HomeMy WebLinkAbout2025/12/02 City Council Resolution 2025-090 RESOLUTION NO. 2025-090
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
ROHNERT PARK ADOPTING WATER SERVICE RATES (YEARS 2026-2029)
WHEREAS, the City exercises its constitutional authority to establish, operate, and
regulate a water service system, pursuant to California Constitution, Article XI, section 7,
and as set forth in Rohnert Park Municipal Code Chapter 13.44; and
WHEREAS,Section 13.44.030 of the Rohnert Park Municipal Code provides that the
City Council shall, by resolution, establish rates for water service; and
WHEREAS,Resolution No. 2022-020,adopted by City Council on February 8 2022,
established water service rates which were enacted for 2022 - 2026, with authorized annual
increases January 1 of each year; and
WHEREAS, the City hired Hildebrand Consulting ("Consultant") to review the
City's current water service rates to determine if they generate sufficient revenue over time
to pay for the City's ongoing costs to provide the water service, including costs for
maintenance and replacement projects, ongoing operations costs, and any planned major
capital projects;and
WHEREAS, Consultant prepared the 2025 Water Rate Study Report dated
September 15, 2025, ("Rate Study") that determined the total costs of providing the water
service utility to City customers and calculated the proposed water service rates to be charged
to each customer class based on their proportionate impact on the water service system (the
Rate Study is incorporated herein by reference); and
WHEREAS, at a public meeting of the City Council on August 26, 2025, the City
Council approved Resolution No. 2025-066 to establish Utility Rate Setting Procedures (for
Water Rates and Sewer Rates),by which the City provides an opportunity for property owners
and tenants to submit to the City a written objection to identify substantive reasons why a
proposed update to utility rates does not comply with legal requirements under California
Constitution Article XIII D, Section 6 (a.k.a., Proposition 218), and this process must be
followed by property owners and tenants as a condition to challenging utility rates in court(a
requirement to exhaust administrative remedies in accordance with"AB 2257,"Government
Code Section 53759.1); and
WHEREAS, at a public meeting of the City Council on September 23, 2025, City
staff presented the Rate Study which found: (a) current water service rates are insufficient
to support the increasing costs of operation, maintenance and replacement of the City's
water system, (b) additional revenue is needed to cover the total costs of City water service,
and (c) an increase in water service rates to be paid by City customers is correspondingly
needed and recommended to be implemented for the remainder of fiscal year 2026 along with
annual adjustments each July 1 thereafter until July 1, 2029; and
WHEREAS, at a public meeting of the City Council on September 23, 2025, City
staff presented the Rate Study which also found: that it is necessary to update the Water
Shortage Surcharge Policy which is a tool the City would use to reduce the (potentially
severe)financial impacts associated with reduced water sales and increases in operating costs
during a drought or other water shortage event; and
WHEREAS,the Rate Study, along with supporting notices and documents, has been
made available to the public (online and in paper copy form at the City Clerk's office since
September 26, 2025); and
WHEREAS, the Rate Study recommends the rate adjustments to achieve several
objectives, including:
• Adequate revenues to meet the utility's ongoing service and financial
obligations that will keep up with inflation;
• Adequate revenues to support the needs of the utility's capital program.
WHEREAS, pursuant to California Constitution Article XIII D, Section 6 (a.k.a.,
Proposition 218),prior to extending,imposing or increasing water rates for a property-related
service,the City must provide property owners notice at least 45 days before a public hearing
regarding modifications to the water rates. The notice must contain an explanation of: (1)the
amount of the propose rates, (2)the basis on which the rates are calculated, (3)the reason for
the rate modifications, (4) the date, time and place of a public hearing to consider the rate
modifications,and(5)the rights of property owners to submit written protests to the proposed
rate modifications. The proposed rate modifications may not be imposed if,prior to the close
of the public hearing, written protests are submitted by property owners or tenants
representing a majority of the properties subject to the modified rates ("majority protest");
and
WHEREAS, at the September 23, City Council meeting, Council directed staff to
mail the required notice of public hearing to be held on December 2, 2025, to consider
adoption of the recommended increased water service rates; and
WHEREAS, notice of the public hearing to consider proposed adjustments to the
water rates was mailed at least 45 days prior to the scheduled public hearing as required by
state law (California Constitution Article XIII D, Section 6), and that notice identified the
deadline of November 12 at 5:00 p.m. for property owners or tenants to submit a written
objection in accordance with AB 2257; and
WHEREAS, on December 2, 2025, the City Council held a duly noticed public
hearing on the water service rates identified in this Resolution,and considered the Rate Study,
the agenda report and supporting documents presented by City Staff, any public comments
received prior to that hearing, and all information and public comments related to this matter
as presented at the hearing (specifically including any written objections or written protests
against the proposed water service rates); and
WHEREAS,prior the time of closing the public hearing,the City Council considered
any written objections and written responses prepared by City staff and determined that no
clarification or reduction to the proposed water service rates were warranted, based on the
criteria of AB 2257; and
Resolution 2025-090
Page 2 of 5
WHEREAS, at the time of closing the public hearing for Council's consideration of
this Resolution on December 2, 2025, the City had not received written protests from a
majority of properties subject to the water service rates, and therefore, a majority protest to
the proposed increase in water rates described in this Resolution does not exist.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of
Rohnert Park that effective January 1, 2026, the water service rates set forth in Exhibit "A"
are hereby approved, as described below.
