Stage 6 Stage 6 Water Rationing (Rule 166) is the response to “high risk” water supply conditions and requires a 35 percent system-wide reduction. Stage 6 Water Rationing also enacts a moratorium on water permits that propose to use public or private water use credits. Restrictions on non-essential outdoor water use may occur during this stage. Restrictions implemented in previous Stages remain in force.

Stage 7 Stage 7 Water Rationing (Rule 167) is the response to “extreme” water supply conditions and requires a 50 percent system-wide reduction. Restrictions on non-essential outdoor water use may also occur during this stage. Stage 7 includes a moratorium on use of portable and hydrant water meters. Restrictions implemented in previous Stages remain in force.

per capita plan

“Per capita” rationing was requested repeatedly during the process of developing the Expanded Water Conservation and Standby Rationing Plan (Regulation XV) in 1998. Sources of input included comments at public hearings and discussions with the Public Utilities Commission (PUC) staff, the Technical Advisory Committee (TAC), the Policy Advisory Committee (PAC), and the Citizens Conservation Committee (CCC). The approved Plan (i.e. Regulation XV) employs a per-capita conservation rate design. For residential uses, the per-capita rate design has five sharply ascending blocks; for other categories, there are two ascending blocks. The per-capita conservation rates are census-based and assign a base rate to each customer that reflects the number of persons in a home and the size of the property. Conservation is rewarded with a lower rate block, and water use above the base rate significantly increases in each of three top blocks. This increasing block rate structure has been in place since 1997. CAW will be requesting additional blocks for non-residential users in its next General Rate Case filing.

During Stage 5 and higher levels of water rationing, each residential user will be assigned an equal portion of the water available to residential users. The strength of a per-capita rationing system is that all residents are treated equally. Water rations for residential uses are based on the overall number of residents in the system and the total rationed water available to residential users. Properties with large landscapes and two residents are given the same ration as smaller properties with two residents. After the 1989-91 rationing program concluded, per capita rationing was perceived by the public as the only fair way to ration residents in the future.

Similar to the residential per-capita rations, non-residential users must also reduce according to the amount of the overall water supply used. CAW tracks monthly water use for the following non-residential water use categories: Commercial, Industrial, Public Authority, Golf Course, Other, and Non-Revenue Metered Use. The plan reduces water use in each user category by the reduction amount corresponding to the Stage implemented.

Board policy decisions

Staffing/resources needs and possible revisions to Regulation XV are two areas that need review by the Board prior to finalization of the Stage 4 through 7 Implementation Plan. Resolution on these issues appears to directly impact the program and should be given highest priority.

staffing/resources impact

The Board should consider the organizational structure. As proposed, the Water Demand Manager leads the rationing program through a newly-created Rationing Program Administrator and subordinate staff positions.
The Board should consider fringe benefits to be received by rationing staff as recommended by the District’s Human Resources Specialist.
The Board should consider the efficiency of temporarily relocating the Water Demand Division to the same building/space as the rationing program vs. two distinct locations utilizing shared files, or authorize a massive electronic filing effort prior to rationing.

Regulation/policy amendments

Moratorium timing. The Board should consider adoption of some flexibility to the October 1 Stage 5 and Stage 6 moratorium implementation dates when necessary to reduce future water demand. No noticeable reduction in construction will occur for some time after a moratorium is initiated. Therefore, the effect of this action is minimal unless rationing is prolonged, although instituting a moratorium provides a message to the community that the water shortage is serious. Any moratorium will impact the construction industry.
CAW’s unaccounted for water use above seven percent is considered “Non-essential water use.” CAW is in the process of having a professional evaluation of its system to identify where the unaccounted for water may be, but that report is not expected to be completed before Winter 2007 or Spring 2008. That said, in Stage 5, CAW is subject to a water waste citation for non-essential water use for continuing to exceed the seven percent threshold. Suspension of a water waste violation may be prudent pending completion of the second phase and development of conclusions from the system-wide audit. The Board may want to calendar a report on the system audit and schedule a time/date for action on modifying the unaccounted for water target as an assurance that CAW will complete its audit in a timely manner. Without action resulting from the audit by a predetermined date, CAW could be subject to water waste fees.
Increase outdoor water use restrictions.

