californians in the most efficient and effective manner. MSRs are a requirement of State annexation law and are required to be completed before the consideration of a Sphere of Influence (SOI) amendment or once every five years when a SOI amendment is not being considered. In July 2003 Tulare County LAFCO adopted an MSR exemption policy that identifies the agencies that would be subject to a review and the extent of that review. The agencies in Tulare County were divided into three (3) categories: agencies subject to a full comprehensive study; agencies subject to a questionnaire study; and agencies exempt from an MSR study. The London CSD is subject to a full comprehensive study. The policy further identifies that the services subject to review shall be: • Police protection • Fire protection • Water and wastewater • Solid waste collection and disposal • Streets and traffic circulation • Power generation and distribution • Health Care London, an unincorporated community in Tulare County, is located in the northern portion of the County, approximately three miles southwest of Dinuba and ten miles northwest of Visalia. The London CSD, which was formed in March 1952, provides sanitary sewer and domestic water service for the community. Sanitary sewer and domestic water are the primary services provided by the London CSD that are subject to an MSR. The London CSD also actively provides recreation and park services, although these services are not subject to the MSR requirement. London is an agriculturally oriented service community surrounded on all sides by lands in agricultural production, vacant lands, and scattered rural residential homes. Cities and communities surrounding London include Visalia to the southeast; Dinuba to the northeast; and the community of Traver to the southwest. The Tulare County/Fresno County Line is located approximately 4.8 miles west of London. The current District Boundary and the currently adopted SOI for London are illustrated on Figure 6-1. Figure 6-1 also shows the London Urban Area Boundary (UAB). London Community Service District MSR Page 6-5 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 FIGURE 6-1 – LONDON CSD BOUNDARY, SOI, AND URBAN AREA BOUNDARY (UAB) Source: Tulare County GIS Database London Community Service District MSR Page 6-6 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 The following excerpt from the Tulare County LAFCO website (www.co.tulare.ca.us/lafco/info.asp) defines a SOI and the purpose it serves. A “Sphere of Influence” is the physical boundary and service area that a local governmental agency is expected to serve. Establishment of this boundary is necessary to determine which governmental agencies can provide services in the most efficient way to the people and property in any given area. The Sphere of Influence requirement also works to discourage urban sprawl by preventing overlapping of jurisdictions and duplication of services. The following discussions address the nine legislative factors required by the Cortese-Knox-Hertzberg Act; 1) Growth and population; 2) Infrastructure needs and deficiencies; 3) Financial constraints and opportunities; 4) Cost avoidance opportunities; 5) Opportunities for rate restructuring; 6) Opportunities for shared facilities; 7) Government structure options; 8) Evaluation of management efficiencies; and 9) Local accountability and governance. 6.1 GROWTH AND POPULATION The purpose of this section is to present historical and projected growth patterns and population projections to establish a baseline for the evaluation of the service needs of London. 6.1.1 Historical Data The Census Bureau, on a decennial basis, identifies and provides detailed information on all incorporated Cities along with several smaller unincorporated communities (termed Census Designated Places – CDPs). In each Census, community profiles are developed and provide a wide range of information pertaining to population, demographics, housing information, household data, education and employment, income and poverty, and historical trends. Census 2000 data indicates that London had a population of 1,848 as of January 2000. Census 1990 data indicates that London had a population of 1,638 corresponding to an average annual growth rate between 1990 and 2000 of approximately 1.2%. The unincorporated areas of Tulare County grew from a population of 133,222 in 1990 to a population of 141,150 in 2000, corresponding to an average annual growth rate of approximately 0.6%. Assuming no development constraints, it is likely that the London community will continue to grow at an average annual rate between 1% and 2%. Using an average annual growth rate between 1% and 2%, the London community would reach a year 2025 population between 2,400 and 3,000 residents. 