HomeMy WebLinkAbout10-13-2025 - Study Session Agenda PacketSPECIAL STUDY SESSION AGENDA
CITY COUNCIL MEETING
CITY OF WHEAT RIDGE, COLORADO
Monday, October 13, 2025
Will start at the conclusion of the Regular City Council which starts at 6:30 p.m.
This meeting will be conducted as a virtual meeting, and in person, at: 7500 West 29th
Avenue, Municipal Building, Council Chambers.
City Council members and City staff members will be physically present at the
Municipal building for this meeting. The public may participate in these ways:
• Attend the meeting in person at City Hall. Use the appropriate roster to sign up to
speak upon arrival.
• Provide comment in advance at www.wheatridgespeaks.org (comment by noon
on October 13, 2025)
• Virtually attend and participate in the meeting through a device or phone:
Click here to pre-register and provide public comment by Zoom (You must
preregister before 6:00 p.m. on October 13, 2025)
• View the meeting live or later at www.wheatridgespeaks.org, Channel 8, or
YouTube Live at https://www.ci.wheatridge.co.us/view
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ADA Coordinator, (Kelly McLaughlin at ada@ci.wheatridge.co.us or 303-235-2885) as
soon as possible, preferably 7 days before the activity or event.
Public Comment on Agenda Items
1. Stormwater Utility Feasibility Study
Item No. 1
Memorandum
TO: Mayor and City Council
THROUGH: Patrick Goff, City Manager
FROM: Kent Kisselman, Interim Public Works Director
Eric Czaikowski, Infrastructure Project Manager
DATE: October 13, 2025
SUBJECT: Stormwater Utility Feasibility Study
ISSUE:
The City of Wheat Ridge previously adopted a Stormwater Master Plan to address a range of critical needs, including system enhancements to prevent flooding,
maintenance of aging infrastructure, and various operational requirements. Recently,
the City has also experienced multiple sinkholes attributed to stormwater pipe failures,
underscoring the need for sustainable, long-term investment in the stormwater system.
Raftelis Financial Consultants, Inc. (Raftelis) has conducted a comprehensive
Stormwater Utility Feasibility Study to assess the City's needs and evaluate funding
options. Raftelis will present the findings and recommendations of the study, including
a proposed framework for implementing a stormwater utility fee that aligns with the
City's infrastructure and environmental goals.
PRIOR ACTION:
• City Council approved a contract with RESPEC Consulting Services on March 25,
2024, for the development of a Stormwater Master Plan
• Preliminary results from the Stormwater Master Plan were presented to City Council
at the November 18, 2024, study session
• City Council adopted a Stormwater Master Plan with RESPEC Consulting Services on
May 12, 2025, to improve and provide planning for stormwater infrastructure and
operations
• Stormwater Rate Study RFP issued and subsequent approval of a contract with Raftelis on July 28, 2025, for the development of a Stormwater Utility Feasibility
Study
FINANCIAL IMPACT:
The contract amount with Raftelis for the Study was $64,390. Providing funding is necessary to bring the items listed in the Stormwater Master Plan into fruition. Most
Study Session Memo – Stormwater Utility Feasibility Study
October 13, 2025
Page 2
municipalities in the surrounding area rely on a stormwater fee to upgrade and maintain
their infrastructure. The chart below illustrates these monthly rates for single family
residents.
BACKGROUND:
Effective stormwater management is a fundamental element of responsible community
development. Proper planning, design, and construction of urban drainage systems are
essential to protecting properties, structures, and critical infrastructure from flood-related damage and potential loss of life.
In Wheat Ridge, continued urban development has significantly reduced opportunities to
incorporate traditional stormwater detention facilities that help capture and slowly
release runoff. As a result, the City increasingly relies on installing larger underground pipes that convey stormwater directly to major drainageways. At the same time, limited
maintenance of the existing stormwater infrastructure has contributed to system
degradation, including recent incidents of sinkholes caused by pipe failures. These
conditions highlight the growing need for sustained investment in both new
infrastructure and maintenance of the current system.
To address these challenges, the City adopted the Stormwater Master Plan on May 12,
2025, which provides a comprehensive roadmap for system improvements and
operational needs. One of the Plan’s primary recommendations is to conduct a rate
study to evaluate the feasibility of establishing a stormwater utility fee as a dedicated funding source.
To advance the Master Plan’s recommendations, the City engaged Raftelis to perform a
Stormwater Utility Feasibility Study. The study assessed current and future system
needs, reviewed best practices from other communities, and developed potential rate structures for a dedicated utility fee.
Raftelis has completed its analysis and will present its findings and recommendations
to City Council. The proposed stormwater utility fee would create a stable and equitable
revenue stream to fund both ongoing system maintenance and critical capital improvements alleviating the pressure currently placed on the City’s General and CIP
Funds.
Study Session Memo – Stormwater Utility Feasibility Study
October 13, 2025
Page 3
Monthly Single Family Residential Fee for Peer Communities
Currently the city does not have an Enterprise Fund to provide the necessary revenue for stormwater maintenance and upgrades. An arbitrary amount of $10 per month for
Wheat Ridge residents (single family residential (SFR)) was selected to illustrate how much funding would be collected with this fee and the short fall that would need
additional funding such as low interest bonds.
An impervious area (IA) charge was also used to analyze projected funding. A customer
is charged based on impervious surface on the property. Impervious surfaces do not allow stormwater to infiltrate. Greater amounts of IA increase the total volume and peak
rates of runoff and lead to increased pollution, thus increasing demand upon the
stormwater system and stormwater program. The majority of stormwater utilities across the U.S. use IA exclusively as a basis for their fees.
Raftelis used a two-pronged approach to estimate units of service and impervious area.
SFR parcels were assumed to be charged a flat rate of 1 equivalent residential unit
(ERU) each. Non-single family residential properties, which includes multi-family (greater than three units), industrial, commercial, non-profits, schools, etc. are typically
charged a variable rate based on their actual impervious area. The same GIS parcel and
$28.46
$26.53
$21.79
$21.66
$18.85
$12.82
$11.75
$11.32
$10.00
$10.00
$9.88
$8.97
$8.72
$8.70
$7.64
$7.50
$6.92
$5.50
$5.36
$2.00
$0.00 $5.00 $10.00 $15.00 $20.00 $25.00 $30.00
Boulder
Greeley
Denver
Englewood
Longmont
Erie
Golden
Loveland
Wheat Ridge
Lyons
Littleton
Castle Rock
Windsor
Parker
Louisville
Arvada
Adams County
Brighton
Pueblo
Northglenn
Study Session Memo – Stormwater Utility Feasibility Study
October 13, 2025
Page 4
aerial imagery data utilized to calculate the ERU were used to estimate impervious
surface area on non-single family residential (NSFR) properties via a visual review. Units
of service on SFR and NSFR properties were summed up for total units of service.
Raftelis developed an open-source Microsoft Excel-based financial model to calculate
estimated rates under different funding scenarios based on stormwater program
revenue requirements and estimated units of service. The financial model includes
proposed O&M expenses, proposed capital renewal and replacement expenses, and
additional capital projects. The model allows the user to change the percentage allocation of existing costs, as well as capital project timing and funding approaches to
see the impact on proposed rate. The tables below illustrate the revenue requirements
based on this rate.
Revenue Requirement 2026 - 2030
2026 2027 2028 2029 2030
Operating Expenses
Operations $ 366,100 $ 379,500 $ 393,300 $ 407,700 $ 422,800
Maintenance Programs $ 489,000 $ 503,800 $ 519,000 $ 534,600 $ 550,600
Total Operating Expenses $ 855,100 $ 883,300 $ 912,300 $ 942,300 $ 973,400
Non-Operating Expenses
Revenue Bond Payments $ - $ - $ - $ - $ 239,100
PAYGO $ -
$ 1,803,000
$ 1,486,000
$ 1,723,000
$ 2,993,000
Transfer to Operating
Reserve $ 210,900 $ 6,900 $ 7,200 $ 7,400 $ 7,700
Total Non-Operating
Expenses $ 210,900
$ 1,809,900
$ 1,493,200
$ 1,730,400
$ 3,239,800
Total Revenue
Requirements
$ 1,066,000
$ 2,693,200
$ 2,405,500
$ 2,672,700
$ 4,213,200
Study Session Memo – Stormwater Utility Feasibility Study
October 13, 2025
Page 5
Revenue Requirement 2031 - 2035
2031 2032 2033 2034 2035
Operating Expenses
Operations $ 438,400 $ 454,500 $ 471,200 $ 488,700 $ 506,900
Maintenance Programs $ 567,100 $ 584,000 $ 601,500 $ 619,600 $ 638,100
Total Operating
Expenses
$ 1,005,500
$ 1,038,500
$ 1,072,700
$ 1,108,300
$ 1,145,000
Non-Operating
Expenses
Revenue Bond
Payments
$ 1,535,900
$ 1,535,900
$ 1,796,000
$ 2,304,600
$ 2,304,600
PAYGO
$ 1,576,000
$ 2,313,000
$ 1,453,000
$ - $ -
Transfer to Operating
Reserve
$ 7,900 $ 8,100 $ 8,500 $ 8,700 $ 9,100
Total Non-Operating
Expenses
$ 3,119,800
$ 3,857,000
$ 3,257,500
$ 2,313,300
$ 2,313,700
Total Revenue
Requirements
$ 4,125,300
$ 4,895,500
$ 4,330,200
$ 3,421,600
$ 3,458,700
RECOMMENDATIONS:
Option 1 – Implement a Stormwater Utility Fee in 2026
Direct staff to establish a stormwater utility and implement a monthly stormwater fee
(illustratively, $10 per single-family equivalent unit) beginning in 2026.
