Canadian Property Management - GTA & Beyond

F O R B U I L D I N G O W N E R S , A S S E T A N D P R O P E R T Y M A N AG E R S

VOL. 25 NO. 2 • JUNE 2018

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TABLE OF CONTENTS

CONTENTS 04

08

COVER STORY

04

CONSERVATION COSTS OVERSTATED DURING CAMPAIGN Energy management experts argue electricity rates are the correct source of funding

14

IN THIS ISSUE

08

ELECTRICAL CAPACITY POSES EV HURDLE

12

ONTARIO REVISES PROPERTY ASSESSMENT SCHEDULE

Condos could struggle with demand to accommodate charging stations

MPAC moves baseline evaluation date forward to enable more consultation

10

LOCKING IN GLOBAL ADJUSTMENT COSTS

14

VACANT DWELLING TAX DEEMED COSTLY TO COLLECT

Large commercial electricity customers prepare for new round of conservation initiative

Toronto lacks data to easily identify empty homes

“ELECTRICITY SUPPLY AND DEMAND ARE ALWAYS LINKED. SAYING THAT ENERGY CONSERVATION HAS ‘NOTHING TO DO WITH KEEPING THE LIGHTS ON’ IS LIKE SAYING THAT YOUR RIGHT HAND HAS NOTHING TO DO WITH YOUR LEFT FOOT.” COREY DIAMOND EXECUTIVE DIRECTOR, EFFICIENCY CANADA

ENERGY MANAGEMENT

CONSERVATION C

OVERSTA

DURING CAMP Energy management experts argue electricity rates are the correct source of program funding

BY BARBARA CARSS

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JUNE 2018

COSTS

ATED

PAIGN

ENERGY MANAGEMENT

T

he upfront costs of Ontario’s electricity conservation programs are lower than the incoming government is alleging.

During the recent provincial election campaign, Premier Doug Ford promised that his party’s plan to fund energy efficiency measures with tax revenue rather than directly through hydro rates would cut the average family’s annual electricity costs by about $43. However, the average residential customer currently pays less than $28 toward conservation.

“Electricity distributors and the IESO (Independent Electricity System Operator) are investing roughly $400 million annually, which is prorated to 130 billion kilowatthours (kWh) of consumption. That works out to about 0.3 cents per kWh allocated to the Global Adjustment,” calculates Andrew Pride, an engineer and consultant providing guidance on environmental sustainability and energy management, who oversaw provincial conservation initiatives prior to the Ontario Power Authority’s merge with the IESO. “For average households consuming 750 kWh, their share of program costs would be $2.30 per month.”

Beyond debunking flawed estimates of potential savings, he argues that decoupling conservation costs from the electricity rate structure would upend the most economically rational funding formula. The user-pay approach directly links charges to consumption, allows electricity distributors to self-sufficiently finance initiatives that principally benefit their own operations and ratepayers, and makes program administrators accountable to funders who are also their customers.

“Considering that, long term, the electricity system saves more than two dollars for every dollar invested in conservation, it makes sense for the electricity system to pay the costs,” Pride asserts. “Keeping the drivers aligned supports cost-effective energy savings.”

“Rate-based financing for energy conservation programming is a widely accepted practice throughout North America,” concurs Mark Winfield, a professor in York University’s Faculty of Environmental Studies and co-chair of its Sustainable Energy Initiative.

COST-EFFECTIVE INVESTMENT Expenditures to implement energy-saving measures have proven to be investments with favourable returns. The Environmental Commissioner of Ontario’s 2018 Energy Conservation Progress Report points to both the short-term benefits of reducing peak demand that would otherwise press gasfired generation plants into production of pricier and dirtier power, and the longer term savings from delaying or avoiding the need to build new highly capital-intensive generating facilities and associated transmission and distribution assets.

Commissioner Dianne Saxe pegs the lifecycle costs of new generation at 7 cents per kWh for wind power, 12 cents/kWh for hydroelectric and nuclear, 14 cents/kWh for solar and 16 cents/kWh for bioenergy, versus system costs of 2.1 cents/kWh as existing generating capacity is stretched through conservation and demand management. “Over the past decade, conservation has saved money for all electricity customers and delivered additional benefits to those who participate in programs, including low-income customers and Aboriginal communities,” she states.