6.1.2 Planning Boundaries In addition to a SOI, which is defined by LAFCO as the “…physical boundary and service area that a local government agency is expected to serve…” an urban area boundary (UAB) has been established and designates the London urban area. Figure 6-1 shows the District Boundary and SOI in comparison to the District’s UAB. The UAB is, for the most part, coterminous with the external SOI boundary of the District. The Tulare County General Plan contains an Urban Boundaries Element which establishes goals for designating realistic planning areas around cities and unincorporated communities which could be used to help determine boundaries for community service districts and County service areas, in areas where differing levels of service are required, and within which corporate annexations may take place. The London Community Service District MSR Page 6-7 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 following are excerpts from the County of Tulare General Plan Policy Summary Section 1UB.C.1 – Unincorporated Communities Policies. “Urban Development Boundaries are established around the following unincorporated communities in the County to serve as official urban planning areas for these communities: Cutler-Orosi, Ducor, Earlimart, East Orosi, Goshen, Ivanhoe, Lemon Cove, London, Pixley, Plainview, Poplar-Cotton Center, Richgrove, Strathmore, Terra Bella, Tipton, Traver, Woodville, Alpaugh, and Springville.” “A land use plan is to be developed for each community with an Urban Development Boundary, specifying desired densities and land use categories, with particular attention to defining suitable areas for the full range of urban development and rural residential development. Such plans shall include the entire area within the Boundary and shall recognize the short and long term ability of each community to provide necessary urban services within its Urban Development Boundary.” Furthermore, the County of Tulare General Plan Policy Summary Sections 1UB.F.1. and 1UB.F.2. set forth policies with regard to “Boundary Consistency”, and “Review and Revision of Boundaries.” Excerpts from these sections of the County General Plan Policy Summary relating to special districts are reiterated below. “In areas where special districts provide rural as well as urban services, LAFCo should distinguish between “urban” and “rural” service areas for the purpose of establishing Spheres of Influence for such districts. If an unincorporated community is served by a special district, the Urban Development Boundary should be consistent with the district’s “urban” Sphere of Influence.” “County census boundaries should be as consistent as possible with Urban Development Boundaries.” “Urban Area Boundaries and Urban Development Boundaries shall be reviewed at least once every five years to determine if boundary changes are justified, or if additional boundaries are needed for communities not included herein. However, a review may be conducted at any time on request of the affected city or agency.” As indicated on Figure 6-1, the London UAB is, for the most part, coterminous with the external SOI boundary of the District. The County census boundary is bounded by the Kennedy School House Ditch to the west, Avenue 384 to the north, Road 60 the west, and Avenue 376 to the south. The District’s SOI extends slightly east of Road 60, slightly west of the Kennedy School House Ditch, and slightly south of Avenue 376, but does not extend north to Avenue 384 as does the County census boundary. Generally, the census boundary covers the urbanized area of the community. 6.1.3 Written Determinations 1. Between 1990 and 2000, London experienced an average annual population growth rate of approximately 1.2%, compared to 0.6% for the unincorporated areas of Tulare County. 2. Assuming no development constraints, it can be expected that London will experience growth at an average annual rate between 1% and 2%, indicating the community would reach a year 2025 population between 2,400 and 3,000 residents. London Community Service District MSR Page 6-8 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 3. Consistent with the Urban Boundaries element of the Tulare County General Plan, the London UAB is, for the most part, coterminous with the District’s SOI. London Community Service District MSR Page 6-9 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 6.2 INFRASTRUCTURE NEEDS AND DEFICIENCIES The purpose of this section is to evaluate the infrastructure needs and deficiencies of the London CSD in terms of availability of resources, capacity to deliver services, condition of facilities, service quality, and levels of service. 6.2.1 Domestic Water The London CSD is responsible for providing domestic water service within the District’s Boundary. The water system is regulated by the California Department of Health Services Division of Drinking Water and Environmental Management, which is responsible for the administration and enforcement of the Safe Drinking Water Act involving those systems in California with more than 200 connections. London CSD staff has indicated that there are approximately 430 connections to the London CSD water system. The District’s water system consists of three active wells and one hydro-pneumatic pressure tank. The water system has no permanently installed treatment at this time. District staff has indicated that the water system was constructed in 1952 and experiences minor leaks. Water system leaks have