A. The rates set forth in the Table 1 rate schedule column labeled "January 1, 2026"
on Exhibit "A" shall be effective January 1, 2026 Upon that effective date: (1) City
staff is directed to bill customers at those water service rates; and (2) water rates
previously approved by City Council under Resolution No. 2022-020 are hereby
repealed and replaced by these rates.
B. Thereafter, water service rates set forth on Table 1 of Exhibit"A" in each column
respectively labeled: July 1, 2026, July 1, 2027, July 1, 2028, and July 1, 2029, shall
be effective on the date that is the later of: (1) July 1 of the year identified on each
respective column, and (2) thirty days after the date that written notice is mailed to
customers in accordance with Government Code Section 53756(d). The Finance
Director, or designee, is directed to mail the written notice to each customer not less
than 30 days before the effective date of each of the annual adjustments, including an
identification of the effective date of the adjustment. Upon the effective date of each
annual adjustment, City staff is directed to bill customers at the water service rates set
forth in the corresponding rate schedule column.
C. The Temporary Water Shortage Surcharge Structure Rates set forth in Table 2 of
Exhibit"A" shall be effective during the time in which the City Council has publicly
declared a water shortage under Stage 1 through Stage 6,with the rates in effect under
the relevant column for Stage 1 through Stage 6.
BE IT FURTHER RESOLVED that the City Council hereby finds that the above
recitals are true and correct, and, accordingly, are incorporated as a material part of this
Resolution.
BE IT FURTHER RESOLVED that, after due consideration of the entire record
identified in this Resolution, particularly the analysis set forth in the Rate Study, the City
Council hereby finds that the water service rates approved by this Resolution are excluded
from the definition of a "tax," and the water service rates are therefore not subject to voter
approval, in accordance with California Constitution, Article XIII C, Section 1(e)(7) [for the
first finding, below], California Constitution, Article XIII D, Section 6(c) [for the second
finding, below], and California Constitution, Article XIII D, Section 6(b) [for the third
through seventh findings, below]: The City Council hereby finds that the water service rates
approved by this Resolution:
1. are "property-related fees" imposed in accordance with California
Constitution, Article XIII D;
2. are fees or charges for"water services";
Resolution 2025-090
Page 3 of 5
3. will generate revenue in an amount that is no more than necessary to cover the
reasonable cost of providing the water service described in the Rate Study. The
water service described in the Rate Study includes the City's costs of
operation, maintenance, repair, and replacement of the water system;
4. will generate revenue that will not be used for any purpose other than that for
which the charge is imposed,to support the City's costs of providing the water
service. Revenue from the water service rates will be kept in a separate fund
used only for costs related to the provision of water service;
5. are allocated and imposed on ratepayers in a manner that is based on the
ratepayer's burdens on, and benefits received from, the water services
described in the Rate Study, so that the water service rates do not exceed the
proportional cost of the service attributable to the ratepayer's property based
upon pipe size connected to and water consumption for each;
6. will not be imposed upon any parcel for which water service is not
immediately available.
7. are charges imposed for providing water service which is a specific
governmental service provided directly to the ratepayer that is not provided to
those not charged. The water service rates will not be used for general
governmental services that are available to members of the public who are not
required to pay for those services.
BE IT FURTHER RESOLVED that the City Council hereby finds that this resolution is not a
project within the meaning of Section 15378 of the CEQA (California Environmental Quality Act)
Guidelines because it has no potential for resulting in physical change in the environment directly or
ultimately. In the event that this resolution is found to be a project under CEQA, it is subject to the
CEQA exemptions contained in CEQA Guidelines section 15273(a) because it constitutes the
establishment of charges for the purpose of obtaining funds to meet the water utility's financial and service
obligations for ongoing operation and maintenance, debt service, and capital improvements within
existing service areas, and CEQA Guidelines section 15061(b)(3) because it can be seen with certainty to
have no possibility of a significant effect on the environment.
DULY AND REGULARLY ADOPTED BY THE CITY COUNCIL OF THE CITY OF
ROHNERT PARK ON this 2nd day of December, 2025.
CITY OF ROHNERT PARK
Gerard . - f ayor
_
Resolution 2025-090
Page 4 of 5
ATTEST:
Sylvia Lopez Cuevas, City Clerk
APPROVED AS TO FORM:
Michael Barrett, Deputy City Attorney
Attachments: Exhibit A, 5 Year Schedule of Proposed Rates and Water Surcharge Policy
ADAMS: ,C ELWARD L_ RODRIGUEZ: Fail SANBORN GIUDICE: 9(d
AYES: ( ) ES: ( ( ) ABSENT: ( / ) ABSTAIN: ( 95)
Resolution 2025-090
Page 5 of 5
Exhibit A to Resolution 2025-090
City of Rohnert Park Water Rates Effective January 1, 2026
Table 1 - Five Year Water Rate Schedule
Table 2 - Temporary Water Shortage Surcharge Structure
January 1,
2026
July 1,
2026 2
July 1,
2027
July 1,
2028
July 1,
2029
Rate Revenue Increases:14.0% 9.0%9.0%7.0%6.0%
Current
Usage Rates ($/gal.)