Pros: Creates a dedicated, stable revenue source; reduces reliance on General Fund
resources; addresses critical infrastructure needs.
Cons: Increases costs for residents and businesses; requires administrative setup and
public outreach.
Option 2 – Phase-In a Stormwater Utility Fee Over Time Approve the formation of a utility but phase in the fee over two to three years, starting
with a lower rate and increasing gradually.
Pros: Allows time for public education and smooth adjustment to the new fee; begins
generating dedicated revenue.
Cons: Slower fund accumulation may delay capital projects; partial reliance on existing
Study Session Memo – Stormwater Utility Feasibility Study
October 13, 2025
Page 6
funding sources remains.
Option 3 – Defer Implementation and Reevaluate Funding Options
Continue to fund stormwater improvements through the General Fund, Capital Improvement Program, and potential external funding (grants or low-interest loans)
while revisiting the utility concept at a later date.
Pros: Avoids immediate new fees; allows time to seek alternative funding sources.
Cons: Sustains underfunding of critical stormwater needs; increases long-term costs
and risk of infrastructure failures.
Staff seeks Council direction on whether to proceed with implementation of a
stormwater utility, phase-in approach, or deferment for further analysis. Raftelis will be available at the study session to present findings and answer questions.
ATTACHMENTS:
1. Stormwater Utility Feasibility Study
CITY OF WHEAT RIDGE
Stormwater Utility
Feasibility Study
FINAL REPORT / September 26, 2025
ATTACHMENT 1
227 W. Trade Street, Suite 1400, Charlotte, NC 28202
www.raftelis.com
September 26, 2025
Mr. Eric Czaikowski
Infrastructure Project Manager
City of Wheat Ridge
7500 West 29th Avenue
Wheat Ridge, CO 80033
Subject: Stormwater Utility Feasibility Study Report
Dear Mr. Czaikowski:
Raftelis is pleased to provide this Stormwater Utility Feasibility Study report to the City of Wheat Ridge
(City). The goal of this study was to evaluate the feasibility of implementing a stormwater utility, which
included gathering information on the City’s stormwater program and regulatory requirements, calculating
revenue requirements, estimating units of service, and calculating estimated rates under a potential fee. The
report summarizes the proposed stormwater utility rate structure, units of service analysis, revenue
requirements (operations and maintenance, capital and reserves), financial analysis, funding scenarios, policy
decisions (both already made and to be made) and implementation considerations. Proposed expenditures
and rates have been compared to peer communities to provide an understanding of the jurisdictions to which
Wheat Ridge may be compared by the public.
Please note that revenue bonds are modeled in the financial scenarios below; however Raftelis is not acting as
a Municipal Advisor, and the opinions or views contained herein are not intended to be, and do not constitute
“advice” within the meaning of the Municipal Advisor Rule.
It has been a pleasure working with you, and we thank you and City staff for the support provided during this
study. We look forward to continuing to assist the City.
Sincerely,
Henrietta Locklear
Senior Vice President
Contents
1. Introduction .................................................................................. 1
2. Program and Revenue Requirements .......................................... 2
2.1. Current Program and Funding Approach ...................................................................2
2.2. Cost Drivers ...................................................................................................................2
2.3. O&M Costs .....................................................................................................................2
2.4. Capital Project Costs ....................................................................................................4
2.5. Reserve Funds ..............................................................................................................7
3. Data and Units of Service Evaluation .......................................... 8
3.1. Rate Structure Options .................................................................................................8
3.2. Rate Structure Recommendation ................................................................................8
3.3. Data Evaluation .............................................................................................................9
3.4. ERU Determination .......................................................................................................9
3.5. Units of Service Estimation ........................................................................................ 13
4. Funding Evaluation .................................................................... 16
4.1. Total Revenue Requirements and Preliminary Rates .............................................. 16
4.2. Proposed Stormwater Rate Comparisons ................................................................ 18
4.3. Stormwater Credit Program Considerations ............................................................ 20
5. Implementation Considerations ................................................. 21
5.1. Implementation Data Needs ....................................................................................... 21
5.2. Billing Methods ........................................................................................................... 21
5.3. Billing Finalization ...................................................................................................... 22
5.4. Legal and Policy Considerations ............................................................................... 22
5.5. Public Outreach and Engagement ............................................................................. 22
5.6. Implementation and Outreach Schedule ................................................................... 24
Tables
Table 1. Operating Costs ......................................................................................................................... 3
Table 2. Maintenance Costs .................................................................................................................... 3
Table 3. O&M Revenue Requirement 2026 - 2030 ................................................................................... 3
Table 4. O&M Revenue Requirement 2031 - 2035 ................................................................................... 4
Table 5. Ranked Priority Projects ............................................................................................................. 4
Table 6. Other Priority Projects ................................................................................................................ 4
Table 7. Regional Stormwater Projects .................................................................................................... 5
Table 8. Capital Project Planned Spending 2026 - 2030 .......................................................................... 5
Table 9. Capital Project Planned Spending 2031 - 2035 .......................................................................... 6
Table 10. Debt Issuance Summary .......................................................................................................... 6
Table 11. Operating Reserve Targets 2026 - 2030 .................................................................................. 7
Table 12. Operating Reserve Targets 2031 - 2035 .................................................................................. 7
Table 13. Single Family Residential Parcel Counts and Representation in the Sample .......................... 10
Table 14. Estimated Units of Service based on Estimated ERU Value ................................................... 15
Table 15. Revenue Requirement 2026 - 2030 ........................................................................................ 16
Table 16. Revenue Requirement 2031 - 2035 ........................................................................................ 16
Table 17. Proposed Rates per ERU 2026 - 2035 ................................................................................... 17
Table 18. Projected Cash Flows 2026 - 2030 ......................................................................................... 17
Table 19. Projected Cash Flows 2031 - 2035 ......................................................................................... 17
Figures
Figure 1. Capital Projects Revenue Requirement..................................................................................... 7
Figure 2. Geographic Distribution of SFR Sample .................................................................................. 10
Figure 3. Examples of Measured Impervious Area on Sample Parcels .................................................. 11
Figure 4. Impervious Area Distribution for SFR Sample (by parcel type) ................................................ 12
Figure 5. Sample Minimum, Median, and Max Impervious Area for each SFR Parcel Type ................... 12
Figure 6. Example grid with SFR parcels and roads blacked out ............................................................ 14
Figure 7. Projected Cash Flows 2026 - 2035 ......................................................................................... 17
Figure 8. Monthly NSFR Fee per 3,800 square feet for Peer Communities ............................................ 18
Figure 9. Monthly SFR Fee for Peer Communities ................................................................................. 19
Figure 10. BWSC Stormwater Parcel Viewer Tool ................................................................................. 24
Appendices
Appendix: Final SFR Sample List (Parcel Identification Numbers)
THIS PAGE INTENTIONALLY LEFT BLANK
City of Wheat Ridge / Stormwater Utility Feasibility Study 1
1. Introduction
The City of Wheat Ridge (City) is located just west of Denver in Jefferson County, Colorado. It covers 9.5
square miles and has a population of approximately 32,400, as of 2020. The City has grown from a primarily
agricultural community to a more modern city with increasingly dense development. The City’s stormwater
system has approximately 45 miles of pipes, but given its history, the City’s drainage infrastructure was not
proactively planned or developed, and there are significant parts of the city with undersized or no drainage
infrastructure at all. In recent years, major system failures highlighted the general system condition, and the
City took several critical measures to understand and address the stormwater infrastructure needs.
Importantly, Wheat Ridge voters approved ballot measure 2J in November 2023, extending a sales tax to
fund, through bond issuance, capital improvements across the city, including enhancing drainage and
floodplain infrastructure at high priority areas and critical locations.
For a longer-range view, the City also commissioned and completed a stormwater master plan (SWMP),
performed by RESPEC Company, LLC (RESPEC), and adopted the final plan in May 2025. This study
highlighted critical needs of the stormwater system, including Priority Enhancement Projects, Regional
Stormwater Projects, Existing System Repairs, Detailed Drainage Studies, Personnel, and Equipment
recommendations. The study also included a conceptual stormwater utility fee analysis.
The City also worked with University of Colorado’s Department of Geography and Environmental Sciences
to conduct a preliminary funding analysis completed in Spring 2025. The report discussed a general approach
to developing a stormwater utility fee, which, if established, could generate revenues to support stormwater
operations, maintenance, and capital project delivery. When structured appropriately, stormwater utilities
provide an equitable way to fund stormwater management costs because customers pay based on their
demand upon the stormwater system. Without a dedicated stormwater fee, the City primarily relies upon tax
revenues to fund the stormwater infrastructure program. This can risk funding instability or insufficiency, as
funds are subject to reallocation when other City priorities arise.
Following the recommendations of the master plan, the City engaged Raftelis to evaluate the feasibility of
implementing a stormwater utility, which included gathering information on the City’s stormwater program
and regulatory requirements, projecting operations and maintenance (O&M) and capital expenses, estimating
units of service, developing a feasible financial plan, and calculating potential rates.
The City has significant unmet stormwater management needs, including large investments in stormwater
capital infrastructure to address major flooding issues. The City also needs to shift from reactive maintenance
to proactive maintenance to more efficiently and cost-effectively operate the system. The City’s current
funding strategy does not meet their current stormwater needs and has led to deferred maintenance of the
system. The City needs a more stable, dedicated, equitable and revenue-sufficient method to fund its
stormwater program moving forward.