Require all large water users or large non-residential water users to install Smart irrigation system controllers and maintain water use within a reduced water budget established by a certified Landscape Irrigation System Auditor, or
Eliminate outdoor water use entirely. During Stage 5 of Regulation XV, there are no restrictions on outdoor water use other than water waste and Non-essential water use related to unreasonable or excessive use, including washing of hard surface areas and buildings and irrigating between 9:00 a.m. and 5:00 p.m. on add/even days.

The CAW and non CAW resource limits (i.e. production limits) described in Rule 32 (Exhibit 3) are used as the basis for calculating the water available to meet the percentage reduction in Stages 5-7 for distribution systems located within the Monterey Peninsula Water Resources System (MPWRS). The current production limits do not reflect either SWRCB Order No. 95-10 or the Seaside Ground Water Adjudication decision. The Board should consider decreasing CAW’s production limit (codified in Rule 32) from the MPWRS to reflect these resource limitations. Reducing the production limit would increase the water savings the community would have to achieve to stay within the rations.
Similarly, production limits for non CAW users subject to the Seaside Basin Adjudication decision (i.e. Bishop, Ryan Ranch, Hidden Hills and Seaside Municipal) should be considered for adjustment based on the court’s ruling. Other water distribution systems within the constricted areas should also be included in any production limit adjustments. As with the MPWRS systems, a reduction in the production limit would increase the level of effort the community would be required to undertake to stay within the rations.
The Board should consider directing staff to establish production limits for all water distribution systems subject to rationing.

Use actual use as the base for a specified time period.
Assign staff to review uses and assign production limits on systems that have no production limit.
Prioritize production limit review to higher use systems.

Add the Laguna Seca area water distribution systems in rationing of the main CAW system due to the Seaside Adjudication decision. The Board has already directed that this action be considered as a separate strategic objective.
Add emergency excess use rates to all water distribution systems effective upon implementation of Stage 5. CAW has given a preliminary indication that they support this action and has recommended that the District is the appropriate party to file a special application with the CPUC. Without CPUC action to authorize excess use rates for rationing purposes, excess use rates cannot be implemented during Stage 4 and above.
Consider grouping multiple meters that service one site together. The grouped meters would be assigned a single ration with the following exceptions:

Distinct tenants should have individual rations.
Enforce against the account holder, not the property owner.

Approve a list of Best Management Practices for various non-residential uses. Staff is in the process of developing this list.
Approve administrative guidelines for Water Rationing Variances (Rule 169) developed in consultation with Water Demand Committee and approved by the Board. Rationing variances are considered for things such as livestock drinking water and emergency, extreme or unusual circumstances. Guidelines need to be developed to provide direction to staff on when and how to grant these variances and for what quantities of water. The guidelines should also address when variance requests should be reviewed by the Board or Water Demand Committee.
The District and CAW entered into a Non-Disclosure Agreement in June 2000 to protect the ratepayers from public disclosure of their water use (Exhibit 4). The agreement takes the place of a formal proceeding before the California Public Utilities Commission to obtain access to customer records for specific purposes. The rationale for the agreement was to facilitate District access to confidential customer consumption information for two purposes: (1) to analyze the past efficacy of its water transfer programs and (b) to enable the District to enforce its Expanded Water Conservation and Standby Rationing Plan (Regulation XV). However, the agreement falls short in that it allows access to consumption information for specific CAW customers subject to enforcement procedures under Regulation XV or other investigations identified by the District’s General Manager, rather than allowing MPWMD staff complete access to all unspecified customer consumption data as is required to implement Stage 5 rationing. The Board should direct staff to request authorization for access to consumption records for rationing purposes from CAW and/or the CPUC.

IMMEDIATE ACTIONS NEEDED

The following actions should be considered for budgeting and immediate implementation:

· Public Outreach Plan

· Computer programming/website design

· Update conservation regulation to take into account current Best Management Practices

· Implement enforcement of mobile water distribution systems

· Prepare job descriptions and recruiting announcements for rationing staff

· Seek reimbursement from CAW for expenses related to MPWMD emergency rationing costs (A0502012, Special Request 6/9)

· Adopt a revised enforcement ordinance

· Adopt revisions to Regulation XV

· Request access to customer consumption records from CAW

· Formal requests to CPUC for excess use rates for systems other than the main CAW water distribution system, and if necessary, for access to customer consumption records for rationing purposes

· Amend Regulation XV to include excess use rates for Bishop, Hidden Hills and Ryan Ranch systems during Stages 3-7.