the potential for causing cross contamination problems. The London CSD received Proposition 13 funding in the amount of $98,156 to prepare an infrastructure rehabilitation feasibility study to detect and evaluate leaks and determine the feasibility of replacing the distribution system. The District is currently pursuing funding through the State Revolving Fund Program for construction of a new domestic water well and hydro-pneumatic tank, along with distribution system improvements. The London CSD water system is currently un-metered, which does not promote water conservation. The District should consider evaluating the potential water savings and the projected total cost to water users in the community resulting from the installation of water meters. The District would likely need funding assistance through state and/or federal grant/loan programs to install water meters. User fees would also likely need to be increased. A cost/benefit analysis resulting from the installation of water meters should be performed. A fully metered water system could serve as a water conservation measure by minimizing over usage and/or wasting of water. Tulare County Improvement Standards require that the construction of water source facilities shall comply with the requirements of Bulletin No. 74, “Water Well Standards” prepared by the State of California Department of Water Resources. The Tulare County Improvement Standards also establish specific requirements for quantity and quality of water to be delivered to a system. Some of these requirements are summarized below. • The quantity of water delivered to the distribution system within a subdivision from all source and storage facilities for a period of two hours shall be the maximum domestic demand plus a fire flow quantity of not less than 500 GPM for single family residential, 1,500 GPM for multi-family residential, commercial, and light manufacturing, and 2,500 GPM for heavy manufacturing. • For systems up to 625 customer units (equivalent dwelling units) the domestic quantity shall not be less than Q = 100 + 25 * √N, and Q = 100 + N for more than 625 customer units at sufficient pressure to provide a minimum pressure of 25 PSI to each lot served; where Q equals the rate of flow in GPM delivered from the combined source facilities to the distribution system, and N equals the total number of customer units where each customer unit is equivalent to one for a single family dwelling on a normal subdivision lot. Other types London Community Service District MSR Page 6-10 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 of development shall be assigned appropriate customer unit values by the Engineer as experience with the distribution system or locality indicates. • The minimum source and domestic demand storage design requirements shall be in accordance with Plate No. WS-11 of Section IV of the Tulare County Improvement Standards. • The quality of water supplied for human consumption shall conform to Sections 3, 4 and 5 of the latest United States Public Health Service Drinking Water Standards. Samples will be taken and tests made by the County Department of Health Services for bacteriological determination of potability. • Chemical and physical tests for potability shall be performed by a commercial laboratory certified by the State Department of Health Services for performance of chemical and physical analysis and the costs thereof shall be borne by the sub-divider. Assuming 430 equivalent dwelling units (EDUs), in order to meet Tulare County Improvement Standards the London CSD water system would need to be capable of delivering a combined flow rate (from all source and storage facilities) of 1,120 GPM (500 GPM fire flow, and 620 GPM domestic demand) for a period of two hours while maintaining a minimum pressure of 25 PSI to each lot served; The total pumping efficiency of the District’s water supply sources is unknown. Prior to granting any SOI expansions, it is recommended that LAFCO verify that there is adequate water system capacity to meet any anticipated increased demands. An estimate of water system capacity can be calculated by using General Order 103, published by the California Public Utilities Commission. For the estimated water system capacity, the total supply source available is compared to a calculated total supply source required. Other factors that may affect the capacity of water systems, including but not limited to, water quality, low pressures, required storage, age of system, and pipeline restrictions, are not considered. For the London CSD, the total supply source available is not known, and therefore only the total supply source required is calculated. The estimated supply source required is calculated using the following equation, Q = (N)*(C)*(F) where, Required N = Number of customers served C = Gallon per minute constant: 5 to 9 for flat rate systems, 2 to 5 for metered systems F = Factor to reflect diversity (inversely proportional to the number of customers) Using an N value of 430, a C factor of 8.0, and an F factor of 0.35, the estimated total supply source required is calculated to be 