Single Family Usage Rate
Tier 11 $0.004133 $0.004712 $0.005136 $0.005598 $0.005990 $0.006349
Tier 2 $0.005718 $0.006519 $0.007106 $0.007746 $0.008288 $0.008785
Multi-Family and Non-Residential Usage Rate
Uniform Rate $0.005013 $0.005715 $0.006229 $0.006790 $0.007265 $0.007701
Fixed Monthly Service Charges
Up to 1"$34.30 $39.10 $42.62 $46.46 $49.71 $52.69
1.5"$63.99 $72.95 $79.51 $86.67 $92.74 $98.30
2"$99.62 $113.57 $123.79 $134.93 $144.37 $153.04
3"$182.75 $208.34 $227.09 $247.52 $264.85 $280.74
4"$301.52 $343.73 $374.67 $408.39 $436.98 $463.19
6"$598.45 $682.23 $743.63 $810.56 $867.30 $919.34
8"$954.75 $1,088.42 $1,186.37 $1,293.15 $1,383.67 $1,466.69
Monthly Fire Protection Service Charge
2"$25.80 $29.41 $32.06 $34.94 $37.39 $39.63
3"$32.85 $37.45 $40.82 $44.49 $47.61 $50.46
4"$41.08 $46.83 $51.05 $55.64 $59.53 $63.11
5"$50.47 $57.54 $62.71 $68.36 $73.14 $77.53
6"$55.15 $62.87 $68.53 $74.70 $79.93 $84.72
8"$75.09 $85.60 $93.31 $101.70 $108.82 $115.35
10"$90.35 $103.00 $112.27 $122.37 $130.94 $138.80
12"$105.60 $120.38 $131.22 $143.03 $153.04 $162.22
1 For the first 3,000 gallons per month
2 This marks a change from the current practice of changing rates on the first of the calendar year.
Proposed
Normal
Supply
Stage 1
Voluntary
Stage 2
Mandatory
Stage 3
Mandatory
Stage 4
Mandatory
Mandator
y
Stage 6
Mandatory
Assumed Demand Reduction-->None 5%15%25%35% 45% 50%
Water Shortage Surcharge 1-->None None 5%10% 17% 22%
Water Usage Rate with Surcharge Applied ($/gallon)2
Single Family Residential
Tier 1 (0 to 3,000 gal/mo)$0.004712 $0.004712 $0.004712 $0.004950 $0.005180 $0.005510 $0.005750
Tier 2 (above 3,000 gal/mo)$0.006519 $0.006519 $0.006519 $0.006840 $0.007170 $0.007630 $0.007950
Multi-Family and Non-Res. (all water)$0.005715 $0.005715 $0.005715 $0.006000 $0.006290 $0.006690 $0.006970
Hydrant Meters $0.007960 $0.007960 $0.007960 $0.008360 $0.008760 $0.009310 $0.009710
Fixed Monthly Charge 3
Service Charge
Notes:
declared by the City Council.
2 This table shows the temporary water shortage surcharges applied to the proposed rate increases for FY 2025/26 for illustrative purposes.
-------------- No changes to the service charge ----------------
1 Temporary water shortage surcharges are incremntal increases in the normal water usage rates appplied during periods of water shortage, as
The percentages shown in this table would be applied to any then-current rates in future years.
3 No changes to the fixed monthly services charges would be imposed as a result of declared water shortages.
RESOLUTION NO. 2025-066
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROHNERT PARK
ESTABLISHING UTILITY RATE SETTING PROCEDURES (FOR WATER RATES
AND SEWER RATES) UNDER PROPOSITION 218, AND ASSEMBLY BILL 2257
GOVERNMENT CODE SECTIONS 53750 THROUGH 53759.2); AND REPEALING
RESOLUTION NO. 2011-25
WHEREAS,The City of Rohnert Park("City")provides utility services for water service
and sewer service to property owners(who may also be referred to as"owners")within the relevant
City service area, and establishes the amount of water rates and sewer rates to be charged
customers in accordance with Rohnert Park Municipal Code ("Municipal Code") Chapter 13.44
and applicable law; and
WHEREAS, California law authorizes the City to charge a fee to the property owners or
property owners' "tenants" (who may be collectively referred to as "ratepayers" or"customers")
for the proportionate cost of providing water services and sewer services to each customer in
accordance with the procedural and substantive requirements of the voter-approved ballot measure
known as "Proposition 218" (California Constitution Article XIII D; as it is implemented by the
Legislature at Government Code sections 53750—53759.2;and as it has been judicially interpreted
by appellate court decisions). The City refers to those fees as water rates and sewer rates (which
may be referenced herein individually as"water rates"or"sewer rates,"or referenced collectively
as"rate"or"rates"); and
WHEREAS, Under Proposition 218, the City's water rates and sewer rates are each
considered to be a "fee" for a "property-related service" (also referred to as a "property-related
fee"), subject to the particular requirements of Constitution Article XIII D, Section 6. A property-
related fee is one imposed upon any parcel or person as an incident of property ownership. In
general, the City may only increase its existing rates if the City (1) calculates the rates in
accordance with Proposition 218, (2) conducts a public hearing before the City Council ("City
Council"), as described in this resolution, and (3) a"timely written protest" is not submitted by
property owners representing a majority of the parcels served by the City; and
WHEREAS, Under Government Code sections 53759.1 and 53759.2 ("AB 2257";
Chapter 561, Statutes of 2024), the City may establish a supplemental process for objecting
property owners to exhaust administrative remedies, also described in this resolution, by which
the City will take specified actions in response to any "timely written objection." Any timely
written objection will also be counted by the City as a timely written protest. However, under this
process, only an owner who submits a timely written objection will have a right to challenge a
proposed increase in sewer service charges through a legal proceeding. (These supplemental
processes were authorized by Assembly Bill No. 2257, Chapter 561, Statutes of 2024, effective
January 1, 2025.); and
WHEREAS, the purpose of this resolution is to provide a meaningful opportunity for a
property owner to submit a written objection to a proposed new or increased rates before resorting
to litigation after the new or increased rates are approved by the City Council; and