City of Wheat Ridge / Stormwater Utility Feasibility Study 2
2. Program and Revenue
Requirements
2.1. Current Program and Funding Approach
The stormwater infrastructure maintenance and related activities are performed by the City’s Department of
Public Works personnel. Funding for these activities comes from the City’s General Fund. Day-to-day
stormwater management activities include modest infrastructure maintenance, street sweeping and other
responsibilities defined primarily by the City’s National Pollutant Discharge Elimination Program (NPDES)
Municipal Separate Storm Sewer System (MS4) permit. Some larger capital projects are funded through the
2J bond program, which is backed by sales tax revenue. The lack of a dedicated funding source for
stormwater activities means that equipment, personnel, and capital project costs are handled on an as-needed
basis, typically in emergency or reactionary circumstances and currently paid through the General Fund.
2.2. Cost Drivers
The City does not currently have a defined stormwater program budget, and existing funding is relatively low,
so the focus of this analysis are new costs identified and developed through the 2025 RESPEC SWMP and
the accompanying report, and supplemental estimates provided by the City. Generally, the City’s stormwater
management revenue requirements are related to O&M of the stormwater system and capital project
spending. Historically, the City has focused on reactive maintenance needs; therefore deferred maintenance
needs to improve the condition of assets and projects to address flooding are a substantial driver of capital
expenses.
2.3. O&M Costs
Operating costs broadly fit into 3 categories: personnel, equipment, and detailed drainage studies. Personnel
costs developed by RESPEC include a new Infrastructure Project Manager to oversee the delivery of
stormwater-related capital projects and otherwise improve management of the assets and infrastructure. The
City has already filled this position. The SWMP calls for the hiring of a CIP Project Manager and additional
operations staff, however, the City does not plan to fill these positions in the near term, so the costs have not
been included in the financial model or subsequent stormwater fee rate calculations. The SWMP
recommended that the City allocate a certain amount for equipment purchases dedicated to maintaining
drainage infrastructure, and that the City conduct detailed drainage studies to better understand current and
evolving needs over time. Even though the additional operations staff are not included, the additional
equipment costs are included since Public Works staff will likely continue to support stormwater operations
and will need specific equipment to maintain the stormwater system. Equipment costs and detailed drainage
study costs were estimated over the 10-year period 2026 to 2035 in the master plan. Raftelis used these 10-year
estimates to develop annual costs beginning in 2026, incorporating annual inflation in future years. A
summary of the annual operating costs included in this analysis is shown below.
City of Wheat Ridge / Stormwater Utility Feasibility Study 3
Table 1. Operating Costs
Category Annual Costs (2026$)
Personnel $118,000
Equipment $138,100
Detailed Drainage Studies $110,000
Total Operations Costs $366,100
The SWMP also recommended multiple maintenance-related activities in support of the stormwater system.
Cleaning and televising pipes serves multiple purposes including restoring pipes to their designed cross-
sections for conveyance, cataloguing pipe conditions, and identifying which pipes may need to be replaced.
This, coupled with Geographic Information System (GIS) mapping, will allow the City to better understand
the condition of pipes around the city, manage and track asset inventory, and prioritize replacement and
additional maintenance projects. Cleaning and dredging existing detention facilities is a routine and essential
maintenance activity for pollution purposes and for flooding mitigation. The City experienced a series of pipe
failures in recent years, leading to $700,000 spent on emergency repairs in 2024 alone. The SWMP anticipates
recommends an average of $1,200,000 per year for existing system repairs. In order to balance out the funding
of this new enterprise fund, the budget ramps up to this spending level, and achieves the equivalent total
spending on existing system repairs over the 10-year period. All maintenance costs were quantified over the
10-year period, and the estimated annual costs are shown in the table below.
Table 2. Maintenance Costs
Category Average Annual
Costs (2026$)
Clean & Televise Existing Pipes by Zone $ 314,000
Clean/Dredge Existing Detention Facilities $ 135,000
Geographic Information System Mapping $ 40,000
Existing System Repairs $ 1,200,000
Total Maintenance Costs $ 1,689,000
Total annual operations and maintenance costs are $855,100 starting in 2026. These costs are adjusted for
inflation over the 10-year period considered in this stormwater utility analysis. The annual revenue
requirements for both types of O&M costs are shown below in Table 3 and Table 4.
.
Table 3. O&M Revenue Requirement 2026 - 2030
2026 2027 2028 2029 2030
Operations $ 372,000 $ 378,200 $ 384,700 $ 391,600 $ 398,800
Maintenance Programs $ 1,089,000 $ 1,089,000 $ 1,889,000 $ 1,889,000 $ 1,889,000
Total $ 1,461,000 $ 1,467,200 $ 2,273,700 $ 2,280,600 $ 2,287,800
City of Wheat Ridge / Stormwater Utility Feasibility Study 4
Table 4. O&M Revenue Requirement 2031 - 2035
2031 2032 2033 2034 2035
Operations $ 406,300 $ 414,200 $ 422,500 $ 431,200 $ 440,400
Maintenance Programs $ 1,889,000 $ 1,889,000 $ 1,889,000 $ 1,689,000 $ 1,689,000
Total $ 2,295,300 $ 2,303,200 $ 2,311,500 $ 2,120,200 $ 2,129,400
As discussed above, these represent new costs, and aside from the recently hired Infrastructure Manager, they
do not represent a reallocation of costs currently funded by general fund monies.
2.4. Capital Project Costs
The SWMP included 8 ranked priority projects and provided project costs (in 2026$). These projects focus on
reducing local flood risk by upsizing undersized or failing pipes and by installing additional pipes as needed.
A summary of these projects can be found below in Table 5. Raftelis modeled project delivery timeframes and
funding sources in coordination with City staff. Stormwater fee revenue is discussed in Section 4.1.
Capital projects below are shown to be funded either with Pay-as-you-go (PAYGO) funding or through debt,
which may take the form of revenue bonds or general obligation bonds, both of which would be serviced by
stormwater fee revenue as modeled. Bond funding is first introduced in 2028 to allow time for the stormwater
fund to collect revenues, build reserves, and improve the financial position of the fund prior to selling revenue
bonds. The City should consult its financial advisor and conduct a financial feasibility analysis prior to issuing
any debt.
Table 5. Ranked Priority Projects
Project Priority Total Project Cost Funding Source Funding Year
Independence Street Ph1 1 $ 1,635,265 PAYGO 2027
Independence Street Ph2 2 $ 1,283,052 PAYGO 2029
Pierce Street Ph1 3 $ 1,417,498 Debt 2028
Pierce Street Ph2 4 $ 2,344,374 Debt 2030
Holland Street 5 $ 1,175,773 PAYGO 2031
W 32nd Avenue Ph1 6 $ 1,643,583 PAYGO 2034
W 32nd Avenue Ph2 7 $ 2,280,088 Debt 2035
W 44th Avenue 8 $ 4,246,723 Debt 2034
Total Ranked Priority Projects $16,026,400
Another set of projects mentioned in the SWMP are the priority projects that will require further coordination
with the Colorado Department of Transportation (CDOT). Based on direction from the City, the two
included projects were assumed to only be 50% funded by the stormwater utility fund. The remaining costs
are assumed to be paid by CDOT.
Table 6. Other Priority Projects
Project Full Cost Funding Source Funding Year
Kipling Street $1,966,000 Debt 2032
I-70 Frontage Rd $4,853,000 Debt 2034
Total Other Priority Projects $6,819,000
City of Wheat Ridge / Stormwater Utility Feasibility Study 5
The SWMP also contemplated regional stormwater projects totaling $32,000,000 to fund improvements in
Clearvale, Lena Gulch, and Lewis Meadows Park. Typically, these types of projects are funded in part by
Mile High Flood District (MHFD) so the estimated impact cost to the City is modeled at $16,000,000. Even
at this reduced cost, this is the most expensive capital project in the SWMP, so it was broken into three phases
and staggered every other year starting in 2031. All projects are assumed to be funded by a revenue bond or
similar source.
Table 7. Regional Stormwater Projects
Project Full Cost Funding Source Funding Year
Regional Stormwater Projects Ph1 $5,000,000 Debt 2031
Regional Stormwater Projects Ph2 $5,500,000 Debt 2033
Regional Stormwater Projects Ph3 $5,500,000 Debt 2035
Total Regional Stormwater
Projects $16,000,000
Additionally, there are 12 priority repair projects being studied by J&T Consulting at the time of this report.
Costs for these projects were not yet available and are therefore not included in this study, however the
financial model and future rate projections can be updated with these costs once they are known.
The funding source selected for a project can have a significant impact on the overall revenue requirements.
The cost of a PAYGO project is typically realized the same year(s) as the project or uses existing fund
balance, whereas a project that is financed with debt will spread that cost over an extended period, typically
decades. There are a variety of financing options available, many of them offering lower interest rates or, in
some cases, interest forgiveness. As discussed above, for the purposes of this study, it was assumed that
projects that needed to be financed would be financed with a municipal bond. If the City can secure other
means of financing, the potential savings could be used to fund a variety of remaining stormwater needs or
increase the spending on maintenance programs to enhance the level of service provided. Table 8 and Table 9
below are the total capital spending each year (after inflation).