PERSONNEL

a. PERSONNEL FOR sTAGES 5-7

The need for additional operational support during Stages 4-7 is apparent based on the District’s experience with rationing in the past. During the last rationing program in 1989-91, the highest Phase III rationing (20%) required a full-time staff of 14 to administer. Public criticism early in the program led to an increase in staff that eventually included a manager, a Supervising Conservation Representative, seven Conservation Representatives, a Hearing Coordinator, an Office Specialist, a Clerical Assistant, an Applications Programmer and a Data Management Assistant. Even with this level of staffing, field work (e.g., inspections and water waste investigations) was basically non-existent and hearings were delayed.

Based on this last experience, the District should assume for planning purposes that rationing at Stages 4-7 could last for a period of 3 years. The District must also realize that the success of a rationing program is based on the ability of the staff to carry out their mission without the strain of inadequate staffing. It was apparent after the last rationing program that quality staff, capable of handling the workload, is a critical component of the program. This is achieved by providing sufficient compensation for the level of work, and by providing adequate training, supervision, workspace and equipment. It is also imperative that this staff work side-by-side with the existing Water Demand Division staff to facilitate record sharing and cohesion of the program objectives.

The Expanded Water Conservation and Standby Rationing Plan (Regulation XV) was adopted in 1998 and its rationing Stages 4-7 have not been implemented to date. For this reason, the exact level of service that will be required to successfully fulfill the operational needs of the program are unidentified. However, using the lessons learned from the last rationing period, the staffing for Stages 5-7 must include at a minimum:

Recommended Supervisory Staff

1) Water Rationing Administrator reporting to the Water Demand Manager

2) Senior Rationing Specialist reporting to the Water Rationing Administrator

These positions would be filled competitively. Both internal and external candidates would be considered for both positions. If a current Water Demand staff member was selected for either position, they would be given a temporary promotion and allowed to return to their former position upon the end of rationing work.

Recommended Non-supervisory Staff

1) Two or more Water Rationing Specialists to handle each of the following areas:

a. Hearing coordination/preparation

b. Research

c. Conservation/Inspections

d. Public communications

2) Two or more Water Rationing Technicians (data managers)

3) Two Office Specialists

The lack of benefits was a demoralizing factor in the District’s rationing history. Staff was hired as “contract employees” with no benefits. There was substantial turnover and rationing staff protest regarding legal benefit entitlement. After review, it was also concluded that PERS retirement coverage and health insurance benefits were required under California Public Employees Retirement System (CALPERS) for all full-time employees hired on appointments for over 1,000 hours in a fiscal year. In addition CALPERS Health Insurance regulations required coverage for employees who worked full time on appointments over 6 months.

In light of this history, and the likelihood that staff hired would have tenures of 1-3 years, it is recommended that rationing staff be brought on as regular staff, with the appropriate benefit package. The functions of the individuals occupying these new positions, would be similar to some of those performed by the Conservation Technician and Conservation Representatives in the Water Demand Division. However, the scope of duties would be largely confined to the implementation and enforcement of water rationing ordinances, with a much more narrow scope and shorter learning curve. Because of this narrow scope of function, it is recommended the majority of positions be placed in newly created Water Rationing job classifications, set at a lower place on the District salary chart. The exception would be the clerical support staff, whose general office would make placement in the District’s current Office Specialist classification appropriate.

Water rationing positions would be subject to the provisions of the Memorandums of Understanding with LIUNA UPEC Local 270, regarding Reduction in Force, when they were no longer needed. These provisions specify that employees are placed on a layoff list within their job classification. Therefore, eventual elimination of the rationing staff would not effect any classifications currently in use at the District, with the exception of Office Specialist. In that case, the last hired regular full-time Office Specialist would be the first laid off.

Position titles and proposed salary ranges

Water Rationing Administrator Range 34

Senior Water Rationing Specialist Range 28

Water Rationing Specialists I/II Ranges 18 and 22

Water Rationing Technician Range 16

Office Specialists I/II Range 10 and 12

personnel costs

Water Rationing Administrator - $87,838 annualized

Senior Water Rationing Specialist - $79,431 annualized

Water Rationing Specialists I/II/s budgeted at the I level - $67,960 annualized

Water Rationing Specialists I/II/s budgeted at the II level - $72,207 annualized

Water Rationing Technician - $65,987 annualized

Office Specialist I/II’s budgeted at the II level - $61,710 annualized

Estimated personnel costs at full staffing are approximately $700,000. Funding for the costs of rationing are paid by CAW using a memorandum account approved under Special Request 9 of the 2006 General Rate Case Decision A0502012 and A0502013.

