A. 
The purpose of the drought allocation plan (DAP) is to provide Western Municipal Water District of Riverside County (Western) and its wholesale customers with a means of allocating limited imported water supplies from the Metropolitan Water District of Southern California (Metropolitan) under various shortage conditions. The DAP is intended to help the region minimize the impacts of shortages and ensure an equitable allocation of imported water supplies.
B. 
The DAP will be used to allocate water for retail municipal, industrial, and agricultural purposes among the following agencies:
1. 
Box Springs Mutual Water Company.
2. 
City of Corona.
3. 
City of Norco.
4. 
Eagle Valley Mutual Water Company.
5. 
Elsinore Valley Municipal Water District.
6. 
Lee Lake Water District.
7. 
Rancho California Water District.
8. 
Western Municipal Water District retail customers.
(Ord. 385 § 2 (Exh. A § 1), 2015)
A. 
A fourth year of dry climate conditions throughout the state and uncertainty about water availability from the State Water Project have increased the possibility that Metropolitan may not have access to the supplies necessary to meet total firm demands at some point in the future and may have to allocate shortages in supplies to its member agencies. To prepare for this possibility, Metropolitan staff worked jointly with member agencies to develop an updated water shortage allocation plan (WSAP) for 2015 and beyond. This plan, which addresses the principles adopted by the Metropolitan board of directors in the 1999 water surplus and drought management plan (WSDM plan), was adopted by Metropolitan's board of directors in December 2014. A summary of the 2007 plan and the 2014 update is included in Appendix B, attached to the ordinance codified in this chapter.
To facilitate implementation of Metropolitan's plan at the local level, Western has developed this DAP. The DAP identifies the methods that will be used to allocate limited imported supplies among Western's wholesale customers, if and when Metropolitan implements its WSAP.
B. 
Wholesale Customer Coordination. In 2008, the initial preparation and implementation of a DAP for the Western service area required input from Western's wholesale customers. Recognizing the importance of wholesale customer involvement for the first-of-its-kind plan document, Western created a workgroup made up of staff from Western and the potentially affected wholesale customers. For this update, Western staff simply modified the allocation methodology so that it was consistent with Metropolitan's recently updated WSAP plan. These changes in methodology were presented to wholesale customer representatives at a regular meeting hosted by Western's general manager in January 2015. As these changes, which are explained in WMWDC § 5.45.030, did not substantially change the plan outcome, the need for formal workshops was unnecessary to gain support for this update.
(Ord. 385 § 2 (Exh. A § 2), 2015)
This section includes a description of the updated supply allocation methodology developed following the 2014 modification of Metropolitan's WSAP. The goal of the DAP is to provide an equitable means of apportioning imported supplies during periods where Metropolitan implements the various shortage levels of its WSAP. This allocation methodology is consistent with the approach defined within Metropolitan's plan and has been adjusted for local needs and conditions. Appendix A, attached to the ordinance codified in this chapter, includes estimated retail agency allocations based on the following methodology:
A. 
Base Period Calculations. The first step in estimating retail demands and wholesale water needs in the allocation year is to establish a base period with established water supply and delivery data that approximates a base operating condition within Western's service area. The base period for each of the different categories of demands and supplies is calculated using data from the two most recent nonallocation years (fiscal years 2012-13 and 2013-14); exceptions to this methodology are noted in the following descriptions of base period calculations:
The following are the components of the base period calculation:
1. 
Base Period Total Demand. Total water demands for the base period are calculated by adding the base period import supplies (the demands on Western) and the base period local supplies.
2. 
Base Period Local Supplies. Local supplies for the base period are calculated using the two-year average of groundwater production, groundwater recovery, surface water production, and other imported supplies. Nonpotable recycled water production is not included in this calculation. (This is to address the impact of demand hardening due to recycled water use.)
3. 
Base Period Wholesale Demands. Firm demands on Western for the base period are calculated using the two-year average of retail municipal and industrial (M&I) demands.
4. 
Base Period Gallons per Capita Daily (GPCD). Conservation demand hardening occurs at the retail water use level as consumers install more conservation-saving devices and participate in available programs. In order to estimate conservation savings, Metropolitan requires each member agency to establish an historical baseline GPCD calculated in a manner consistent with California Senate Bill SBx7-7. Western's 10-year GPCD base period for this plan is 1999 through 2008. The calculated regional base period GPCD is 362. Reductions from the base period GPCD to the allocation year are the basis used to calculate the equivalent conservation savings in acre-feet.