Table 8. Capital Project Planned Spending 2026 - 2030
2026 2027 2028 2029 2030
Ranked Priority Projects
Independence Street Ph1 - $ 1,803,000 - - -
Independence Street Ph2 - - - $ 1,560,000 -
Pierce Street Ph1 - - $ 1,641,000 - -
Pierce Street Ph2 - - - - $ 2,993,000
Capital Project Spending - $ 1,803,000 $ 1,641,000 $ 1,560,000 $ 2,993,000
City of Wheat Ridge / Stormwater Utility Feasibility Study 6
Table 9. Capital Project Planned Spending 2031 - 2035
2031 2032 2033 2034 2035
Ranked Priority Projects
Holland Street $ 1,576,000 - - - -
W 32nd Avenue Ph1 - - - $ 2,550,000 -
W 32nd Avenue Ph2 - - - - $ 3,715,000
W 44th Avenue - - - $ 6,589,000 -
Other Priority Projects
Kipling Street - $ 1,384,000 - - -
I-70 Frontage Rd - - - $ 3,765,000 -
Regional Stormwater
Projects
Regional Stormwater
Projects Ph1 $ 5,000,000 - - - -
Regional Stormwater
Projects Ph2 - - $5,500,000 - -
Regional Stormwater
Projects Ph3 - - - - $5,500,000
Capital Project Spending $ 6,576,000 $ 1,384,000 $ 5,500,000 $12,904,000 $ 9,215,000
The total Capital Project Spending in the 10-year period is $38,845,400 without inflation, and $43,576,000
with inflation.
Table 10 is a summary of each of the debt issuances from the financial model, which shows the debt series,
the amount borrowed (par amount) and the annual debt service payment. Importantly, debt payments are
assumed to begin the year after the issuance, so payments on the Series 2035 debt do not begin until after the
10-year period. Figure 1 shows the total of PAYGO project spending and bond payments each year.
Table 10. Modeled Debt Issuance Summary
Series Par Amount Annual Debt Service
Series 2028 Debt $ 1,641,000 $ 133,000
Series 2029 Debt - -
Series 2030 Debt $ 2,993,000 $ 242,600
Series 2031 Debt $ 5,000,000 $ 405,300
Series 2032 Debt $ 1,384,000 $ 112,200
Series 2033 Debt $ 5,500,000 $ 445,800
Series 2034 Debt $10,354,000 $ 839,200
Series 2035 Debt $ 9,215,000 $ 746,900
City of Wheat Ridge / Stormwater Utility Feasibility Study 7
Figure 1. Capital Projects Revenue Requirement
With the use of debt, the total Revenue Requirement for capital projects in the 10-year period is $13,321,600
to support the higher capital spending. This scenario represents a way that a fairly substantial capital plan can
be accommodated in a short time frame while keeping rates reasonable, but it also represents a high debt
burden, which should be considered carefully by the City, alongside other funding opportunities and
extensions to the capital program.
2.5. Reserve Funds
Reserves can serve multiple purposes for enterprise funds. They can provide rate stabilization and funds for
major cash-funded capital projects. The City does not have a set reserve policy, so Raftelis used standard
industry practices to develop the operating reserve requirements in the financial model. The financial model
currently has the reserves set at 25% (90 days) of the operating budget starting in year one. The initial transfer
to the Operating Reserve is a larger amount, which sets the baseline funding level. In subsequent years,
revenue requirements are increased if additional contribution to the fund balance is needed to maintain
reserve target levels. The yearly reserve target is shown in Table 11 and Table 12.
Table 11. Operating Reserve Targets 2026 - 2030
2026 2027 2028 2029 2030
Total Operating Expense $1,461,000 $1,467,200 $2,273,700 $2,280,600 $2,287,800
Target Days Cash on Hand 90 90 90 90 90
Target Operating Reserve
Amount $120,100 $241,200 $560,700 $562,400 $564,200
Table 12. Operating Reserve Targets 2031 - 2035
2031 2032 2033 2034 2035
Total Operating Expense $2,295,300 $2,303,200 $2,311,500 $2,120,200 $2,129,400
Target Days Cash on Hand 90 90 90 90 90
Target Operating Reserve
Amount $566,000 $568,000 $570,000 $522,800 $525,100
$-
$500,000
$1,000,000
$1,500,000
$2,000,000
$2,500,000
$3,000,000
$3,500,000
$4,000,000
$4,500,000
2026 2027 2028 2029 2030 2031 2032 2033 2034 2035
Revenue Bond Payments PAYGO
City of Wheat Ridge / Stormwater Utility Feasibility Study 8
3. Data and Units of Service
Evaluation
3.1. Rate Structure Options
A stormwater rate structure may have several components that could serve as proxy for demand. Every
component should be considered from the standpoint of fairness and proportionality to cost drivers to
promote the rate structure’s legal defensibility and appropriateness given the particular costs of the stormwater
program. The following three elements are often used in stormwater rate structures, with the first being by far
the most common:
1. Impervious area (IA) charge – Customer is charged based on impervious surface on the property.
Impervious surfaces do not allow stormwater to infiltrate. Greater amounts of IA increase the total
volume and peak rates of runoff and lead to increased pollution, thus increasing demand upon the
stormwater or combined storm-sewer system and stormwater program. The majority of stormwater
utilities across the U.S. use IA exclusively as a basis for their fees.
2. Gross area (GA) charge – A customer’s fee could also be based in part on the overall size of the
parcel. By itself, GA doesn’t directly correlate with all stormwater cost drivers like IA does, but it does
correspond to some of them, especially if land use is also a consideration. It should be noted that a
rate structure that considers both GA and IA tends to shift cost recovery to customers who own larger
parcels.
3. Fixed or minimum charge – Every customer could be required to pay a fixed or minimum charge to
cover the costs of stormwater utility administration or other general program costs, which are
distributed evenly among all customers regardless of customer class or property characteristics. For
example, it costs the same amount to generate a bill for a commercial customer as it does for a
residential customer. However, while this fixed charge can fairly recover some costs, adding this type
of charge tends to shift program costs to smaller customers, and adds complexity.
The most common stormwater rate structure in the U.S. and Canada is an impervious area rate structure,1
with the units of charge being equivalent residential units, or ERUs. An ERU is a unit of measurement that
is developed for each utility and is typically determined as the median size of impervious area on residential
parcels within the utility’s service area. Alternatively, the utility may use a preset unit of measurement as its
standard unit, such as an increment of 1,000 SF of IA. The ERU is considered the best practice in the industry
as it establishes parity between the residential and non-residential customer classes and accurately represents
the proportionate burden on the stormwater conveyance system. Depending on the way the rate structure is
designed, the ERU can also represent a simplified approach to billing single family residential properties to
limit the need for individual impervious area measurements.
3.2. Rate Structure Recommendation
Raftelis recommends the City implement an impervious area-based rate structure to equitably distribute
stormwater management costs amongst customers based on their demand on the stormwater system. An
impervious area ERU based rate structure is the most common rate structure for stormwater utilities in
1 Western Kentucky University Stormwater Utility Survey 2024. Accessed on 2/10/2025. https://digitalcommons.wku.edu/seas_faculty_pubs/20/
City of Wheat Ridge / Stormwater Utility Feasibility Study 9
Colorado and across the United States2. Impervious area serves as a rationale nexus between stormwater fees
and the demand on the system, because the more impervious area a property has, the greater the volume and
rate of runoff it contributes during storms, and the greater the demand for the utility’s stormwater
management services.
Typically, the first step to calculate impervious area-based rates is to estimate the total number of stormwater
billing units (units of service) based on the total impervious area in the City classified into single family
residential (SFR) and non-single family residential (NSFR) properties. Generally, the units of service value is
the denominator by which the total revenue requirements are divided in order to calculate rates. This analysis
uses the ERU as the billing unit.
3.3. Data Evaluation
Raftelis’ analysis was based on 2022 aerial imagery from the Denver Regional Aerial Photograph Project
(DRAPP)3 and current parcel data provided by the City. Parcels were classified into single-family residential
(SFR) and non-single family residential (NSFR) categories based on the “STTSTRC” attribute in the parcel
dataset. Classification of parcels into the SFR and NSFR categories was developed independently but aligns
with the University of Colorado Stormwater Infrastructure Analysis Report.4 Initially, Raftelis’ SFR parcels
included single family, duplex, triplex, and townhomes. NSFR parcels include all parcels not falling into the
SFR category, including multi-family, industrial, commercial, schools, non-profits, etc.
3.4. ERU Determination
An ERU reflects the typical amount of impervious area on an SFR parcel and allows for simplified billing of
the largest customer group – single family residential properties. The ERU is often used as the base billing unit
since most SFR properties are similar and treating them uniformly is both simple to understand and simple to
administer. Raftelis developed the Wheat Ridge-specific ERU value via the method described below.
3.4.1. Sample Selection
A random sample of 400 was selected from Single Family, Duplex, Triplex, and Townhome parcels (Table
13). A sample size of 400 parcels out of a total of 9,816 parcels was selected to provide a statistical confidence
level of 95% that the true ERU value is within a margin of error of less than 5 percent.
2 https://www3.epa.gov/region1/npdes/stormwater/assets/pdfs/FundingStormwater.pdf
3 https://data.drcog.org/dataset/denver-regional-aerial-photography-project-tiles-2022
4 Stormwater Infrastructure Analysis: Mapping the Future of Stormwater Solutions in Wheat Ridge, Colorado. Student Report,
Department of Geography and Environmental Sciences, University of Colorado Denver, Spring 2025.
City of Wheat Ridge / Stormwater Utility Feasibility Study 10
Table 13. Single Family Residential Parcel Counts and Representation in the Sample
Parcel Count Percentage
Distribution Sample Count Percentage
Distribution
Single Family 7,917 81% 324 81%
Duplex: Two Family 955 10% 46 12%
Triplex: Three Family 33 0% 2 <1%
Townhomes 911 9% 28 7%
9,816 100% 400 100%
Upon inspection, some selected parcels were found to be vacant and were replaced with other randomly
selected parcels. The geographic distribution of the sample was evaluated against the distribution of SFR
parcels across the City (Figure 2).