C. training

Immediately upon hire, rationing program staff will begin training overseen by the Water Demand Manager, a Senior Conservation Representative or a Conservation Representative II from the Water Demand Division. All staff will receive basic training related to:

General District functions and organization
District and rationing office facilities
Office equipment
Reporting levels
Rationing regulations
Rationing database and functions
Conservation regulations
Non-Disclosure Agreement with CAW
Customer service standards

In addition, specific training will be done in the following areas as required to perform the functions of the position:

Data entry
Hearing staff reports
Ration adjustments
Inspecting for Best Management Practices
Water waste enforcement process
General correspondence

D. space needs

The existing District office facility does not have space available to accommodate a rationing office. Off-site space will be needed, preferably within the Ryan Ranch Office Park. According to a local commercial real estate specialist, office space in the Ryan Ranch area would cost between $2-$2.75/square-foot. Using an estimated square-footage of 2,000 square-feet at $2.50/sf, the monthly rent for office space would be $5,000. The size and cost of adequate space to accommodate a rationing office and possibly the Water Demand Division will be developed further prior to implementation.

Access to the property files in the Water Demand Division is essential to successful implementation of the rationing program. These files are not currently in digital form, although electronic files are a goal of the Water Demand Division Database Project. The need to retrieve hard files from the Water Demand Division is a dilemma. To accommodate this need, the following options are offered:

A dedicated rationing office staff-member could work in the Water Demand Division with the sole duty of retrieving, scanning and emailing property files as needed in the rationing office. This staff member would also ensure that all paperwork generated in the rationing office is filed in the Water Demand Division files;
A concentrated effort could be made to scan and electronically file the Water Demand Division’s property files. This effort will be undertaken as part of the database project, although the specific parameters of the electronic filing system are not known at this time. It is anticipated that the database project will be under contract by December 2007, at which time this option could be pursued with direction from the programmer.
The Water Demand Division could be temporarily relocated to the site where the rationing office is located, allowing for continuity between the two programs. However, this would result in vacant space at the District’s main office for the duration of the rationing program.

public education and outreach

Public information campaigns continue to be the most popular way of encouraging water users to adopt water conservation behaviors during drought. Primary objectives include: (l) persuading the consumers that they should conserve water, and (2) providing them with information on how to do so. The joint effort at public outreach by California American Water and the District has been successful in reducing per capita water use on the Peninsula. So much so, in fact, that water conservation here is considered a model for other areas. However, ongoing conservation efforts over the past several years have resulted in a reduction in elasticity from which to obtain additional savings. Hard water savings through retrofitting has been a priority of the District since 1987. Behavioral water savings have been encouraged since SWRCB Order No. 95-10 in July 1995, and have been particularly requested when water use has approached the limit set by the state.

During drought periods, it is crucial that the District, CAW, and other water distribution system operators work together to communicate a consistent message regarding the local water situation. It is also essential that the message coincide with the implementation of the various stages of rationing. During the previous rationing, it was noted, “Haste in adopting the rationing program (the initial ordinance was adopted just 19 days before it became law), made the provision of public educational materials on a timely basis impossible. The implementation of water rationing did not always coincide with the information getting out to the public.” For this reason, public education materials and advertising must be developed as far in advance of rationing as possible and kept on the shelf until needed.

During the 1989-91 rationing period, the theme was “Save Your Share.” This theme reflected early concerns about program fairness. Stages 5 through 7 are about fairness. Although the art-work is no longer available for the previous ads, the District may want to breathe new life into the old rationing theme and use the old material as the basis for rationing ads. The advantage to using old material is that it would substantially reduce advertising development costs. Examples of the previous advertising campaign are found in the Final Report, Phase III Water Rationing (Exhibit 5).

Establishing a partnership with local media outlets is another important aspect of a successful public outreach campaign. As part of the material developed for the rationing program, the General Manager, Water Demand Manager, and the Water Rationing Administrator should make every effort to secure media interviews through press conferences and releases, one-on-one contacts, media kits, etc. In addition, the purchase of air time through the public television broadcasting stations for the purpose of airing a rationing program slide show (PowerPoint) would further reach the television audience. These efforts would be coordinated with CAW’s General Manager, Community Relations Manager and water conservation staff.