B. 
Allocation Year Calculations. The next step in estimating water demands in the allocation year is to adjust the base period estimates of retail demand for population or economic growth, and to adjust for changes in local supplies.
1. 
Allocation Year Demand Adjustment. Total retail demands for the allocation year are calculated by adjusting the base period retail demands for growth.
2. 
Growth Adjustment. The lesser of 159.4 GPCD (value provided by Metropolitan), or the calculated base period for each agency, is applied to the change in population from the base period to the allocation year.
3. 
Allocation Year Local Supplies. Allocation year local supplies are estimated using the base period local supplies and should include any adjustments for gains and losses of local supply, and extraordinary increases in production over the base period. These adjustments are made to give a more accurate estimate of actual supplies in the allocation year and, in turn, more accurately reflect an agency's demand for supplies from Western.
a. 
Gain of Local Supply Adjustment. This adjustment accounts for planned or scheduled gains in local supply production above the base period, which are not due to extraordinary actions to increase water supply in the allocation year. These previously scheduled increases in supply programs or local production should be added to the base period local supplies.
b. 
Loss of Local Supply Adjustment. This adjustment accounts for losses of local supply production from the base period. Losses of local supply, due to such things as hydrology or water quality, should be subtracted from the base period local supplies.
c. 
Extraordinary Increased Production Adjustment. This adjustment accounts for extraordinary increases in local supplies above the base period. Extraordinary increases in production include such efforts as purchasing transfers or mining of groundwater basins. In order not to discourage such extraordinary efforts, only a percentage of the yield from these supplies is added back to allocation year local supplies. This has the effect of "setting aside" the majority of the yield for the agency who procured the supply. The following table shows the percentages of the extraordinary increases in local supply that are counted in each level of supply allocation:
Regional Shortage Level (%)
Percentage Counted in Local Supply
1 (5%)
0%
2 (10%)
0%
3 (15%)
15%
4 (20%)
20%
5 (25%)
25%
6 (30%)
30%
7 (35%)
35%
8 (40%)
40%
9 (45%)
45%
10 (50%)
50%
4. 
Allocation Year Wholesale Demands. Demands on Western for the allocation year are calculated by subtracting the allocation year local supplies from the allocation year retail demands.
C. 
Allocation Formula and Accounting. The following table contains the elements used in the allocation formula. The formula was designed to be equitable on the wholesale level while helping to minimize hardships experienced by individuals and by the regional economy at the retail level.
(1) Regional Shortage Level
(2) Regional Shortage Percentage
(3) Wholesale Minimum Allocation
(4) Retail Impact Adjustment Maximum
1
5%
92.5%
0%
2
10%
85.0%
5.0%
3
15%
77.5%
7.5%
4
20%
70.0%
10.0%
5
25%
62.5%
12.5%
6
30%
55.0%
15.0%
7
35%
47.5%
17.5%
8
40%
40.0%
20.0%
9
45%
32.5%
22.5%
10
50%
25.0%
25.0%
1. 
Shortage Levels (1). The formula allocates shortages of Western supplies over 10 levels: from five to 50 percent, in five percent increments.
2. 
Shortage Percentage (2). The maximum total regional shortage percentage of Western's available supplies when compared to the sum of the demands in the allocation year.
3. 
Wholesale Minimum Allocation (3). The wholesale minimum allocation is established to ensure a minimum level of wholesale water service (Western supplies) at the wholesale customer level, and sets the target for recognizing a wholesale customer's ongoing investment in Western's system. The wholesale minimum allocation ensures that wholesale customers will not experience shortages on the wholesale level that are greater than one and one-half times the percentage shortage of Western's regional water supplies. The wholesale minimum allocation is equal to 100 percent minus one and one-half times the shortage level.
4. 