1,200 GPM for the London CSD. It is likely that the District would need to expand its water supply and improve the distribution system to support any significant development projects proposed within its SOI. 6.2.2 Sanitary Sewer The London CSD is also responsible for providing sanitary sewer service to residents within its Boundary. London CSD staff has indicated that there are approximately 430 connections to the District’s sewer system. Raw sewage is collected and transported to a wastewater treatment and disposal facility (WWTF) located southeast of the community. London Community Service District MSR Page 6-11 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 The District’s WWTF is operated under the provisions of Waste Discharge Requirements Order No. 96- 172 issued by the California Regional Water Quality Control Board (RWQCB), Central Valley Region. Order No. 96-172 prescribes that the monthly average discharge flow shall not exceed 0.3 MGD. According to WWTF records, and the District Engineer, the average dry weather flow at the WWTF is 0.20 MGD. According to the District’s Engineer, improvements completed in 2000 with USDA Rural Development funding increased the plant’s capacity to 0.50 MGD. Approximately 13.1 acres of District- owned peach orchards were converted to evaporation/percolation ponds as a part of the project. The London CSD should work with the RWQCB to get the District’s WDR Order updated. Due to a capacity problem in 1988 and 1989, the District built two additional disposal ponds however the increased capacity was still not able to accommodate the increasing flow. Un-disinfected effluent spilled into King Ditch in 1990. On another occasion, the effluent overflowed to an open field north of the WWTF. Two additional disposal ponds have been constructed since that incident. The WWTF currently consists of five aerated lagoons and nine percolation and evaporation ponds. According to Order No. 96-172, an engineering report that demonstrates that the District has sufficient treatment and disposal capacity for present flows, much less increased flow, has not been submitted to the Board. This report was requested by June 1994 in a letter sent to the London CSD in May 1994. The May 1994 letter also requested the London CSD to submit its plans on expansion of the WWTF for future flows. The London CSD has not assessed growth in the community and has not predicted future flows. As such, the London CSD has not made any plans on increasing the capacity of the WWTF for future flows. 6.2.3 Written Determinations Domestic Water 1. The London CSD operates a water supply and distribution system under the jurisdiction of the California Department of Health Services Division of Drinking Water and Environmental Management, which is responsible for the administration and enforcement of the Safe Drinking Water Act involving those systems in California with more than 200 connections. 2. London CSD staff has indicated that there are approximately 430 connections to the District’s water system, which consists of three active wells and one hydro-pneumatic pressure tank. The water system has no permanently installed treatment at this time. 3. District staff has indicated that the water system was constructed in 1952 and experiences minor leaks. Water system leaks have the potential for causing cross contamination problems. The London CSD received Proposition 13 funding in the amount of $98,156 to prepare an infrastructure rehabilitation feasibility study to detect and evaluate leaks and determine the feasibility of replacing the distribution system. The District is currently pursuing funding through the State Revolving Fund Program for construction of a new domestic water well and hydro-pneumatic tank, along with distribution system improvements. 4. The London CSD water system is currently un-metered, which does not promote water conservation. The District should consider evaluating the potential water savings and the projected total cost to water users in the community resulting from the installation of water meters. The District would likely need funding assistance through state and/or federal grant/loan programs to install water meters. User fees would also likely need to be increased. London Community Service District MSR Page 6-12 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 A fully metered water system could serve as a water conservation measure by minimizing over usage and/or wasting of water. 5. Assuming 430 equivalent dwelling units (EDUs), in order to meet Tulare County Improvement Standards the London CSD water system would need to be capable of delivering a combined flow rate (from all source and storage facilities) of 1,120 GPM (500 GPM fire flow, and 620 GPM domestic demand) for a period of two hours while maintaining a minimum pressure of 25 PSI to each lot served; 6. The total pumping efficiency of the District’s water supply sources is unknown. Prior to granting any SOI expansions, it is recommended that LAFCO verify that there is adequate water system capacity to meet any anticipated increased demands. 