WHEREAS, this resolution is intended to provide a procedure for property owners to
submit a written objection regarding a new or increased rates to the City's attention early in the
rate consideration process, and to provide an opportunity for the City to address or resolve any
objections before the City Council makes a final decision on whether to adopt a proposed rate
pursuant to Proposition 218; and
WHEREAS, this resolution will identify the process the City will follow in order to
implement the administrative remedies to be exhausted by property owners under Government
Code sections 53759.1.In general,the City will make available the proposed rates,post the written
basis for the proposed rates on its internet website,provide 45 days for a property owner to review
the proposed rates and timely submit to the City a written objection to the rates that specifies the
grounds for alleging noncompliance with Proposition 218, and require the City to consider and
respond in writing to timely submitted objections prior to the close of the public hearing described
in these recitals; and
WHEREAS, for any rates approved by the City implementing the procedures described in
this resolution, a person or entity shall be prohibited from bringing a judicial action or proceeding
alleging noncompliance with Article XIII D of the California Constitution for those rates, unless
that person or entity has timely submitted to the City a written objection to that rate that specifies
the grounds for alleging noncompliance with Proposition 218; and
WHEREAS, the City Council hereby intends to adopt the exhaustion of administrative
remedies procedure as outlined in Government Code section 53759.1, and the administrative
record principles contained in Government Code section 53759.2; and
WHEREAS, the City Council previously adopted Resolution No. 2011- 25 to establish
procedures for conducting protest hearings for property related fees (such as the water rates and
sewer rates) in accordance with Proposition 218, and the City intends Resolution No. 2011-25 to
be superseded and replaced by this resolution in order to establish procedural implementation of
Proposition 218 as well as AB 2257.
NOW, THEREFORE, BE IT RESOLVED, by the City Council of the City of Rohnert
Park, as follows:
A. The City Council hereby adopts the utility rate setting procedures attached hereto
as Exhibit "A," and incorporated herein by reference ("Utility Rate Setting Procedures"). The
Utility Rate Setting Procedures explicitly incorporate and implement the requirements contained
in Proposition 218 and the procedures by which property owners are required to exhaust
administrative remedies as set forth in Government Code section 53759.1, subdivision(c).
B. For any rate adopted or approved by the City implementing the procedures
described in this resolution, a person or entity shall be prohibited from bringing a judicial action
or proceeding alleging noncompliance with Article XIII D of the California Constitution for those
rates,unless that person or entity has timely submitted to the City a written objection to those rates
in accordance with this resolution that specifies the grounds for alleging noncompliance with
Proposition 218.
C. The City Council hereby adopts the administrative record principles contained in
Government Code section 53759.2.
Resolution 2025-066
Page 2 of 3
D. This resolution will take effect immediately upon adoption by City Council, and
will apply to any proposed new or increased rates of which notice is provided in accordance with
this resolution.
E. The City Council authorizes the City Manager to take such other and additional
actions as may be reasonably necessary to implement the purpose of this resolution and implement
the exhaustion of administrative remedies procedure adopted herein.
F. The City Council hereby repeals Resolution No. 2011-25.
DULY AND REGULARLY ADOPTED BY THE CITY COUNCIL OF THE CITY
OF ROHNERT PARK ON this 26th day of August, 2025.
CITY .
40,
O ERT PARK
y-A.W.
IdGi •' ,ayor
ATTEST:
Sylvia Lopez Cuevas, City Clerk
AP R D AS TO FORM:
ich lle Marche enyon, City Attorney
Attachments: Exhibit A, Utility Rate Setting Procedures
ADAMS ELWARD: 4 V 4_ RODRIGUEZ: SANBORN. GIUDICE:
AYES: ( 5. NOES: (AB NT: ( ) ABSTA A
Resolution 2025-066
Page 3 of 3
Resolution No. 2025-066 (Exhibit “A”)
Page 1 of 6
Utility Rate Setting Procedures
These “Utility Rate Setting Procedures” (“Procedures”) describe the processes that will be
followed by the City of Rohnert Park (“City”) in establishing any new or increased water rates or
sewer rates, as summarized in the Resolution identified in the header of this Exhibit “A.” The
Utility Rate Setting Procedures include compliance with Proposition 218 as well as the
procedures for exhausting administrative remedies under Government Code section 53759.1
known as “AB 2257”).
1. Overview of Exhaustion Procedure (AB 2257)
The City will follow the “exhaustion procedure” set forth herein, to be conducted concurrently
with the Proposition 218 process, for the City Council’s consideration of any proposed new or
increased water rates or sewer rates. This exhaustion procedure shall be conducted in accordance
with “Proposition 218” (California Constitution Article XIII D; as it is implemented by the
Legislature at Government Code sections 53750 – 53759.2; and as it has been judicially
interpreted by appellate court decisions), and the particular procedures set forth in Government
Code section 53759.1. The exhaustion procedure provides an opportunity for record owners to
submit a “timely written objection” to identify substantive bases for asserting proposed water
rates or sewer rates do not comply with Proposition 218.