Figure 2. Geographic Distribution of SFR Sample
The final sample list of parcel identification numbers (PINs) is attached as Appendix A.
3.4.2. Impervious Area Measurement
Within ArcGIS, a Raftelis analyst overlaid parcel polygons for selected SFR sample parcels on 2022 aerial
imagery from DRAPP and created new spatial features to represent the impervious area on each parcel based
on visual assessment of the parcel. Impervious surface was identified as any structure that prevents water from
infiltrating into the soil, such as buildings, paved and gravel driveways, paved pathways, and parking lots.
The impervious area polygons were created to match the footprint on the ground of these surfaces, rather than
rooflines which may be obscured by the angle of the aerial photography. Figure 3 provides a selection of
digitized SFR parcel types. The parcel boundaries are shown in blue, and the impervious area features created
by Raftelis are translucent blue.
City of Wheat Ridge / Stormwater Utility Feasibility Study 11
Figure 3. Examples of Measured Impervious Area on Sample Parcels
(From left to right: Townhome - 1,084 sq ft; Triplex - 2,331 sq. ft.; Single Family - 3,688 sq ft.;
Duplex - 3,695 sq. ft.)
3.4.3. ERU Determination Results
3.4.3.1. Calculated ERU Values
Raftelis merged impervious area polygons developed for the sample set and intersected the results with the
parcel layer, ensuring one feature (including multi-part features, where applicable) per parcel. The area in square
feet of each impervious area feature was calculated and became the basis for the statistical analysis. Raftelis
recommends using the median measured impervious area from the sample as the ERU. The median is more
statistically robust, and less sensitive to outliers, the very small or very large impervious surface amounts in the
sample, and therefore a more accurate representation of the “typical” impervious area for residential properties
within the City.
The calculated median measured impervious area for the full sample is 3,692 square feet (Figure 4) for all
single family, duplex, triplex, and townhome properties. For the purpose of the ERU analysis, townhome
common area was not included in the unit measurements. Townhomes are discussed in further detail below.
City of Wheat Ridge / Stormwater Utility Feasibility Study 12
Figure 4. Impervious Area Distribution for SFR Sample (by parcel type)
3.4.3.2. Results by SFR Land Use Code
In addition to reviewing the results for the entire sample, Raftelis reviewed the results by land use code to
evaluate whether there are notable differences between the typical amount of IA in single family, duplex,
triplex, and townhome parcels. Figure 5 shows the median amount of impervious area for each of the four
SFR parcel types.
Figure 5. Sample Minimum, Median, and Max Impervious Area for each SFR Parcel Type
0
20
40
60
Co
u
n
t
o
f
S
a
m
p
l
e
P
a
r
c
e
l
s
Measure Impervious Area range (sq ft)
Townhome
Triplex
Duplex
Single Family
Median = 3,692 sq ft
Median,
3,808
Median,
3,792 Median,
2,415
Median, 1,084
0
5,000
10,000
15,000
20,000
25,000
30,000
35,000
Single Family Duplex Triplex Townhome
Im
p
e
r
v
i
o
u
s
A
r
e
a
(
s
q
f
t
)
Min
Median
Max
Median (all SFR)
City of Wheat Ridge / Stormwater Utility Feasibility Study 13
As this graph demonstrates, the median amount of impervious area ranges from 1,084 sq ft for townhomes to
3,808 sq ft for single family. The median and maximum IA for triplex and townhome parcels falls below the
median IA for the whole sample. There are a total of 911 townhome parcels and 33 triplex parcels in the City.
Upon visual review in GIS, the townhome parcels look to be substantially different from single-family, duplex
and triplex parcels because they often just include the building footprint and there is a separate NSFR parcel
for the common area, driveways, and parking. Alternatively, while the two triplexes in the sample had lower
IA than the single family and duplex parcel in the sample, visual review in GIS showed that the 33 triplex
parcels had similar enough qualities to the single-family and duplex parcels to be included in the SFR class.
3.4.4. Recommended ERU
Raftelis recommends the City to use the median amount of measured IA in the SFR with the townhome
sample removed, which is 3,805 sq ft. For ease of communication, the ERU can be rounded to 3,800 square
feet.
3.5. Units of Service Estimation
Raftelis used a two-pronged approach to estimate units of service and impervious area. SFR parcels,
substantially similar in their development as described above, were assumed to be charged a flat rate of 1
ERU each. Non-single family residential properties, which includes multi-family (greater than three units),
industrial, commercial, non-profits, schools, etc. are typically charged a variable rate based on their actual
impervious area. The same GIS parcel and aerial imagery data utilized to calculate the ERU were used to
estimate impervious surface area on NSFR properties via a visual review. Units of service on SFR and NSFR
properties were summed for total units of service.
Although cities sometimes choose to exempt certain groups, such as municipal properties or school districts,
each of these properties has an impact on the drainage system if they have impervious area and can be billed a
stormwater fee under Colorado state law. In some cases, the administrative effort for a municipality to bill
and pay itself is deemed too burdensome, so they exempt municipal properties from the fee. In other cases,
billing all developed properties that have an impact on the drainage system strengthens the perceived fairness
of the fee, and this is seen as a crucial element to the utility framework (more often like water and sewer). All
properties (aside from public rights-of-way) have been included in the initial units of service estimation.
3.5.1. SFR Units of Service
Many utilities use a more simplified rate structure for SFR parcels because the impervious area characteristics
of the parcels in this customer class are more homogenous. Single family residential parcels are also
numerous, so it is both efficient and equitable to adopt a single flat rate for this property class. Under a flat
residential rate, single family customers are charged the same amount regardless of size and amount of
impervious area on an individual property. Typically, under this structure each SFR property is charged for 1
ERU (3,800 sq. ft.). For purposes of this analysis, Raftelis utilized a flat rate SFR rate structure for single
family, duplex, and triplex properties. Townhomes, having substantially less impervious area per unit, were
assumed to represent 0.3 ERUs each, with common areas captured under the NSFR impervious area
estimation described in Section 3.5.2.
If the City wishes to further increase differentiation and equity in the SFR class, they could implement a tiered
or capped approach, which could be explored further during the implementation phase. Under the tiered
approach SFR properties could be placed one of three or more tiers where ERUs would be variable and tied
City of Wheat Ridge / Stormwater Utility Feasibility Study 14
to the median of each tier. Under the capped approach, SFR properties with impervious area over a certain
threshold would be treated like NSFR parcels and billed for actual impervious area, rather than being billed as
SFR. As shown in Figure 4, there were some large single-family parcels in the SFR sample, including one
parcel with approximately 30,000 square feet of IA and two with approximately 11,000 square feet of IA.
3.5.2. NSFR Impervious Area Estimation
To complete the estimate of NSFR units of service, a grid containing 700 cells – with 435,600 square feet per
grid cell – was overlaid on the City parcels. SFR parcels and roads were masked so that only NSFR parcels
remained visible. All types of properties (commercial, industrial, school, non-profits, city) were included in
the NSFR group in order to capture the total impact on the drainage system. Impervious area associated with
streets and sidewalks are part of the stormwater conveyance system and are exempt from the stormwater fee,
which is the approach for the majority of stormwater utilities. The percentage of impervious area visible
within the grid cells was independently estimated by two analysts and the resultant values for each of the grid
cells were compared. An additional estimate was performed for all grid cells where the estimate differed by
more than a tolerable amount, in this case deemed to be 6%. Once all the estimations were complete, the
percentage of NSFR impervious area was averaged for each of the grid cells and the total number ERUs of
NSFR IA was calculated for each grid cell. ERUs for each grid cell were rounded up to the nearest whole
number and summed to estimate the total number of NSFR ERUs of IA in the City. Figure 6 below shows
City imagery and parcels with the grid overlay, and SFR parcels and streets masked.
Figure 6. Example grid with SFR parcels and roads blacked out
City of Wheat Ridge / Stormwater Utility Feasibility Study 15
3.5.3. Units of Service Estimation Results
Using the visual estimation technique described above, NSFR impervious area in the City was estimated to be
around 51 million square feet, which resulted in 13,653 ERUs of IA on the City’s NSFR parcels.
Raftelis estimated units of service for the City based on the total number of estimated NSFR ERUs and the
total number of SFR parcels. The units of service listed in the table below (Table 14) consider each SFR parcel
to be 1 ERU, each townhome to be 0.3 ERU, and NSFR parcels to be 1 ERU per every 3,800 square feet of
estimated impervious area. The townhome value is representative of this parcel set, though the ultimate
billing policy may treat these properties in a slightly different way.
Table 14. Estimated Units of Service based on Estimated ERU Value
Customer Class Total Parcels Estimated ERUs
SFR 8,905 8,905
Townhomes 911 273
NSFR 3,003 13,653
Total 12,819 22,831
The units of service estimation above can be used to calculate preliminary rates based on the stormwater
program revenue requirements and other rate modifiers or policies (e.g., credits) and revenue considerations
(e.g., collections, growth of units of service). Stormwater program O&M and capital costs options and
estimated rates are outlined below. The required revenue was divided by the estimated units of service to
estimate the rate per ERU needed to meet the program revenue requirement. Based on publicly available
data, Wheat Ridge is not experiencing growth, so for the purpose of projecting out units of service and
estimated rates over the planning period, it was assumed that there would be 0% growth of SFR and NSFR
impervious area. Final fees should be based upon measured impervious area for NSFR properties developed
during the implementation phase of the stormwater utility.