Finally, it is extremely important to secure the support of other local public agencies. Local land use jurisdictions within the District, along with the local federal installations/offices, must be encouraged to place a high priority on enforcement of water use restrictions. Ideally, each public entity would partner with the District in the enforcement effort, sending a unified message to the community.

outreach plan components

Develop and implement a Rationing Program website, including on-line electronically transmitted forms and an on-line payment service.
An E-Newsletter with weekly or bi-weekly updates on the rationing program delivered accurately and with timely information to other parties, including local governments, news media and water users.
Presentations to all City Councils/Board of Supervisors, at a minimum. Also regular updates during Oral Communications at public meetings.
Presentations to local service organizations, homeowner’s associations, clubs, MPC, CSUMB, etc.
Information booths at fairs, festivals and other publicly-attended events, particularly those appealing to local water users.
Targeted media placements

Ads in daily and weekly papers

Stage information
Rebate program facts
Drought message with local drought pictures (make it real and personal)
Everyone must help message
Ways to save and ways to save more

Inserts in papers

Public Service Announcements on radio and television
Movie theater conservation ad
Small conservation messages in sponsored event programs
Billing inserts (required by Regulation XV)
Local “hot line” for telephone calls
Conduct enforcement and compliance training sessions with local governments.
Identify and communicate the location of sources of sub-potable water supplies available to the public that do not impact the rationed areas to substitute for potable sources of construction water, dust control, etc.

Public outreach is estimated to cost approximately $300,000 annually during rationing. This estimate is based on advertising costs budgeted by CAW for the 2007 summer water conservation campaign.

Enforcement

The Board is scheduled to begin consideration of an ordinance to add an administrative citation enforcement provision to the Rules and Regulations. The following is an outline of the current process (i.e. Rule 171):

Water users are given an opportunity to correct the first occurrence of water waste or non-essential water use, as those terms are defined by Rule No. 11 (Definitions). Water waste or non-essential water use which continues after the user has had reasonable notice to cease and desist that type of water use shall be considered a flagrant occurrence.
A $50 fee per day is assessed for each flagrant occurrence of water waste or non-essential water use. The fee shall accumulate daily until the occurrence is corrected. Note: It is difficult to pinpoint exactly when correction of a violation occurs without documentation from a professional repair person.
A $150 fee per day is imposed for each subsequent occurrence (including multiple occurrences) of water waste or non-essential water use which occurs within 18 months of the first occurrence. The fee accumulates daily until the occurrence is corrected. (See Note above.)
All fees are to be paid within 30 days.
Within the 30 day period, a water user may seek waiver or forgiveness of all or part of the water waste fees on the basis of hardship. The water user must provide the District with a written explanation as to why the fees should not be collected. Staff is authorized to determine whether or not fees should be waived in full or in part, with the final decision resting with the General Manager.
After 30 days, fees which have not been paid or waived may result in a lien being placed on the property served by the water account. This is problematic when the water waste is not caused by the property owner. The proposed administrative enforcement procedure would address this situation.
Repeated occurrences of water waste or non-essential water use may result in the placement of a flow restrictor within the water line or water meter.
Decisions related to enforcement of water waste or non-essential water use are appealable.

Data management needs

Hardware, software and programming

overview of data management

Two public criticisms of the previous 1989-91 rationing had to do with inadequate computer hardware and programming staff turnover. The information system utilized by the Rationing Office in 1989-91 was designed to monitor the consumption of the District’s water users, match it against their ration derived from their base year history, census, optional baseline or variance allocation, and generate letters for those accounts exceeding their ration. It also provided a record of water usage, excess usage, variances, hearing panel decisions, and surcharges for each account. At one time, the information system included 57 different databases; these were eventually reduced to six.

The rationing databases were DOS-based Foxbase+ databases. The main rationing database used daily CAW dumps of consumption data. During the 28 months of rationing, the office employed five different computer programmers. This rapid turnover led to disorganization and confusion. During the last nine months of rationing, information management improved considerably when a programmer was hired who stayed through the conclusion of rationing.

The former Foxbase+ system could be dusted off and used in the event that rationing is required before a modern web-based system could be completed. The former DOS-based system does not provide the web-based applications that will enable rationing staff to respond to customers in a judicious manner and to which the public is accustomed to. The old database would require modifications to adjust to changes CAW made in its data system in 2001 if it were required as an interim system during development of a web-based system. The old system would also require regular oversight from the District’s Information Technology Manager. There would be significant impacts related to shifting the IT Manager’s workload to accommodate the rationing database. These impacts and costs are not quantified at this time. The cost of developing a modern web-based system is preliminarily estimated at $100,000.

