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MAYOR . CITY MANAGER <br /> Valerie Amezcua Alvaro Nunez <br /> MAYOR PRO TEM �R: S,,, CITY ATTORNEY <br /> David Penaloza <br /> Sonia R.Carvalho <br /> COUNCILMEMBERS CITY CLERK <br /> Phil Bacerra � Jennifer L. Hall <br /> Johnathan Ryan Hernandez <br /> Jessie Lopez <br /> Thai Viet Phan <br /> Benjamin Vazquez CITY OF SANTA ANA <br /> PUBLIC WORKS AGENCY <br /> 20 Civic Center Plaza+P.O. Box 1988 <br /> Santa Ana.California 92702 <br /> www,santa-ana.org <br /> March 10, 2026 <br /> Ms. Barbara Orozco <br /> <br /> <br /> Subject: City of Santa Ana Response to Valid Legal Objection <br /> Dear Ms. Orozco: <br /> Thank you for your correspondence, which was received February 9, 2026 by the City <br /> Clerk's office. Your correspondence meets the requirements of a valid legal objection <br /> pursuant to Government Code section 53759.1. This letter constitutes the City of Santa <br /> Ana's response. <br /> 1. The City retained an independent rate consultant to conduct a robust cost of service <br /> analysis and rate study, which constitutes the administrative record and demonstrates <br /> that the rates do not exceed the proportional cost of service. California courts have <br /> routinely held that customers may be grouped into classes based on similar usage <br /> characteristics, and such classifications satisfy Proposition 218's requirement to <br /> allocate costs based on the proportional cost of service to the parcel. Here, the City <br /> classified customers based on the size of the meter serving the parcel. On the fixed <br /> charge side, this allowed for proportional allocation of the City's fixed costs based on <br /> capacity demand on the system, using ratios for maximum flow. On the volumetric <br /> side, this allowed the City to allocate costs based on relative system investment as <br /> well as shared usage characteristics stemming from the size of the meter serving the <br /> parcel. <br /> For more information, please review the rate study at: <br /> https://SantaanautiIityrates.com/wp-content/uploads/2026/01/Cit -of-Santa-Ana- <br /> 2025-Water-and-Sewer-Rate-Study-Report.pdf <br /> 2. As set forth in Table 52 of the study, the City only allocates the fixed costs associated <br /> with the delivery of water services that do not fluctuate based on water use, including <br /> SANTA ANA CITY COUNCIL <br /> Vaie6e Amezcua David Penaloza Thai Viet Phan Benjamin Vazquez Jessie Lopez Phil Bacera Johnalhan Ryan Hernandez <br /> Mayor Mayor Pra Tam-Ward 6 ward 1 Ward 2 Ward 3 Ward 4 Ward 5 <br /> yamezcua(telsanta-ana.org dpenalozardsanta-ana,orn lohantrasanla-ana,oep bvazauezCa7sanla-anaorc �essielopez@santa-ana.ora phacerransanta-ana.org irvanhemandez@zanta-anax <br />