Retail Impact Adjustment Maximum (4). The retail impact adjustment maximum is the factor used to address major differences in retail level shortages associated with across-the-board cuts. The purpose of this adjustment is to ensure that agencies with a high level of dependence on Western do not experience highly disparate shortages compared to other agencies when faced with a reduction in wholesale water supplies. The retail impact adjustment maximum factor is calculated as the difference between the regional shortage percentage and the wholesale minimum allocation. The amount of the adjustment each wholesale customer receives is prorated on a linear scale, based on its dependence on Western at the retail level. The prorated amount of allocation is referred to as the retail impact adjustment allocation. For agencies that are 100 percent dependent on Western, this method will result in an allocation of Western supplies that, at the retail level, will result in a shortage equal to the regional shortage percentage. In other words, through this allocation, no agency will experience a greater percentage shortage than the regional shortage percentage.
5. 
Conservation Demand Hardening Credit. The conservation demand hardening credit is calculated at the regional level in Metropolitan's WSAP. The value of the regional conservation credit is divided proportionally among the agencies within Western's service area that purchased imported water during the base period. The individual agency's volume of imported water is compared to the total of all agency purchases of imported water. The conservation demand hardening credit will be based on an initial 10 percent of the GPCD-based Conservation savings plus an additional five percent for each level of regional shortage set by the board of directors during implementation of the WSAP. The credit will also be adjusted for:
a. 
Overall percentage reduction in retail water demand, and
b. 
Western's dependence on Metropolitan.
This provides a base demand hardening credit equal to 10 percent of conservation savings and increases the credit as deeper shortages occur, which is when conservation demand hardening has a bigger impact on the retail consumer. The credit also increases based on the percentage of an agency's demand that was reduced through conservation. This accounts for increased hardening that occurs as increasing amounts of conservation are implemented. Lastly, the credit is scaled to the member agency's dependence on Metropolitan to ensure that credits are being applied to the proportion of water demand that is being affected by reductions in Metropolitan supply.
6. 
M&I Allocation. The allocation of Western supplies to an agency for its retail demand is the sum of the wholesale minimum allocation, the retail impact adjustment, and the conservation demand hardening credit.
D. 
Allocation Example – Calculating Base Period Information to Determine Allocation Year Needs. The following example gives a step-by-step description of how the recommended formula would be used to calculate an allocation of Western's imported supplies to its wholesale customers and retail service area. This example is based on a fiscal year 2015-16 allocation using the average of fiscal year 2012-13 and fiscal year 2013-14 as the base period. The data used for this example was provided by each agency in late 2014.
1. 
Step 1: Calculate Base Period Retail Demand. The first step in developing an agency's allocation is to estimate the agency's retail level water needs.
a. 
Two pieces of information are required to calculate retail level water needs:
i. 
The amount of local supplies that were produced in the base period; and
ii. 
The amount of demands on Western in the base period.
b. 
Base period local supplies are calculated using the average of production data from fiscal year 2012-13 and fiscal year 2013-14 for groundwater, groundwater recovery, surface water, and/or other non-Western imported supplies.
c. 
Base period wholesale demands on Western are calculated using the same averaged time period as the base period local supplies.
d. 
Base period retail demand can be calculated once the information described above has been determined. The sum of the base period local supplies and the base period wholesale demands equals the base period retail demand.
2. 
Step 2: Adjust Base Period Retail Demand for Growth. The second step in developing an agency's allocation is to adjust the base period retail demand for growth that occurred since the base period. Based on Department of Finance statistics, the projected population growth in Riverside County was 1.12 percent for the period 2011 through 2013. The base period population is adjusted by 1.12 percent for each year between the base period and the allocation year. The change in the demand for water is calculated by multiplying the change in population by the lesser of 159.4 gallons per capita daily or the calculated base period GPCD for each agency.
Agency within Western
Applied GPCD
Box Springs Mutual Water Company
104.0
City of Corona
159.4
City of Norco
159.4
Eagle Valley Mutual Water Company
–
Elsinore Valley Municipal Water District
159.4
Lee Lake Water District
138.0
Metropolitan Water District
–
Rancho California Water District
159.4
Western Municipal Water District Retail
159.4
Allocation year retail demand is the result of applying the growth adjustment to the base period retail demand. It represents a reasonable estimate of the total amount of firm water that an agency needs at the retail level in the year of allocation.
3. 
Step 3: Adjustment for Changes in Local Supply from the Base Period. The third step in calculating each agency's allocation is to calculate the agency's local supply production in the year of the allocation. This is done by using base period local supplies that were calculated in Step 1 as a base estimate, and adding back any gains or losses in base period local supplies that are occurring in the allocation year. If an agency has undertaken extraordinary efforts to secure alternative supplies, this extraordinary increase in local supplies would also be added here.