NOTE that a “record owner” may be referred to in these Procedures as the “owner” or
property owner”; and a “record owner” shall include a tenant who is directly liable to pay
the rates. The processes described herein may be referred to as “these Procedures.” As used in
these procedures, the term “rates” may be used to refer to a proposed update to either the City’s
water rates or sewer rates.
a. City staff will post on its internet website a notice of the exhaustion procedure,
and this notice will be prominently incorporated in the Proposition 218 public hearing
notice mailed to each record owner.
b. The notice will identify the date and time by which timely written objections must
be submitted to the City, and the date will be no less than 45 calendar days after the
notice is mailed to record owners.
c. City staff will review timely written objections and draft written responses
providing the substantive basis for retaining or altering the proposed rates in response to
the written objections. City staff will present its written responses to the City Council
prior to the close of the public hearing for the Proposition 218 protest hearing, and the
City Council will review to determine whether action is needed in response to the written
objections or written responses.
d. Following the City Council’s review and response to timely written objections
and written responses, it is within the discretion of the City Council to proceed with the
Proposition 218 protest hearing process, as described herein, to consider approval of the
proposed rates.
e. Rate Challenger Must Exhaust Administrative Remedies. No claim, suit for
damages, suit for injunctive relief, petition for writ of mandamus, or administrative or
judicial proceeding shall be brought against the City (including the City Council, or its
Resolution No. 2025-066 (Exhibit “A”)
Page 2 of 6
employees, officers, or designees) regarding a challenge to the proposed rates unless the
challenging party first exhausts its administrative remedies by complying with these
Procedures and submitting to the City a timely written objection.
2. Notice of Proposition 218 Public Hearing and Initiating Exhaustion Procedure (AB 2257)
Prior to approving or imposing any new or increased rates, the City will conduct a public hearing
and provide prior written notice to each record owner of the hearing and the exhaustion
procedure as described in these Procedures. To the extent the City sends a regular billing
statement for water service or sewer service provided to a “customer” (e.g., a “tenant” or other
ratepayer”) who is not the record owner, the City will also mail the written notice to the
customer at the address for the billing statement. The City will mail the public hearing notice to
each record owner no later than 45 days prior to the public hearing. The contents of the hearing
notice will include:
a. Compliance with Proposition 218:
1) The date, time, and location of the public hearing.
2) The amount of the rates imposed on each parcel.
3) The basis upon which the amount of the proposed rates were calculated.
4) The reason for the rates.
5) The location to which owners must submit written protests via mail, or
personal delivery.
6) If required by Government Code section 54354.5, the notice will identify
the opportunity for record owners to be heard as to whether the proposed rates are
not in compliance with any requirements of the Revenue Bond Law of 1941
Government Code Sections 53000 – 55821), including: (a) are discriminatory or
excessive, or (b) will not be sufficient under the provisions of any outstanding
revenue bonds (including Government Code section 54515).
7) How members of the public may obtain additional information regarding
the proposed new or increased fee, including a link to information that is available
on the City’s website or by requesting a mailed copy. This may include a copy of
the resolution or ordinance by which the proposed new or increased rates are
proposed to be adopted.
b. Compliance with the Exhaustion Procedure for Written Objections. If the City
chooses to follow the exhaustion procedure for written objections, concurrently with
mailing the public hearing notice, the City will post on its internet website the written basis
for the proposed rates and a link to the Proposition 218 public hearing notice which will be
supplemented with the following prominently displayed information:
1) The “deadline” (date and time) by which a “timely written objection” must
be submitted to the City. The deadline will be no earlier than 45 days after the City
mails to property owners the notice of the public hearing.
Resolution No. 2025-066 (Exhibit “A”)
Page 3 of 6
2) The location to which written objections must be submitted to the City via
mail, or personal delivery.
3) All substantive requirements for submitting a written objection. The record
owner must comply with the requirements set forth in Procedures section 3, below,
including specifying the grounds on which the owner alleges the proposed new or
increased rates does not comply with Proposition 218.
4) Notice that: (a) any person’s failure to submit a timely written objection
bars any right of that person to challenge the proposed new or increased fee through
a legal proceeding; and (b) there is a 120-day statute of limitations for challenging
the proposed new or increased rates (in accordance with Government Code section
53759).
c. The City will mail the public hearing notice to each record owner of a parcel that
is subject to payment of the new or increased fee. The notice shall be mailed to owner’s
address shown on the last equalized property tax assessment roll.
1) There is a rebuttable presumption that the most recent equalized property
tax assessment roll of the Sonoma County Recorder is sufficient evidence of the
record owner of each parcel. A person may rebut the presumption by providing to
the City written proof of ownership.
2) The City Clerk, or designee, may certify by affidavit the proper mailing of
notices described in these Procedures, and any such affidavit shall constitute
conclusive proof of mailing in the absence of fraud.
3) Failure of any person to receive notice shall not invalidate the hearing or
its results.
4) The City will also provide supplemental notices to the address where the
City customarily mails the billing statement for rates.
d. Concurrently with publishing and mailing the public hearing notice, the City will
post on its website relevant information regarding the proposed new or increased fee
including a copy of the cost of service analysis (which may be referred to as a “rate
study”) which provides documentation of compliance with all substantive requirements
of Prop 218 regarding the calculation of the amount of the proposed new or increased fee.