7. It is likely that the District would need to expand its water supply and improve the distribution system to support any significant development projects proposed within its SOI. Sanitary Sewer 1. The London CSD is also responsible for providing sanitary sewer service to residents within its Boundary. London CSD staff has indicated that there are approximately 430 connections to their sewer system. 2. The District owns and operates a WWTF southeast of the community, which is operated under the provisions of Waste Discharge Requirements (WDR) Order No. 96-172, issued by the RWQCB. 3. Order No. 96-172 prescribes that the monthly average discharge flow shall not exceed 0.3 MGD. Available data indicates that the current flow at the WWTF is 0.20 MGD. The District’s Engineer noted that improvements completed in 2000 with USDA Rural Development funding increased the plant’s capacity to 0.50 MGD. The London CSD should work with the RWQCB to get the District’s WDR Order updated. 4. According to WDR Order No. 96-172, the London CSD has not assessed growth in the community and has not predicted future flows. As such, the London CSD has not made any plans on increasing the capacity of the WWTF for future flows. London Community Service District MSR Page 6-13 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 6.3 FINANCING OPPORTUNITIES AND CONSTRAINTS The purpose of this section is to evaluate the jurisdictions capability to finance needed improvements and services. 6.3.1 Annual Budget The District’s annual budget has not been provided for this review, therefore determinations with regard to financial resources, opportunities, or constraints can be made at this time. It can be expected that the District would have opportunities to work with the development community to help finance infrastructure improvements that would increase the District’s infrastructure capacities in order to accommodate new development projects within its current District Boundary or SOI. 6.3.2 Written Determinations 1. It can be expected that the District would have opportunities to work with the development community to help finance infrastructure improvements that would increase the District’s infrastructure capacities in order to accommodate new development projects within its current District Boundary or SOI. London Community Service District MSR Page 6-14 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 6.4 COST AVOIDANCE OPPORTUNITIES The purpose of this section is to identify practices or opportunities that may help to eliminate unnecessary costs. 6.4.1 Fiscal Structure The District has adequate staff resources and administrative capabilities to provide the needed level of services to the residents within its boundaries. The District avoids excessive overhead costs by operating with a part-time administration, which provides adequate levels of service to the small community. The District also avoids unnecessary costs by contracting out professional services including engineering, legal services, and other consulting services. The District requires new development projects to pay connection fees in order to mitigate impacts to the District’s infrastructure, currently set at $1,400 per equivalent dwelling unit (EDU) for water connections, and $1,990 for sewer connections. It is recommended that the District work with the development community to fund the construction of water and sewer infrastructure improvements that would serve new development sites as a way of avoiding unnecessary costs. The preparation of water and sewer system master plans could help the District avoid unnecessary costs associated with the construction of emergency system improvements to meet demands. Master plans identify infrastructure improvements that will be needed in the future, including an improvement timeline that would allow the District adequate time to set aside and/or obtain funding for those future improvements before the absence of such improvements begins to delay or halt proposed development. Master plans typically identify funding sources for their implementation. If the SOI were expanded in the future, the District would assume fiscal responsibilities to construct or maintain the sewer and domestic water infrastructure associated with the SOI and any territories that were annexed. LAFCO should consider the relative financial and operational burden of new annexations to the District when it comes to its ability to provide water and sewer service, as well as capital maintenance and replacements required as a result of expanding the District Boundary. Opportunities exist at the time of annexation and development to introduce alternative methods of construction and maintenance of public or semi-public infrastructure to serve the future SOI/annexation areas. 6.4.2 Written Determinations 1. The District avoids excessive overhead costs by operating with a part-time staff, which provides adequate levels of service to the small community. The District also avoids unnecessary costs by contracting out professional services including engineering, legal services, and other consulting services. 