As a final point, access to the Water Demand Division database(s) is essential to successfully managing rationing data. In 2007, there are three databases used to record property information related to conservation: Permits, Conservation (i.e. change of ownership/use) and Rebates. The terminals used by rationing staff must have access to these databases to avoid conflicts between the rationing and conservation/permit programs.

software

District staff has identified appropriate programming necessary to make adequate data available to enforce the rationing program envisioned in Regulation XV. Still unresolved is by whom and how a rationing data system will be designed. Staff has also requested a data analysis from CAW to determine if the non-residential water factors are adequate for rationing. Until this information is available, proceeding with database programming is not recommended.

Prior to embarking on programming, the Board needs to determine what changes are needed to implement a fair and enforceable rationing program. This is a top priority, and programming should commence on a fast-track at least six months prior to the anticipated implementation date.

The following data management needs have been identified:

CAW consumption data (and other water distribution system data) must be retrievable by District rationing staff;
System production limits apply to all users within a system;
Program calculates rations based on input for production limit, percentage reduction and historical percentage by user group (for non-residential customers);
Access to census data is required;
Residential rations must be input and adjustable as a group based on the number of residents;
All other user groups must have rations calculated by the system based on the factor used;
All rations must be adjustable to accommodate variances;
“Water Banks” must be developed for each customer;
System must generate enforcement letters and envelopes when prompted (i.e. warning, notice, final notice, posting notices, etc.);
Accounts receivable;
System must be able to link into new Water Demand Division database as a component.

hardware

During the first 18 months of rationing in 1989, the staff shared one computer for data entry and programming, and three “dumb” terminals for viewing data. This deficiency was likely due to the initial assumption that rationing could last only a short time. Following the report of the Rationing Review Committee, in March 1990 (Exhibit 6), additional computer terminals and staff were added and the system was considerably upgraded.

This Implementation Plan assumes that rationing will continue for at least one year, and that each office employee will be using a computer terminal for most of their work. A comparison of costs for leasing and purchasing will occur prior to action to obtain computer hardware. It is anticipated that purchasing equipment will be comparable in cost to leasing. The preliminary estimate for computer equipment is $96,300. This estimate is from the District’s Information Technology Officer based on his professional knowledge and includes a copier/printer/scanner. Copies of the estimates for initial purchase of computer-related equipment are attached as Exhibit 7.

website

The Internet is a valuable tool for educating the public and for disseminating information. In addition to serving as an interactive method of education, the Internet provides a valuable mechanism for collection of fees. It is recommended that a website be designed specifically for the rationing program. The rationing website should have basic information about the program, conservation information and links, frequently asked questions, various electronic forms related to the program (i.e. survey forms, variance requests, appeals, etc.), email addresses for rationing staff, etc. It should also provide the convenience of electronic payment of fees by bank transfer or credit card.

budget

CAW Special Request 6 (SR6) provides for establishment of a memorandum account for expanded conservation and rationing costs billed by the District. This memorandum account was authorized by the CPUC in the previous General Rate Case (GRC), and was reauthorized under the same terms. SR6 allows reimbursement by CAW for expenses up to $100,000 annually in the 2006 GRC.

Special Request 9 (SR9) is also a memorandum account specific to MPWMD emergency rationing costs. This memorandum account was also approved in the previous GRC (D0302020, OP 5) and does not state an annual limit. SR9 allows the District to recoup its costs for expenses related to rationing.

Start up costs for the rationing program could initially be accommodated by tapping the District’s conservation reserve fund, currently at approximately $340,000 (July 2007). Expenditure of funds from the reserve would be replaced upon reimbursement by CAW.

PRELIMINARY RATIONING COST ESTIMATES September 2007
	Start Up	Fiscal Year
Personnel		700,000.00
Legal Fees		100,000.00
Hardware/Software	96,300.00	5,000.00
Database Programming	100,000.00	10,000.00
Rent		60,000.00
Public Education/Outreach (including mailing costs)		300,000.00
Travel and Transportation		3,500.00
Training	7,000.00	7,000.00
Furniture and equipment	50,000.00	5,000.00
Legal Notices		30,000.00
Office Supplies	10,000.00	6,000.00
Miscellaneous		10,000.00
Total	263,300	1,236,500