City of Wheat Ridge / Stormwater Utility Feasibility Study 16
4. Funding Evaluation
4.1. Total Revenue Requirements and Preliminary Rates
Raftelis developed an open-source Microsoft Excel-based financial model to calculate estimated rates under
different funding scenarios based on stormwater program revenue requirements and estimated units of
service. The financial model includes proposed O&M expenses, proposed capital renewal and replacement
expenses, and additional capital projects. The model allows the user to change the percent allocation of
existing costs, as well as capital project timing and funding approaches to see the impact on proposed rate.
The financial model has been provided to the City under separate cover.
To calculate preliminary rates for the City, Raftelis developed total revenue requirements, which include
O&M expenditures, capital expenditures that are planned to be funded by the stormwater fee, debt service
requirements for debt funded capital projects, and reserve allocations as shown in Table 15 and Table 16. The
timeline for fee implementation may not support a full year of program costs in 2026, but revenue
requirements and rates are both presented on an annual basis. More refined programming can be developed
during the fee implementation process, when timing and methods for billing and collection are determined.
Table 15. Revenue Requirement 2026 - 2030
2026 2027 2028 2029 2030
Operating Expenses
Operations $ 372,000 $ 378,200 $ 384,700 $ 391,600 $ 398,800
Maintenance Programs $ 1,089,000 $ 1,089,000 $ 1,889,000 $ 1,889,000 $ 1,889,000
Total Operating Expenses $ 1,461,000 $ 1,467,200 $ 2,273,700 $ 2,280,600 $ 2,287,800
Non-Operating Expenses
Debt Service $ - $ - $ - $ 133,000 $ 133,000
PAYGO $ - $ 1,803,000 $ - $ 1,560,000 $ -
Total Non-Operating Expenses $ 120,100 $ 1,803,000 $ 319,500 $ 1,693,000 $ 133,000
Transfer to Operating Reserve $ 120,100 $ 121,100 $ 319,500 $ 1,700 $ 1,800
Total Revenue Requirements $ 1,581,100 $ 3,391,300 $ 2,593,200 $ 3,975,300 $ 2,422,600
Table 16. Revenue Requirement 2031 - 2035
2031 2032 2033 2034 2035
Operating Expenses
Operations $ 406,300 $ 414,200 $ 422,500 $ 431,200 $ 440,400
Maintenance Programs $ 1,889,000 $ 1,889,000 $ 1,889,000 $ 1,689,000 $ 1,689,000
Total Operating Expenses $ 2,295,300 $ 2,303,200 $ 2,311,500 $ 2,120,200 $ 2,129,400
Non-Operating Expenses
Debt Service $ 375,600 $ 780,900 $ 893,100 $ 1,338,900 $ 2,178,100
PAYGO $ 1,576,000 $ - $ - $ 2,550,000 $ -
Total Non-Operating Expenses $ 1,951,600 $ 780,900 $ 893,100 $ 3,888,900 $ 2,178,100
Transfer to Operating Reserve $ 1,800 $ 2,000 $ 2,000 $ - $ -
Total Revenue Requirements $ 4,248,700 $ 3,086,100 $ 3,206,600 $ 6,009,100 $ 4,307,500
City of Wheat Ridge / Stormwater Utility Feasibility Study 17
To determine preliminary rates, the revenue requirement for each year was divided by the estimated units of
service for that year. These rates were then normalized to compensate for year-to-year changes in the revenue
requirements and rounded for simplicity. The resulting rates per ERU are shown in the table below. While
these rates support the current modeled scenario, Raftelis strongly recommends reviewing revenue sufficiency
and necessary rate adjustments annually with respect to updated program projections. It is appropriate to
review the rate structure, units of service, and cost of service more comprehensively approximately every five
years to maintain the equity and appropriateness of the rate structure and individual properties’ fees.
Table 17. Proposed Rates per ERU 2026 - 2035
2026 2027 2028 2029 2030 2031 2032 2033 2034 2035
ERU $10.00 $10.00 $11.00 $12.00 $12.00 $13.00 $14.00 $15.00 $15.00 $17.00
Projected cash flows (projected revenues, expenses, and fund balances (which include the reserve)) for the 10-
year period are shown in Figure 7, Table 18, and Table 19 below.
Figure 7. Projected Cash Flows 2026 - 2035
Table 18. Projected Cash Flows 2026 - 2030
2026 2027 2028 2029 2030
Revenues $ 2,739,000 $ 2,739,000 $ 3,013,000 $ 3,288,000 $ 3,288,000
Expenses ($ 1,461,000) ($ 3,270,200) ( $ 2,273,700) ($ 3,973,600) ( $ 2,420,800)
Ending Fund Balance $ 1,278,000 $ 746,800 $ 1,486,100 $ 800,500 $ 1,667,700
Table 19. Projected Cash Flows 2031 - 2035
2031 2032 2033 2034 2035
Revenues $ 3,562,000 $ 3,836,000 $ 4,110,000 $ 4,110,000 $ 4,657,000
Expenses ($ 4,246,900) ($ 3,084,100) ($ 3,204,600) ($ 6,009,100) ($ 4,307,500)
Ending Fund Balance $ 982,800 $ 1,734,700 $ 2,640,100 $ 741,000 $ 1,090,500
$-
$1,000,000
$2,000,000
$3,000,000
$4,000,000
$5,000,000
$6,000,000
2026 2027 2028 2029 2030 2031 2032 2033 2034 2035
Revenues Expenses Ending Fund Balance
City of Wheat Ridge / Stormwater Utility Feasibility Study 18
Although revenues do not exceed expenses every year, the projected fund balance is sufficient to make up for
any projected shortfalls in a given year. This means that the proposed rates are sufficient to cover the
projected expenses in the 10-year study period and maintain the operating reserve levels.
4.2. Proposed Stormwater Rate Comparisons
To provide a more comprehensive understanding of the proposed rates and to situate them within a broader
regional context, Raftelis undertook a review of both the prevailing rate methodologies and the rates
implemented by peer communities across the Front Range of Colorado.
The survey of peer communities shows that, of 19 other communities surveyed, two have adopted a flat-rate
billing methodology for NSFR properties, with the remaining communities included in benchmarking
including impervious area as a factor in their NSFR rate structures. Assuming a monthly charge of $10 per
ERU be implemented for NSFR properties in Wheat Ridge, this proposed rate would position the city's
charges squarely in the middle of the range when compared against the current rates levied by the surveyed
communities for a property with 3,800 square feet of IA and gross area of 6,000 sq. ft.
Figure 8. Monthly NSFR Fee per 3,800 square feet for Peer Communities
$39.60
$24.65
$21.66
$20.04
$20.00
$18.85
$18.20
$14.67
$14.25
$11.32
$11.00
$10.00
$10.00
$9.88
$9.19
$8.27
$7.82
$7.64
$6.46
$5.82
$0.00 $5.00 $10.00 $15.00 $20.00 $25.00 $30.00 $35.00 $40.00 $45.00
Boulder
Denver
Englewood
Adams County
Northglenn
Longmont
Greeley
Golden
Arvada
Loveland
Brighton
Wheat Ridge
Lyons
Littleton
Erie
Parker
Castle Rock
Louisville
Pueblo
Windsor
City of Wheat Ridge / Stormwater Utility Feasibility Study 19
For SFRs, twelve of the communities surveyed currently utilize a flat-rate billing approach. Three charge
tiered rates based on impervious area. All other communities within the survey integrate impervious area as a
foundational element in their rate calculations. In this specific category, a proposed monthly charge of $10 per
ERU for SFR properties in Wheat Ridge would position its rates towards the higher end of the middle range,
specifically within the upper-middle quartile, relative to the observed charges across the peer communities.
Figure 9. Monthly SFR Fee for Peer Communities
Each community establishes rates based on its own stormwater program needs, units of service, and growth
expectations. The outlook of future rate increases varied among the utilities surveyed. Most did not specify
upcoming rate adjustments. One community (Denver) provided a clear policy stating that rates would
increase annually based on the percentage change of the Consumer Price Index for Urban Consumers (CPI-
U). Two communities (Englewood and Arvada) note that customers should expect annual rate adjustments as
costs rise for providing services but did not specify planned increases. Two other communities (Brighton and
Boulder) note that rates are periodically reviewed and may be increased due to factors including rising costs
related to operations, capital investment needs, and regulatory compliance. As discussed in section 4, above,
regular revenue sufficiency reviews and rate adjustments are necessary for the ongoing financial health of a
utility.
$28.46
$26.53
$21.79
$21.66
$18.85
$12.82
$11.75
$11.32
$10.00
$10.00
$9.88
$8.97
$8.72
$8.70
$7.64
$7.50
$6.92
$5.50
$5.36
$2.00
$0.00 $5.00 $10.00 $15.00 $20.00 $25.00 $30.00
Boulder
Greeley
Denver
Englewood
Longmont
Erie
Golden
Loveland
Wheat Ridge
Lyons
Littleton
Castle Rock
Windsor
Parker
Louisville
Arvada
Adams County
Brighton
Pueblo
Northglenn
City of Wheat Ridge / Stormwater Utility Feasibility Study 20
4.3. Stormwater Credit Program Considerations
Often, stormwater fees are accompanied by credit programs, which are designed to recognize and sometimes
encourage investments in private stormwater management through reduced stormwater fees. Credits are
granted to customers, typically, for having and maintaining stormwater facilities that mitigate a property’s
demand upon the stormwater drainage system. Credit programs can create an additional administrative
burden on the utility, however, especially if there are no existing data or processes to leverage for tracking
private stormwater management activities. The City does not anticipate developing a credit program at utility
implementation, but Raftelis does recommend revisiting the topic once the utility is established
City of Wheat Ridge / Stormwater Utility Feasibility Study 21
5. Implementation Considerations
To move forward with the implementation of the proposed stormwater utility, the City must finalize the
stormwater program costs that will be funded through a stormwater utility fee. The City must also consider
the data needs to appropriately calculate units of service, the billing method to convey the stormwater fee, the
opportunity to implement a fee credit program, legal requirements, and public engagement strategies.