2. It is recommended that the District work with the development community to fund the construction of water and sewer infrastructure improvements that would serve new development sites as a way of avoiding unnecessary costs. 3. Master planning could help the District avoid unnecessary costs by allowing the District sufficient time to set aside funding needed for future capacity improvements that would allow for development within the community. London Community Service District MSR Page 6-15 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 4. The District could also avoid unnecessary costs associated with the maintenance of capital infrastructure by promoting development in infill areas, and areas where infrastructure is already in place. London Community Service District MSR Page 6-16 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 6.5 OPPORTUNITIES FOR RATE RESTRUCTURING The purpose of this section is to identify opportunities to positively impact rates without decreasing service levels. 6.5.1 Fee Structure The London CSD currently charges a monthly flat for water and sewer service, currently set at $18.00 and $22.00, respectively. Tables 6-1 and 6-2 show a comparison of water and sewer rates and connection fees, respectively, for all applicable service providers being reviewed. The tables also show the relationship between monthly service charges and average household incomes within the respective communities. Since some of the service providers charge a metered rate for water, it is necessary to calculate an average monthly bill based upon a specific amount of usage taken as 2,005 cubic feet, or approximately 15,000 gallons, per month for this analysis. TABLE 6-1 LONDON CSD COMPARISON OF WATER RATES Average Household Service Provider Sample Monthly Bill Connection Fee Income Rate/Income Ratio Earlimart PUD $12.50 $1,500 $1,775/mo. 0.70% Ivanhoe PUD $9.50 $1,700 $2,171/mo. 0.44% Pixley PUD $20.00 $2,000 $1,942/mo. 1.03% Teviston CSD $30.00 $800 $2,014/mo. 1.49% Tipton CSD $24.00 $2,800 $2,198/mo. 1.09% Alpaugh JPA $55.00 $1,500 $1,974/mo. 2.79% Cutler PUD $18.00 $1,500 $2,028/mo. 0.89% Orosi PUD $19.08 $2,400 $2,533/mo. 0.75% Lemon Cove SD $10.01 $500 $2,361/mo. 0.42% London CSD $18.00 $1,400 $1,807/mo. 1.00% Lindsay-Strathmore ID $14.187 T&M $2,096/mo. 0.68% Poplar CSD $25.00 $1,750 $2,043/mo. 1.22% Richgrove CSD NA NA $1,907/mo. NA Springville PUD $23.42 $2,800 $2,023/mo. 1.16% Strathmore PUD $43.30 $1,150 $2,096/mo. 2.06% Terra Bella ID $12.438 $2,908 $2,109/mo. 0.59% Woodville PUD $27.28 $2,000 $2,123/mo. 1.28% Average $23.17 $1,780 $2,080/mo. 1.11% Notes: 1) Fee information obtained from service providers 2) Average household income based upon Census 2000 data 3) Rate/Income ratio calculated by dividing sample monthly bill by average household income 4) Sample monthly bill is calculated for a typical single family dwelling 5) NA=Not Available 6) T&M=Time and Material basis 7) Based on an average of four separate rates charged by the Lindsay-Strathmore Irrigation District 8) Based on potable water service provided by the Terra Bella Irrigation District 9)Richgrove CSD and Lindsay-Strathmore ID were omitted from the average calculations London Community Service District MSR Page 6-17 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 As indicated in Table 6-1, the London CSD charges monthly rates and connection fees that are below average compared to surrounding domestic water service providers. The cost of domestic water service within London equates to approximately 1.00% of the average household income within the community. TABLE 6-2 LONDON CSD COMPARISON OF SEWER RATES Average Monthly Sewer Connection Household Service Provider User Fee (1 EDU)1 Fee1 Income2 Rate/Income Ratio Goshen CSD $32.00 $975 $2,359/mo. 1.36% Earlimart PUD $7.50 $1,000 $1,775/mo. 0.42% Ivanhoe PUD $9.50 $1,890 $2,171/mo. 0.44% Pixley PUD $15.00 $1,800 $1,942/mo. 0.77% Tipton CSD $8.00 $1,050 $2,198/mo. 0.36% Cutler PUD $22.00 $3,520 $2,028/mo. 1.08% Orosi PUD $22.97 $1,745 $2,533/mo. 0.91% Lemon Cove SD $4.50 $500 $2,361/mo. 0.19% London CSD $21.00 $1,990 $1,807/mo. 1.16% Poplar CSD $25.00 $1,300 $2,043/mo. 1.22% Richgrove CSD $18.00 $750 $1,907/mo. 0.94% Springville PUD $35.06 $3,900 $2,023/mo. 1.73% Strathmore PUD $14.70 $500 $2,096/mo. 0.70% Terra Bella SMD $21.00 $500 $2,109/mo. 1.00% Woodville PUD $17.25 $700 $2,123/mo. 0.81% Average $18.23 $1,475 $2,098/mo. 0.87% 1) Source: Wastewater User Charge Survey Report FY 2004-05 (Cal EPA – SWRCB, May 2005) 2) Source: Census 2000 As indicated in Table 6-2, the London CSD charges monthly rates and connection fees that are above average compared to surrounding sanitary sewer service providers. The cost of sanitary sewer service within London equates to approximately 1.16% of the average household income within the community. The District should periodically review its monthly user fees and connection fees to ensure that quality service will continually be provided to existing and future residents. Often it is necessary to increase user fees and/or connection fees to keep pace with cost of living increases and rising material and construction costs. Any rate increases should be substantiated and adopted through a public hearing process. The District currently bills under a metered rate structure for domestic water service, which promotes water conservation. Generally, user fees should be used for the operation and maintenance of existing infrastructure while connection fees should be used for the construction of new infrastructure to accommodate new development. London Community Service District MSR Page 6-18 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 6.5.2 Written Determinations 1. The London CSD charges monthly user fees and connection fees for water and sewer. The District currently bills its customers under a flat rate system for both water and sewer service. 