3. Requirements for Submitting Timely Written Objections (AB 2257)
For the purpose of considering written objections, the City will consider the term “record
owner” to include tenancies of real property where tenants are directly liable to pay the rates
to the City (consistent with Proposition 218; California Constitution Article XIII D, Section 2(g)).
In order for a record owner to submit a timely written objection, it must:
a. Be received by the City at the location identified on the public hearing notice, no
later than the deadline identified on the public hearing notice. The deadline may be no
earlier than 45 days after the City mails to record owners the notice of public hearing.
Resolution No. 2025-066 (Exhibit “A”)
Page 4 of 6
b. Be in writing (1) identifying the name of the record owner, and the street address
or assessor’s parcel number (or other clear identification) of the property subject to the
rates; and (2) signed by the record owner.
c. Specify the grounds for alleging the proposed rates do not comply with Proposition
218. The grounds must identify (i) the substantive requirement of Proposition 218, and (ii)
the reason the proposed rates do not comply with that requirement. For any proposed new
or increased “fee” for a property-related service (such as water rates or sewer rates),
relevant substantive requirements of Proposition 218 include:
1) Revenues derived from the rates shall not exceed the funds required to
provide the property related service (water service or sewer service).
2) Revenues derived from the rates shall not be used for any purpose other than
that for which the fee or charge was imposed.
3) The amount of the rates shall not exceed the proportional cost of the service
attributable to the parcel.
4) No rates may be imposed for a service unless that service is actually used
by, or immediately available to, the owner of the property in question. Rates based
on potential or future use of a service are not permitted.
5) No rates may be imposed for general governmental services including, but
not limited to, police, fire, ambulance or library services, where the service is
available to the public at large in substantially the same manner as it is to property
owners.
4. Requirements for Submitting Timely Written Protests (Proposition 218)
For the purpose of considering and counting written protests, the City will consider the term
record owner” to include tenancies of real property where tenants are directly liable to pay
the rates to the City (consistent with Proposition 218; California Constitution Article XIII D,
Section 2(g)).
In order for a record owner to submit a timely written protest, to be considered as a part of the
Proposition 218 protest hearing described in Section 6, below, it must:
a. Be received by the City at the location identified on the public hearing notice, no
later than the close of the public testimony portion of the public hearing.
b. Be in writing (1) identifying the name of the record owner, and the street address
or assessor’s parcel number (or other clear identification) of the property subject to the
rates; and (2) signed by the record owner. A written protest must be submitted in paper
form. Any protest will not satisfy this requirement if it is submitted in any non-paper format
such as: email, facsimile, or oral protest via telephone or in person.
c. Must clearly identify that the record owner opposes the proposed new or increased
rates that are the subject of the hearing.
Resolution No. 2025-066 (Exhibit “A”)
Page 5 of 6
d. Will only be counted as one protest per parcel. That means if any one or more record
owners of a parcel submits a timely written protest (or timely written objection) for the
same parcel, it will be counted as one timely written protest.
e. Record owners of multiple parcels within the City may file one protest for each
parcel owned within the City’s service area.
f. A record owner may withdraw a written protest only if the withdrawal is submitted
in writing by the record owner clearly indicating an intent to withdraw for an identified
property, and it is received by the City at the location (and no later than the time) for
submitting written protests. After a written protest is withdrawn, a record owner may
submit a new or replacement written protest in accordance with the requirements of these
Procedures. No other modification to a timely written protest may be made.
g. The City Clerk shall take custody of all submitted written objections and written
protests.
1) In order to protect the integrity of the procedures for considering written
objections and written protests as described in these Procedures, all written
objections and written protests shall remain confidential until the City Manager (or
designee) has determined they may be published in accordance with the criteria in
paragraph 4(g)(2).
2) Any submitted written objection and written protest shall be a public record;
however, the City may withhold disclosure if the City determines that the public
interest served by not disclosing clearly outweighs the public interest served by
disclosure under Government Code section 7922.000. As a general rule, the City
finds there is a substantial public interest in not disclosing written objections and
written protests to protect the integrity of the process described herein during the
time that: (A) written objections are still being submitted and (B) prior to the time
that the Brown Act meeting agenda is posted (e.g., at least 72 hours before a regular
meeting under Government Code section 54954.2).
5. City’s Response to Timely Written Objections (AB 2257)
At the close of the written objection period, City staff shall review timely written objections (as
defined in Section 3, above) and shall draft written responses to the written objections. The
City’s written response will include: (i) the grounds on which the objection is (or is not) resulting
in amendments to the proposed new or increased rates; and (ii) an explanation of the substantive
basis for retaining or altering the proposed new or increased rates.
City staff shall present the written responses to the City Council at the public meeting that was
specified in the public hearing notice described in Section 2, above.
a. In accordance with the Brown Act, the public will be provided an opportunity to
address the City Council prior to the Council’s action related to the timely written
objections and written responses. (See Government Code section 54954.3(a).)
b. In accordance with Government Code section 53759.1(d), the City Council, in
exercising its legislative discretion in considering timely written objections and written
Resolution No. 2025-066 (Exhibit “A”)
Page 6 of 6
responses, shall determine for the proposed new or increased rates whether further
review, clarification, or reduction is needed, and whether to proceed to the Proposition
218 protest hearing.