Allocation year local supplies are the result from adjusting the base period local supply for all of the changes listed above.
4. 
Step 4: Calculate Wholesale Water Needs in the Allocation Year. Now that both the allocation year retail demands and the allocation year local supplies have been estimated, the agency's allocation year wholesale demand can be calculated.
Allocation year wholesale demands on Western are calculated by subtracting the allocation year local supplies from the allocation year retail demands. Any demand that is remaining after the agency's local supplies are accounted for represents demand for wholesale supplies from Western.
Dependence on Western is calculated as the percentage of an agency's retail need that is met by Western wholesale supplies.
5. 
Step 5: Apply Base Period Conservation Demand Hardening Credit. The conservation demand hardening credit is calculated at the regional level in Metropolitan's WSAP. The value of the regional conservation credit is divided proportionally between the agencies within Western's service area that purchased imported water in the base period. The individual agency's volume of imported water is compared to the total of all agencies purchases of imported water.
E. 
Allocation Example – Calculating a Supply Allocation in a Regional Shortage Level 3. This example will follow the allocation formula accounting, through a regional shortage level 3 (15 percent). The table below shows the essential elements of the allocation formula under a regional shortage level 3.
(1) Regional Shortage Level
(2) Regional Shortage Percentage
(3) Wholesale Minimum Allocation
(4) Retail Impact Adjustment Maximum
3
15%
77.5%
7.5%
1. 
Step 1: Calculate Wholesale Minimum Allocation. The wholesale minimum allocation is calculated by multiplying the agency's allocation year wholesale demand by the wholesale minimum allocation percentage from the allocation table.
2. 
Step 2: Calculate Retail Impact Adjustment Allocation. The next step in determining this agency's allocation is to calculate the retail impact adjustment allocation. Recall from the allocation table, the retail impact adjustment maximum factor is the difference between the wholesale minimum allocation and the regional shortage percentage. Under a regional shortage level 3 (15 percent), the retail impact adjustment maximum factor available to any agency is seven and one-half percent. Each agency's retail impact adjustment factor is calculated by multiplying the seven and one-half percent retail impact adjustment maximum factor by the agency's dependence on Western, which was calculated in a previous step.
3. 
Step 3: Apply the conservation hardening credit.
4. 
Step 4: Add the Wholesale Minimum Allocation, the Retail Impact Adjustment Allocation, and the Conservation Hardening Credit to Get the Final M&I Agency Allocation. The wholesale minimum allocation, the retail impact adjustment allocation, and the conservation hardening credit are added together to total to the M&I allocation.
5. 
Step 5: Add Unallocated Supplies. After each agency's M&I allocation is calculated, each agency's M&I allocation is added together to determine the total M&I allocation for all of Western's wholesale customers. As with the example above, if the total M&I allocation is lower than the allocation that Western is receiving from Metropolitan, the surplus is allocated among the wholesale customers based on the proportion of each agency's wholesale minimum allocation to Western's total wholesale minimum allocation. If the amount is greater than the allocation from Metropolitan, then the next regional shortage level will be applied until the total M&I allocation is equal or less than allocation from Metropolitan.
6. 
Step 6: Total Allocation. The final step in calculating this agency's allocation of Western supplies is to sum up all of the elements of the allocation formula that were calculated above.
(Ord. 385 § 2 (Exh. A § 3), 2015)
Western (retail) and the retail water suppliers within Western's general service area are, to varying degrees, dependent upon Metropolitan for imported water supply. The following table summarizes the estimated impact of the Metropolitan board of directors-adopted (December 2014) WSAP process for the allocation of water supplies to Western's general service area during 10 levels of water supply shortage. The water supply available to Western is further allocated between the retail water suppliers in a fashion similar to the Metropolitan process.
MWD Water Supply Allocation Plan – 2014 Update
Regional Shortage Level
MWD Declared Shortage
Import Water Available1
Regional Reduction Level2
0
–
–
–
1
-5.0%
72,689
-5.1%
2
-10.0%
72,689
-5.1%
3
-15.0%
71,496
-6.7%
4
-20.0%
69,489
-9.3%
5
-25.0%
67,482
-11.9%
6
-30.0%
65,475
-14.5%
7
-35.0%
63,469
-17.2%
8
-40.0%
61,462
-19.8%
9
-45.0%
59,455
-22.4%
10
-50.0%
57,488
-25.0%
Notes:
FY 2014 Import Demand = 76,614 acre-feet.