2. The monthly user fees and connection fees charged by the London CSD for water service are below average compared to other domestic water service providers in the County, while the District’s sewer rates and connection fees are above average in comparison. 3. The District should periodically review its monthly user fees and connection fees to ensure that quality service will continually be provided to existing and future residents. Any rate increases should be substantiated and adopted through a public hearing process. 4. Generally, user fees should be used for the operation and maintenance of existing infrastructure while connection fees should be used for the construction of new infrastructure to accommodate new development. London Community Service District MSR Page 6-19 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 6.6 OPPORTUNITIES FOR SHARED FACILITIES The purpose of this section is to evaluate opportunities for a jurisdiction to share facilities and resources, thereby increasing efficiency. 6.6.1 Shared Facilities Since the location of the London CSD Boundary is immediately adjacent to existing rural lands, the opportunity for sharing infrastructure does not readily exist. Currently, the London CSD is the only water and sewer service provider in the immediate area. 6.6.2 Written Determinations 1. Since the location of the London CSD Boundary is immediately adjacent to existing rural lands, the opportunity for sharing infrastructure does not readily exist. London Community Service District MSR Page 6-20 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 6.7 GOVERNMENT STRUCTURE OPTIONS The purpose of this section is to consider the advantages and disadvantages of various government structures to provide public services. 6.7.1 Development within SOI Areas One of the most critical elements of LAFCO’s responsibilities is in setting logical service boundaries for communities based on their capability to provide services to affected lands. According to the LAFCO Municipal Service Review Guidelines, elimination of overlapping boundaries that confuse the public and cause service inefficiencies should be considered to avoid unnecessary increases in the cost of infrastructure. Currently there are no foreseeable conditions that would indicate that development within the District’s SOI would result in a change in government structure. Tulare County LAFCO has adopted specific policies for reviewing proposals for a change in organization, reorganization, incorporations, dissolution and other proposals processed by Tulare County LAFCO. Tulare County LAFCO policy C-1 identifies factors and standards to be considered in review proposals including additional requirements for City annexations, standards for annexation to special districts, standards for the formation of special districts, and standards for City incorporation. Tulare County LAFCO policy C-2 outlines general procedures for changes in boundaries or organization to be processed by LAFCO. Generally, proposals for changes in boundaries, formations, or changes of organization can be submitted for the consideration of LAFCO by petition of the registered voters or affected landowners; however, prior to the circulation of any petition, a “Notice of Intent to Circulate” must be presented to the LAFCO Executive Officer. A proposal may also be initiated by a resolution adopted by the governing body of any related public body (county, city or special district). The proposal must be submitted on forms available from the LAFCO staff office, or on the LAFCO website, along with the applicable number of maps, legal descriptions, and filing fees to cover the proposal submitted. Prior to development within its SOI area, the District should complete infrastructure planning – including master plans – to address the infrastructure needs of affected areas and funding mechanisms to meet those needs. The District and/or County could also require developers to prepare specific plans prior to approving development within the District’s SOI. The District should continually expand and improve its water and sewer infrastructure to accommodate development within its current District Boundary and SOI areas with developer assistance. 6.7.2 Written Determinations 1. Prior to development within its SOI area the District should complete master planning to address the infrastructure needs of affected areas and funding mechanisms to meet those needs. 