6. Conducting the Proposition 218 Protest Public Hearing
If the City Council determines to proceed to the Proposition 218 protest public hearing for
proposed new or increased rates (as previously noticed in accordance with Section 2, above), the
public hearing shall be conducted consistent with the following:
a. The City Council will open the public hearing and consider all evidence presented
during the hearing including the public hearing notice and all documents referenced
therein (particularly including the Rate Study), all written objections (AB 2257), written
responses, written protests, and any testimony, documents, or information presented
during the public hearing.
b. Prior to closing the public hearing, the City Council will request if there are any
additional written protests, under Proposition 218, to be submitted to (or withdrawn from)
the City.
c. The City Council will then close the public hearing and request a report from the
City Clerk to identify the number of timely written protests compared to the total number
of parcels subject to the new or increased fees. The City Clerk shall seek legal advice
from the City Attorney if there are any questions regarding the counting of timely written
protests that meet the requirements of these Procedures.
1) A majority protest exists only if the number of timely written protests
exceeds one-half of the parcels served by the City.
2) If the City Clerk determines that additional time is needed to tabulate
timely written protests, the City Council shall recess or continue the public
meeting to provide sufficient time for the City Clerk to complete the tabulation.
3) If the City Clerk determines that there is a majority protest, the City shall
not impose the new or increased rates.
4) If the City Clerk determines that there is not a majority protest, the City
Council shall continue its deliberations and take action on the proposed new or
increased rates.
5) The City Clerk’s determinations under these Procedures shall be the final
determination of the City subject to appropriate judicial review. This shall include
the City Clerk’s determinations that: (a) a written protest meets the requirements
for a timely written protest in accordance with these Procedures; or (b) a majority
protest has (or has not) been submitted for the proposed rates.
City of Rohnert Park
Written Response to Written Objections and Submittals for
Proposed Adjustments to Water Rates and Service Charges
(AB 2257 – Government Code Sections 53759.1 and 53759.2)
The City of Rohnert Park (“City”) provides this written response to timely written
objections related to the City’s proposed approval of updates to water rates and service
charges (hereinafter “water rates”). This response also includes responses to
submissions received by the City that are related to the water rates, were received by
the City during the time for submitting written objections, but which do not meet the
requirements for filing a “timely written objection” in accordance with Government Code
Section 53759.1 and City Resolution No. 2025-006.
By September 26, 2025 (which was at least 45 days prior to December 2, 2025), the
City mailed the “Notice of Public Hearing” (Exhibit “A”) to each record owner served by
City water services, and the City posted the Notice of Public Hearing on the City’s
webpage (https://www.rpcity.org/586/Water-Sewer-Rate-Updates-What-to-Know). The
Public Hearing Notice also prominently identified supplemental documents that were
concurrently posted on the City’s webpage, notably including a copy of the Rate Study
that identifies each parcel to be charged, the amount of the rates, the basis upon which
the rate was calculated, and the reason for the change in rates. The Rate Study was
included on the City’s webpage, and it is labeled “2025 Water Rate Study Report”
(dated September 15, 2025, prepared on behalf of the City by Hildebrand Consulting).
The Public Hearing is scheduled for December 2, 2025, for the City of Rohnert Park City
Council (“City Council” or “Council”) to consider a recommended update to water rates,
in accordance with the requirements of “Proposition 218” (California Constitution Article
XIII D, Section 6) for approving increases to “property related fees.” The Proposition 218
hearing process includes the opportunity for property owners to submit a “Written
Protest” prior to the close of the public hearing, and the City is prohibited from approving
the increase if there is a “majority protest.” There is a “majority protest” if the City
receives timely written protests from owners representing more than 50% of the parcels
served by City water service.
The Public Hearing Notice also provided an opportunity for property owners to submit to
the City a “Written Objection” to the proposed rate increases by no later than the
identified “deadline” of November 12, 2025, at 5:00 p.m. Any written objection is
required to identify the grounds for alleging the City did not comply with Proposition 218.
In accordance with “AB 2257,” the City is required to provide a written response at the
public hearing for each timely written objection received prior to the deadline (“AB 2257”
is Assembly Bill 2257, Chapter 561, Statutes of 2024; codified at Government Code
Sections 53759.1 and 53759.2).
As of the time of the deadline, the City had received one “Written Objection” (the Bartle
letter identified on Exhibit “A,” attached hereto). Therefore, the City has prepared the
“Written Response” to the Written Objection as set forth on Exhibit B (attached hereto).
The Written Response provides the grounds and substantive bases for which the
Response to Written Objections and Protests (2025-11-17)
Page 2 of 2
concerns identified in the Written Objection does not result in a justification to amend
the proposed increases to water rates, as described in the Notice of Public Hearing.
Other than the Written Objection identified above, the City received the five other
“Submittals” also identified on Exhibit A from property owners prior to the deadline of
November 12, 2025, at 5:00 p.m. The Submittals were identified by the owner as a
protest and/or an objection to the proposed update to the water rates. However, none of
the Submittals meet the definition of a timely “written objection” (as defined by California
Government Code Section 53759.1(c)(4)) since they do not specify the grounds for
alleging the proposed water service rates do not comply with the requirements of
Proposition 218 (California Constitution Article XIII C, Section 6).
Although the City is not legally obligated under AB 2257 to provide a written response to
the Submittals, the City provides this written information (including Exhibit B) to explain
how the concerns raised in the Submittals do not establish grounds for amending or
altering the proposed adjustments to the City’s water rates.