1. The total imported water available subject to change based on the certification of local production at the end of a fiscal year.
2. Regional reduction level percentages are based on FY 2014 imported water demands, not the base period demands. The reduction levels also apply to the region as a whole, not to the individual retail agencies.
Appendix B attached to the ordinance codified in this chapter includes an overview of Metropolitan's WSAP methodology for shortage allocations. Western will use a process similar to that of Metropolitan to allocate imported water supplies among the retail water agencies within Western's general service area. Agencies that purchased water in the Metropolitan base period (fiscal years 2012-13 and 2013-14) share in the allocation of imported water. These agencies include: Box Springs Mutual Water Company, the City of Corona Department of Water and Power, Eagle Valley Mutual Water Company, Elsinore Valley Municipal Water District, Lee Lake Water District, Metropolitan, the City of Norco, Rancho California Water District, and Western Municipal Water District for its retail water service area. The following agencies within Western's general service area did not purchase imported water during Metropolitan's base period and, therefore, are not included in the allocation of imported water supplies: Home Gardens County Water District, Jurupa Community Services District, the City of Riverside Public Utilities, Riverside Highlands Water Company, and Rubidoux Community Services District.
The following table summarizes the estimated imported water supply available to the retail water suppliers within Western's general service area at each of Metropolitan's shortage levels 1 through 10. These values are estimates as the actual volumes of water available to each agency are dependent on the production of local supplies throughout Western's imported agency region and is reconciled at the completion of each fiscal year during which a Metropolitan water allocation is in place.
Shortage Level
Box Springs MWC
City of Corona
Eagle Valley MWC
Elsinore Valley MWD
Lee Lake WD
MWD
City of Norco
Rancho Cali-fornia WD
Western MWD (Retail)
Total
1
88
14,643
488
16,734
3,104
11
171
17,797
19,646
72,689
2
88
14,643
488
16,734
3,104
11
171
17,797
19,646
72,689
3
84
14,275
437
16,639
3,098
10
154
17,455
19,339
71,496
4
81
13,799
411
16,230
3,037
9
143
16,946
18,828
69,489
5
77
13,323
385
15,822
2,976
9
133
16,436
18,317
67,482
6
74
12,847
360
15,413
2,915
8
122
15,927
17,806
65,475
7
70
12,371
334
15,005
2,855
7
111
15,417
17,294
63,469
8
66
11,896
308
14,596
2,794
7
101
14,907
16,783
61,462
9
63
11,420
283
14,188
2,733
6
90
14,398
16,272
59,455
10
59
10,944
257
13,780
2,672
6
80
13,888
15,760
57,488
Appendix A attached to the ordinance codified in this chapter includes spreadsheets detailing the calculation of retail agency allocations under Metropolitan shortage allocation levels 1 through 10.
(Ord. 385 § 2 (Exh. A § 4), 2015)
The following are the implementation elements that are necessary for administering an allocation during a time of shortage. These elements cover the processes needed to declare a shortage level as well as providing a penalty rate structure for enforcing each agency's allocation.
A. 
Implementing an Allocation of Supplies. At this time, it is anticipated that the only time Western would allocate imported supplies from Metropolitan is if Metropolitan is forced to allocate its supplies through its WSAP process.
B. 
Setting the Shortage Level. Should Metropolitan implement the WSAP, Western staff will determine the appropriate shortage level so that supplies allocated at the Western service area level are equal to or less than the Metropolitan allocation. Simultaneously, Western will determine whether any appeals need to be filed with Metropolitan.
C. 
Allocation Period. The allocation period for the DAP will be consistent with the period defined within Metropolitan's WSAP. This allocation period covers 12 consecutive months, typically from July of a given year through the following June. This period was selected by Metropolitan so as to minimize the impacts of varying State Water Project allocations. It was also selected to provide wholesale customers with sufficient time to implement their outreach strategies and rate modifications. Metropolitan has indicated that it is their intention when possible to set allocations through the declaration of a shortage level at the April board of directors meeting preceding the next fiscal year.
D. 