5.1. Implementation Data Needs
To proceed with an impervious area-based rate structure for a stormwater utility, the City will need to develop
measured impervious area data for NSFR parcels. The proposed rate structure is a per ERU rate for NSFR
parcels and a flat-rate of 1 ERU for all SFR parcels. This rate structure equitably distributes costs to customers
based on their burden on the stormwater system without requiring significant data development and
maintenance that would be required for a variable or tiered SFR rate. If the City were to consider tiered
residential rates to differentiate between smaller and larger residences, additional data development and
analysis would be required to determine the appropriate tier breaks and classify customers into the correct
tiers.
5.2. Billing Methods
The method for billing customers can have a significant impact on the seamlessness of a fee implementation
and its ongoing maintenance. Different billing methods result in variations in collection rate, staff support,
and policy changes. Prior to implementation, the City will need to determine the billing method that will
balance staff and administrative needs, customer collections, and ease of communications. The typical
methods of billing are as a line item on an existing utility bill, a line item on (or separate bill with) a property
tax bill or as a single item on a standalone bill. In the case of Wheat Ridge, the utility bill option, which is
often a preferred method, is not a viable approach since Wheat Ridge does not provide other utility (water
and wastewater) services. Instead, these services are provided by not one, but a number of different providers
in the area. Thus, a tax or standalone bill line item are more viable options for conveying a new fee. These are
described further below.
5.2.1. Tax Bill
One method of billing stormwater fees is to add the stormwater bills as a line item on the tax bill, or simply in
the same envelope as the existing tax bill. By including the stormwater fee with the tax bill, the City can take
advantage of the established data maintenance structure, and bill print, mailing, and collection mechanism,
including enforcement mechanisms to achieve a higher collection rate.
One of the most pressing concerns with the tax billing option is the potential confusion from tax-exempt
properties when receiving a bill to pay their stormwater fees since it would be the first time that these
properties receive a bill from the Tax Assessor. The City would need to do focused outreach and education
for tax-exempt customers. Lastly, receiving an annual bill would result in a higher lump sum burden that
some customers may find harder to pay than monthly or quarterly bills. The City would need to develop a
customer service program in coordination with Tax Assessor’s Office under this approach.
City of Wheat Ridge / Stormwater Utility Feasibility Study 22
5.2.2. Stand-Alone Bill
Another option would be to send stormwater fees as a standalone bill on a periodic basis. The basis could be a
monthly, quarterly, semi-annual or annual basis – designed to align with the frequency of other bills or to
otherwise balance billing costs and customer payment trends. The customer service and billing system needs
associated with this billing method would likely be more costly than the tax bill option due to the necessity of
incurring additional printing and postage costs, and a likely increase in the amount of staff time that will need
to be devoted to customer support and collections for each bill that goes out. In addition, the collections
enforcement methodology needs to be carefully considered and crafted within applicable laws and statutes.
5.3. Billing Finalization
Depending upon the billing methodology chosen, the City will need to finalize several steps to convey the
stormwater utility bill to customers:
1. Billing method – The City will need to determine if stormwater fees will be billed on the tax bill or
through a stand-alone stormwater bill.
2. Billing policy outline – The City will need to make key decisions on billing policies for the new
stormwater utility. These may include discussions on billing exemptions, aggregation of parcels for
billing purposes, bill disputes, and other topics.
3. Billing data maintenance and customer service – The City will need to determine how data will be
updated and maintained to support accurate billing after utility implementation. The City will also
need to determine how they will conduct customer service, including appeals, adjustment, processing
of credit applications and updates to the billing data as a result of these actions. The City should
determine their internal capacity for handling these processes using business flows compared to the
need for creating or acquiring a software tool to administer some of these processes.
5.4. Legal and Policy Considerations
The City currently has the legal authority to implement a stormwater fee, and many Colorado municipalities
have successfully implemented similar fees. The City will need to develop and pass a stormwater utility
ordinance to establish the proposed stormwater utility and fees. The ordinance would include necessary
details for the fee implementation, such as rate structure details, billing approach, payment enforcement
mechanisms, bill dispute process, and stormwater credits. The City will need to consider its authority to
enforce collections of the new fees. If the City does not have authority to lien properties for non-payment of
stormwater fees, it can be expected that stormwater fee revenue collections would be lower than they would
be with a strong collections mechanism in place. Under a tax bill conveyance scenario collections challenges
would be most acute for tax-exempt properties, while under a standalone bill scenario, collections challenges
are generally more prevalent for all customers.
5.5. Public Outreach and Engagement
The public cast their votes in support of investing in infrastructure through the approval of the “Next
Chapter” of the 2J bond initiative. Building off the success of the bond initiative, the City can communicate to
the public that this Stormwater Utility can help fill the gap in additional infrastructure needs to improve
stormwater management and address major funding issues. Public outreach and engagement will be
imperative to make the connection between the public support for infrastructure investments through the 2J
bond initiative and the remaining stormwater management and funding needs.
City of Wheat Ridge / Stormwater Utility Feasibility Study 23
Raftelis recommends involving the public in the process for implementing a utility. Strong community
support is a major part of a successful fee implementation. The first step to developing a public outreach and
engagement strategy is to identify key stakeholders and target audiences. Key stakeholders and target
audiences for the public outreach effort are often comprised of both internal stakeholders and external
stakeholders. Internal stakeholders comprise City staff, City Boards and Commissions and City’s elected
officials. External stakeholders comprise residents, businesses (particularly those with large amounts of
impervious area), developers, community groups and organizations, educational institutions, and tax-exempt
properties in the City. Residents could be targeted though homeowners’ associations and condominium
associations. Large tax-exempt properties should also be included, once impervious area measurements are
completed.
During the implementation phase, the City will need to conduct outreach and engagement with the key
stakeholders and target audiences described above to promote public understanding for the new stormwater
utility. This plan would likely include in-person engagement events, such as open houses and listening
sessions with community groups, as well as a communication plan that leverages both traditional and social
media.
These techniques may include but are not limited to:
1. Presentations to City Council and other City staff
2. Presentations and listening sessions at planned public engagement events conducted with key
stakeholders and target audiences described above
3. Open house events for the general public
4. City website updates, including the development of FAQs
5. Social media engagement plan
6. Traditional media engagement plan
7. Short video explaining the drivers for the new fees
The project team should create cohesive communication materials to support the goals of the communication
and engagement plan and enable the successful delivery of the engagement techniques identified by this plan.
These materials may include printed media (postcards or bill stuffers), social media posts, fact sheets, website
copy including FAQs, infographics explaining stormwater billing concepts, short animated video, etc.
Depending on the materials, the City may engage a partner organization or consultant to create them.
In addition to providing education and soliciting feedback via in-person meetings and active engagement, the
City could consider more passive communication tools that would be available to future customers at their
convenience. These methods include updates to the City website detailing the utility implementation
background and process. Another component could be communicating draft property-specific fees via a
customer-facing online fee viewer. An example of this fee viewer tool is the one implemented by Boston
Water and Sewer Commission (BWSC) during their stormwater charge implementation. It allows customers
to view their parcel imagery, delineated impervious area, and resulting stormwater charges, as seen in Figure
9 below. Such online tools have proven to be an effective fee communication method with future customers as
they provide property-specific information, reduce customers’ anxiety about the new fee, and reduce customer
support needed in the lead-up and following utility implementation. Raftelis suggests that the City deploy an
online fee viewer after the impervious area data development, rate structure and rates have been finalized to
communicate accurate billing data to customers.
City of Wheat Ridge / Stormwater Utility Feasibility Study 24
Figure 10. BWSC Stormwater Parcel Viewer Tool
5.6. Implementation and Outreach Schedule
As mentioned above, the City should begin the implementation process as soon as they decide to move
forward with implementation. Raftelis’ analysis described above assumed implementation of a Stormwater
Utility beginning in 2026 or early 2027. This provides the City with a 9- to 15-month period to conduct public
outreach and implementation steps. Necessary steps and the associated timing differ based on the billing
approach.
October 2025
This process should begin with a presentation of the findings of this report to City elected officials to solicit
input on program, funding, rates, and implementation. Pending the outcome of that presentation, staff can
refine and implementation plan and schedule, to include the elements described herein.
November 2025 - February 2026
Technical - The focus through the next several months should be refinement of the impervious area data, rate
structures, and financial model. Discussions with the tax office should begin, so that all necessary resources
can be devoted to coordination and technical support if tax billing is an approach under consideration.
Engagement - The City should develop a public outreach and engagement plan during this timeframe to engage
the public and communicate important information about the new fee. This period could conclude with
preliminary information provided on the City’s website, development of an “Frequently Asked Questions”
document, and perhaps the creation of a short video explaining the drivers for the new fee.
March - May 2026
Technical - The City should finalize impervious area data, rates, units of service, and other data needs
identified by the tax office or billing entity, in preparation for billing, and to support more detailed customer
City of Wheat Ridge / Stormwater Utility Feasibility Study 25
outreach. The City should develop customer service policies and procedures and begin to train customer
service staff on stormwater-related billing.