As documented on the Notice of Public Hearing, which included documents available on
the City website (https://www.rpcity.org/586/Water-Sewer-Rate-Updates-What-to-
Know), the City calculated the amount of the proposed water service rates in
accordance with Proposition 218 in order to charge each customer the amount needed
to pay the proportionate cost of providing water service to each property owner.
The City complied with the Proposition 218 requirement that rates be set in an amount
proportional to the cost of service attributable to each parcel, as documented in the
Rate Study at https://www.rpcity.org/586/Water-Sewer-Rate-Updates-What-to-Know.
Conclusions and Recommendations
Therefore, City staff recommends that the City Council: (a) consider the substance of
the timely written objection and the written response from City staff; and (b) determine
the timely written objection does not result in any amendment to or alteration of the
proposed water rates, based on the analysis included on the City’s website (notably
including the Rate Study) and presented as a part of the public hearing on December 2,
2025, which provides the substantive bases for the City Council’s approval of the water
rates as proposed.
Exhibit B
Written Responses to Timely Written Objections and Submittals
1. Ayat Letter Response:
• The City has met its burden of proving that the proposed water rates proportionately
recover costs from ratepayers based on the cost to provide service as demonstrated by
the 2025 Water Rate Study.
• As presented during the City Council meeting of September 23, 2025, the City has
documented that the proposed water rates for Rohnert Park continue to be one of the
lowest rates among other cities in the region.
• The City’s water rates generate revenue to pay for the cost of providing water service.
As costs for service continue to increase, the City increases rates in order to continue
providing safe, reliable, and efficient operations of the water system for the benefit of
all customers.
• Finding: This letter does not specify any grounds for alleging the proposed water rates
do not comply with Proposition 218, as required by Government Code Section 53759.1.
2. Bartle Letter Response:
• While the letter identifies a comparison of past rate structures to the City’s proposed
rate structure, the City met its obligations under Proposition 218 to clearly identify the
amount of the proposed water rates in the chart identified in the mailed Notice of
Public Hearing. The Notice of Public Hearing also included a link to a webpage with
additional detailed information, including the 2025 Water Rate Study, as well as a phone
number to contact the City if any customer has more questions about how to calculate
their bill.
• The Rate Study Financial Plan in Section 2 includes an explanation of the costs covered
by the fixed monthly service charge for City costs that do not vary based on volume of
water used, compared to the Usage Rates for costs that do vary based on volume of
water used. The Rate Study also explains the Water Shortage Surcharge Policy at Section
3.
• The City carefully maintains its accounts for the revenue received and expenses incurred
in providing water service to its customers, and water rate revenue is not used to pay
for costs not related to providing water service.
• The Rate Study Section 2.10 describes how the City establishes and uses reserve funds,
including an Operating Reserve and a Rate Stabilization Reserve.
3. Finding: The City has documented that the proposed water rates comply with the requirements
of Proposition 218.Eads Letter Response:
• As presented during the City Council meeting of September 23, 2025, the City has
documented that the proposed water rates for Rohnert Park continue to be one of the
lowest rates among other cities in the region.
• Finding: This letter does not specify any grounds for alleging the proposed water rates
do not comply with Proposition 218, as required by Government Code Section 53759.1.
4. Henris Letter Response:
• The proposed rates will generate revenue that does not exceed the cost of providing
water service as set forth in the 2025 Water Rate Study. The City maximizes the efficient
and sustainable use of local groundwater supplies, as identified in Rate Study Section
2.6.
• The City has transparently and publicly described its intended approach for considering
approval of the proposed water rates, including the City Council meeting on August 26,
2025, to approve the Utility Rate Setting Procedures; the City Council meeting on
September 23, 2025, to consider the draft Water Rate Study and direct staff to mail the
public hearing notice; the mailed notice of public hearing to all customers, which
included links to the City’s website with additional information regarding the proposed
water rates; and the City Council public hearing on December 2, 2025.
• Finding: This letter does not specify any grounds for alleging the proposed water rates
do not comply with Proposition 218, as required by Government Code Section 53759.1.
5. Riley Letter Response:
• The City has met its burden of proving that the proposed water rates proportionately
recover costs from ratepayers based on the cost to provide service.
• As presented during the City Council meeting of September 23, 2025, the City has
documented that the proposed water rates for Rohnert Park continue to be one of the
lowest rates among other cities in the region. That presentation recognized the lower
rates from the City of Santa Rosa, while also identifying that Rohnert Park’s rates remain
lower than Petaluma, Vallejo, Sonoma, Ukiah, Sebastopol, Cloverdale, Willits,
Healdsburg, St. Helena, and Calistoga.
• The City water utility actively pursues grant opportunities.
• Finding: This letter does not specify any grounds for alleging the proposed water rates
do not comply with Proposition 218, as required by Government Code Section 53759.1.
6. Shapiro Letter Response:
• The City’s water rates are designed to proportionately recover costs from ratepayers
based on the cost to provide service. The first page of the Notice of Public Hearing
summarizes the external factors, such as costs of external water supply, drought, and
inflation, that have impacted the City’s costs of providing water service that have caused
the need to increase rates for those services.
• Finding: This letter does not specify any grounds for alleging the proposed water rates
do not comply with Proposition 218, as required by Government Code Section 53759.1.