Determination of Penalties. At the end of the allocation year, Metropolitan will bill Western for any accrued penalties. Penalties will be based on the water rates in effect the last day of June of the allocation year. Western will bill its agencies for penalties based on its penalty rate structure. Any excess funds collected will be refunded proportionately to those agencies that paid penalties.
E. 
Allocation Surcharge.
1. 
At the end of each allocation year, Metropolitan will bill Western for any accrued allocation surcharges ("surcharges") based on Metropolitan's adopted WSAP. Western will pass-through Metropolitan's surcharges to its retail agencies (which includes Western's own retail customers) based on Metropolitan's allocation surcharge rate structure described at the end of this section.
2. 
If Western exceeds its total allocation from Metropolitan for the year, the underutilization of any individual retail agency's allocation will be reallocated that year to other retail agencies that exceed their allocation in accordance with the same methodology used when Western exceeds its total Metropolitan Tier 1 maximum. This methodology is described in Western's board of directors-adopted "determining water rates and charges for water user agencies" resolution (this resolution changes from time to time and is currently Resolution 2914). Only retail agencies that had Metropolitan water deliveries in the WSAP base year, and thus contributed to the amount of Metropolitan water allocated to Western, will be included in the underutilization reallocation calculation described in this subsection.
3. 
No billing or assessment of surcharges to retail agencies will take place until the end of the 12-month allocation year unless Western at its sole discretion determines that significant surcharges are probable. In this latter case, Western will use an equitable method of invoicing all or a portion of such anticipated surcharges to retail agencies exceeding their individual allocation. This invoicing will be done prior to the end of the allocation year. At the end of the allocation year and after being assessed any surcharges by Metropolitan, Western will reconcile any collected surcharge revenue and issue invoices or credit memos to retail agencies accordingly, with invoice payment terms consistent with those described in the current applicable resolution (referenced in the previous subsection). The purpose of this latter provision is to reduce Western's risk from collecting significant receivable amounts after the end of the allocation year. If at the end of the allocation year Western does not incur any surcharges from Metropolitan, then individual retail agencies will not be invoiced for surcharges (or will be refunded any surcharges paid in advance of year-end).
4. 
Metropolitan's surcharge is based on the costs that Metropolitan and its member agencies are incurring to implement outdoor water use reductions through turf removal programs. The surcharge is designed to provide a price signal based on the marginal conservation costs incurred to reduce water use in dry and shortage years. Any revenues collected by Metropolitan from the surcharge would be used to fund the implementation of the turf removal program, or other similar programs designed to conserve water and reduce future demands.
5. 
Metropolitan is currently paying $2.00 per square foot of turf removed. The estimated water savings is 44 gallons per year for each square foot of turf removed for a period of 10 years. Based on this savings rate, the estimated cost of the program is $1,480 per acre-foot. Water use between 100 percent and 115 percent of a member agency's water supply allocations would be charged with a surcharge of $1,480 per acre-foot. Water use greater than 115 percent would be charged two times the surcharge or $2,960 per acre-foot. Two times the surcharge would allow the funding of additional turf removal and conservation programs to conserve additional water and further reduce demand or, if appropriate, allow for a higher per square foot incentive payment. The surcharge rates are assessed in addition to the normal rates for Metropolitan water purchases. The penalty rate structure is summarized in the table below:
Water Use
Allocation Surcharge in Addition to Cost of Water
100% of Allocation
$0
Between 100% and 115%
$1,480
Greater than 115%
$2,960
6. 
Below are three potential scenarios related to the assessment of the surcharge:
a. 
Scenario 1: Retail agency water deliveries are less than Western's Metropolitan allocation. The result after the allocation year would be that retail agencies would not owe any surcharges even if agencies are over their individual allocation.
b. 
Scenario 2: Retail agency water deliveries are over Western's Metropolitan allocation, but less than 115 percent. The $1,480 per acre-foot surcharge would be assessed only to retail agencies that exceed their individual allocation after taking into consideration the proration of underutilized allocation.
c. 
Scenario 3: Retail agency water deliveries are over Western's Metropolitan allocation by more than 115 percent with individual agencies' exceedance varying. First, underutilized allocation would be prorated to the water deliveries that are over by 100 and 115 percent, with the balance assessed a surcharge of $1,480 per acre-foot. Any water remaining that exceeds 115 percent would be assessed a surcharge of $2,960 per acre-foot (two times $1,480).
(Ord. 385 § 2 (Exh. A § 5), 2015)