The City should finalize a decision on billing approach. If appropriate, ongoing coordination with the tax
office at this stage should focus on identifying the information and data needed to convey the stormwater fee
on the tax bill.
Engagement - In this period, the City should conduct public outreach and education through open house events
for the general public, and/or presentations and listening sessions at planned public engagement events with
community groups, neighborhood associations and developers. Social media engagement and traditional
media outreach efforts could also begin as outlined by the communications plan. Feedback gathered during
this period should be discussed and incorporated into the next implementation steps as needed. Based on
feedback, if additional workshops or engagement activities are needed, they can be scheduled during this
period as well. A list of customers with the largest amounts of impervious area, tax-exempt properties and
large stormwater only customers could be developed for targeted outreach.
If desired, staff can engage Council on any critical decision points for finalization of the fee.
June - August 2026
Technical - The City would present the Stormwater Utility and Fee Ordinance to the City Council in a public
hearing setting. Once the Ordinance is approved, the utility fee will be effective. The City will need to finalize
the bill file and do a test run of the bill file with the billing entity or tax office. If pursuing a stand-alone billing
option, billing can begin in this period if the system and data are ready.
Engagement – This period should include ongoing communication, and an increased focus on customer
service.
December 2026 - January 2027
If the tax bill is the selected billing mechanism, data are likely to be finalized at the end of the year for January
billing. Please note that this timeline is an estimate, and should be refined in coordination with the County.
Beyond
Provide customer service and data maintenance.
City of Wheat Ridge / Stormwater Utility Feasibility Study 26
APPENDIX A:
Final SFR Sample List (Parcel
Identification Numbers)
City of Wheat Ridge / Stormwater Utility Feasibility Study 27
PIN
39-281-11-004
39-231-03-008
39-252-01-015
39-271-05-005
39-281-01-003
39-282-04-031
39-253-01-012
39-284-09-002
39-244-16-090
39-252-20-009
39-162-13-040
39-291-05-032
39-251-24-009
39-223-11-001
39-161-09-010
39-211-07-022
39-233-14-002
39-233-02-172
39-162-20-016
39-214-12-076
39-291-06-081
39-254-10-014
39-212-03-019
39-281-18-015
39-231-03-018
39-251-11-018
39-234-06-004
39-254-11-023
39-243-06-002
39-264-09-003
39-231-07-016
39-242-21-014
39-251-00-010
39-251-07-011
39-231-06-012
39-281-17-007
39-214-10-003
39-224-04-024
39-214-12-103
39-234-00-039
39-221-02-028
39-244-00-035
39-261-11-003
39-294-12-038
39-201-04-075
39-254-16-013
39-284-07-009
39-251-15-012
39-254-21-001
39-231-09-003
39-292-11-004
39-162-20-031
39-201-04-050
39-234-00-056
39-254-14-005
39-221-01-007
39-253-05-019
39-262-11-002
39-254-03-005
39-213-06-029
39-243-07-001
39-222-02-009
39-233-02-232
39-251-15-006
39-261-00-169
39-224-01-009
39-243-20-006
39-244-07-004
39-251-13-007
39-242-20-006
39-253-14-010
39-162-14-015
39-264-12-015
39-281-16-014
39-161-08-004
39-242-25-036
39-252-04-026
39-214-12-077
39-201-02-013
39-231-14-010
39-223-01-013
39-251-10-001
39-284-06-007
39-222-01-003
39-224-09-004
39-294-06-006
39-271-02-003
39-221-05-023
39-221-04-024
39-204-01-101
39-212-05-002
39-291-08-027
39-244-00-018
39-264-13-001
39-243-07-015
39-222-04-038
39-222-04-008
39-243-09-033
39-284-12-001
39-174-02-006
39-223-09-016
39-233-04-006
39-212-11-005
39-231-01-054
39-254-09-010
39-261-06-001
39-244-18-020
39-213-03-110
39-221-05-035
39-254-21-042
39-272-13-005
39-281-11-012
39-232-08-034
39-231-04-043
39-254-07-016
39-233-19-010
39-221-11-006
39-231-11-004
39-252-06-004
39-272-00-061
39-264-04-010
39-211-02-011
39-251-11-002
39-224-09-008
39-253-18-011
39-221-05-031
39-253-00-019
39-252-05-040
39-234-03-009
39-174-13-065
39-261-00-202
39-203-00-005
39-264-04-007
39-222-16-003
39-294-07-033
39-281-20-004
39-253-13-009
39-253-05-014
39-214-12-084
39-244-16-103
39-252-14-006
39-242-05-005
39-261-99-003
39-174-11-041
39-221-04-030
39-292-02-002
39-264-12-007
39-204-03-018
39-262-13-022
39-243-09-008
39-232-08-039
39-222-13-008
39-293-12-006
39-244-21-015
39-244-07-013
39-244-19-001
39-292-06-013
39-272-15-048
39-272-02-003
39-231-01-006
39-242-02-007
39-203-00-013
39-251-08-005
39-174-11-064
39-212-13-012
39-243-10-022
39-223-01-078
39-221-13-020
39-254-01-002
39-261-14-001
39-251-01-014
39-222-04-030
39-231-09-002
39-211-09-002
39-251-23-011
39-251-16-027
39-253-03-019
39-234-02-012
39-224-00-047
39-244-20-013
39-201-04-056
39-271-05-011
39-221-04-032
39-221-06-008
39-221-17-021
39-223-06-003
39-281-16-001
39-254-06-020
39-231-13-023
39-271-09-009
39-242-02-004
39-223-01-005
39-271-11-013
39-243-06-013
39-242-19-003
39-214-05-020
39-284-01-008
39-234-00-066
39-234-05-006
39-261-14-033
39-144-00-013
39-221-08-008
39-144-00-005
39-214-00-038
39-254-06-006
39-223-01-040
39-232-06-027
39-221-06-018
39-252-07-005
39-224-04-001
39-253-11-017
39-234-00-017
39-252-11-006
39-294-07-035
39-291-06-048
39-291-09-003
39-221-08-022
39-233-15-009
39-251-00-014
39-221-02-007
39-243-09-022
39-281-07-003
39-243-02-014
39-261-04-004
39-224-04-004
39-264-12-027
39-281-01-002
39-251-00-019
39-242-11-006
39-213-07-023
City of Wheat Ridge / Stormwater Utility Feasibility Study 2
39-231-02-010
39-251-03-020
39-251-03-015
39-222-02-026
39-243-08-003
39-162-20-011
39-291-02-006
39-242-20-011
39-224-08-010
39-254-00-012
39-221-03-010
39-282-09-043
39-281-04-013
39-254-12-003
39-251-08-003
39-252-16-018
39-222-04-033
39-264-01-069
39-224-00-061
39-271-07-033
39-222-14-005
39-253-06-008
39-233-16-027
39-284-07-004
39-212-06-007
39-252-01-031
39-284-19-005
39-253-11-003
39-224-00-056
39-251-15-005
39-221-02-027
39-242-18-006
39-212-00-056
39-262-00-047
39-281-17-001
39-272-00-021
39-231-07-038
39-244-00-004
39-232-08-037
39-254-20-011
39-232-05-026
39-251-15-001
39-242-19-014
39-242-17-002
39-291-06-078
39-282-01-037
39-254-24-026
39-272-11-004
39-281-01-006
39-271-02-024
39-253-04-009
39-271-07-013
39-281-01-004
39-254-30-002
39-253-07-007
39-253-11-041
39-261-13-008
39-174-13-074
39-211-04-005
39-174-11-059
39-262-03-024
39-281-04-019
39-243-08-025
39-252-00-021
39-253-03-017
39-261-00-178
39-253-00-039
39-281-18-001
39-214-05-024
39-221-08-012
39-221-06-010
39-214-12-003
39-162-14-023
39-214-12-088
39-254-03-019
39-221-04-018
39-161-07-003
39-231-13-001
39-261-99-005
39-234-07-004
39-211-09-016
39-231-09-008
39-254-21-033
39-291-06-090
39-242-10-001
39-264-03-013
39-242-19-016
39-272-01-001
39-233-02-181
39-272-00-045
39-223-01-084
39-254-11-007
39-213-05-003
39-221-19-002
39-243-08-001
39-221-18-001
39-252-05-009
39-233-11-001
39-272-00-019
39-243-11-022
39-282-02-004
39-251-14-032
39-294-07-039
39-243-12-030
39-211-08-007
39-271-05-013
39-231-05-018
39-284-06-006
39-254-12-023
39-243-11-007
39-281-15-018
39-221-04-015
39-254-09-014
39-251-02-017
39-224-00-036
39-251-21-007
39-253-11-011
39-214-07-013
39-292-06-001
39-272-00-011
39-244-16-042
39-231-07-035
39-261-10-003
39-223-01-096
39-204-01-054
39-254-06-019
39-233-14-003
39-282-06-010
39-214-12-047
39-261-06-006
39-203-00-028
39-291-10-020
39-213-06-049
39-251-07-021
39-244-09-011
39-233-02-135
39-161-08-002
39-231-05-046
39-252-13-005
39-272-04-016
39-293-02-005
39-261-00-073
39-253-09-003
39-242-05-002
39-233-10-006
39-223-01-016
39-261-06-004
39-272-15-043
39-243-14-014
39-232-07-014
39-281-11-017
39-291-06-156
39-291-07-005
39-234-00-038
39-233-07-031
39-294-07-020
39-262-12-005
39-243-00-014
39-264-11-013
39-284-11-005
39-211-09-019
39-253-01-009
39-221-99-003
39-261-13-007
39-292-01-005
39-254-07-007
39-201-02-020
39-243-02-015
39-204-01-042
39-214-00-019