2. Any change in organization should be completed in accordance with LAFCO policies and procedures. 3. The District should continually expand and improve its domestic water and sanitary sewer infrastructure to accommodate development within its current District Boundary and SOI areas zoned for development. London Community Service District MSR Page 6-21 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 6.8 EVALUATION OF MANAGEMENT EFFICIENCIES The purpose of this section is to consider the management structure of the jurisdiction. 6.8.1 Organizational Structure Based upon a review of information provided by the London CSD, it appears that the provisions of sanitary sewer and domestic water service are managed in an efficient manner, meeting the needs of the community and ratepayers. The District undergoes annual audits in compliance with auditing standards. The London CSD is governed by a three-member Board of Directors elected at large from within its boundaries that is responsible for setting policy and general administrative procedures. The District is currently pursuing an increase in the Board to five members. The District operates with a part time staff, and is open Monday through Friday between 10 a.m. and 4 p.m. Board meetings are held on the second Monday of each month at 6:00 at the District office located at 37835 Kate Road in Dinuba. District representatives can be contacted by phone. District personnel should be available to respond to emergencies during non office hours. 6.8.2 Written Determinations 1. Based upon information made available, it appears that the provision of domestic water service and sanitary sewer collection are managed in an efficient manner that meets the needs of the community and ratepayers. 2. The London CSD is governed by a three member Board of Directors elected at large from within its boundaries that is responsible for setting policy and general administrative procedures. The District is pursuing an increase in the Board to five members. 3. The District operates with a part-time staff, and is open Monday through Friday between 10 a.m. and 4 p.m. Board meetings are held on the second Monday of each month at 6:00 at the District office located at 37835 Kate Road in Dinuba. 4. District representatives can be contacted by phone. District personnel should be available to respond to emergencies during non office hours. London Community Service District MSR Page 6-22 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01 6.9 LOCAL ACCOUNTABILITY AND GOVERNANCE The purpose of this section is to evaluate the accessibility and levels of public participation associated with the London CSD’s decision-making processes. 6.9.1 Public Access and Information Methods LAFCO may consider the agency’s record of local accountability in its management of community affairs as a measure against the ability to provide adequate services to the SOI and annexation areas. The London CSD has a three member Board of Directors elected by voters residing within the Districts Boundary. Regularly scheduled Board meetings are held on the second Monday of each month at 6:00 p.m. at the District office located at 37835 Kate Road in Dinuba. The District should work with the Tulare County Resource Management Agency (RMA) and/or Tulare County LAFCO to have information regarding District affairs posted on the Tulare County RMA and/or LAFCO website. The District could provide information such as meeting times and locations, budgets, rates, ordinances, agendas, completed/upcoming projects, and other District affairs to Tulare County for posting on the County’s (RMA and/or LAFCO) website. It would make sense to post information regarding District affairs on the County websites, since London is an unincorporated community within Tulare County, and there is a mutual interest in the community. The internet is a relatively low-cost yet powerful method of involving the general public/customers/ratepayers in District affairs. Greater dissemination of information can lead to greater interest in attending Board meetings and participating in elections. It also allows the public, some of whom are not physically able to attend Board meetings, to follow District activities remotely from their home or business. 6.9.2 Written Determinations 1. The District complies with the Brown Act open meeting law by holding regularly scheduled meetings in which the public is invited. Regularly scheduled meetings are held on the second Monday of each month at the District office located at 37835 Kate Road in Dinuba. 2. The District should work with the Tulare County Resource Management Agency (RMA) and/or Tulare County LAFCO to have information regarding District affairs posted on the Tulare County RMA and/or LAFCO website. The District could provide information such as meeting times and locations, budgets, rates, ordinances, agendas, completed/upcoming projects, and other District affairs to Tulare County for posting on the County’s (RMA and/or LAFCO) website. London Community Service District MSR Page 6-23 Tulare County LAFCO MSR G2_6 London Apr06.DOC/55-7301-01