“Conservation is the cheapest way to match supply to demand,” reiterates Keith Brooks, programs director with the public interest group, Environmental Defence. “The Province should continue to put conservation first, pursue all cost-effective conservation and fund it from the rate base.”

Commercial real estate players and public sector facilities managers have clearly seen the value in energy efficiency, both individually and through industry organizations like REALPAC, the Building Owners and Managers Association, the Federation of Rentalhousing Providers of Ontario, the Canadian Condominium Institute and the Canadian Healthcare Engineering Society.

Currently, for example, management teams and tenants from more than 500 buildings, encompassing nearly 80 million square feet of commercial space, are enrolled in the race2reduce, targeting a collective 10% reduction in energy consumption (relative to 2016) for the 2018-2020 period. This follows the 12.1% energy savings achieved across 200 buildings participating in an earlier 2011-2015 iteration of the race. www.REMInetwork.com

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ENERGY MANAGEMENT

GLOBAL ADJUSTMENT OPAQUENESS Yet, commercial electricity customers share residential customers’ concerns about escalating rates. In particular, the lack of details about the components and their relative weights within the bucket of costs known as the Global Adjustment — which now accounts for 80 to 90% of the commodity cost of electricity — makes it easier for critics to typify conservation as a buried cost

and to lump it with other presumed nefarious elements believed to be inflating the price of electricity.

“Right now, seniors, small businesses and families are paying for hidden expenses on their hydro bills that have nothing to do with keeping the lights on,” Doug Ford maintained, as he outlined a scheme envisioned to enable “the average Ontario family” to save 12% on electricity costs.

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Along with transferring conservation programming to the provincial tax base, he also promised to return Hydro One dividends to ratepayers and to attempt to renegotiate some of the energy contracts now enveloped in the Global Adjustment.

Many observers acknowledge that Ford is tapping into justifiable concern about the opaqueness of the Global Adjustment. His targeting of conservation costs might be seen as a complement to the Toronto Region Board of Trade’s energy policy position paper — released to raise issues ahead of the provincial election — which recommends: “Costs not directly related to generation, transmission and distribution should be moved out of electricity prices and either funded by the tax base or cancelled.”

However, proponents of energy efficiency counter that conservation is directly related to those key elements.

“Electricity supply and demand are always linked. Saying that energy conservation has ‘nothing to do with keeping the lights on’ is like saying that your right hand has nothing to do with your left foot,” scoffs Corey Diamond, Executive Director of Efficiency Canada, a national organization promoting energy conservation. “It’s all connected.”

More transparency would serve conservation well since it should reveal its lower cost in comparison to other Global Adjustment components. Many energy management practitioners and potential recipients of program funding would also welcome more scrutiny of the communications and marketing expenditures attached to conservation.

“I think having a review of where we’re spending the money and what we’re getting for it would be a good thing,” submits Scott Rouse, Managing Partner of the consulting firm, Energy@Work. “But I don’t think the programs should be moved off the ratepayer base to the tax base. It’s just one of the fundamentals: electricity should pay for electricity; water should pay for water, etc.” ■ ________________________________________

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ENERGY MANAGEMENT

ELECTRICAL CAPACITY

POSES EV HURDLE

Condos could struggle with demand to accommodate charging stations

BY MICHELLE ERVIN

N

ew rules for steering the installation of electric vehicle charging stations at Ontario condo properties may have a blind spot.

With the rollout of regulations designed to support condo owners who want to swap gasfuelled vehicles for electricity-powered vehicles, condo sector professionals suggest electrical capacity could in some cases continue to impede the introduction of this infrastructure at certain sites. The new rules relax Condominium Act requirements tied to making changes to the common elements that would otherwise have to be satisfied for electric vehicle charging station installations to proceed.

At a press conference to announce the regulations, the then Minister of Government and Consumer Services, Tracy MacCharles, said the move came as part of the province’s Climate Change Action Plan and follows consultations on how best to facilitate the installation of electric vehicle charging stations at condo properties.

“Condo owners have indicated to us they face significant challenges in seeking condo board approval to install electric vehicle charging systems on condo premises and frustration with the inability to obtain a condo board approval for installation,” she reported.

STREAMLINING APPROVALS After conducting in-person consultations with key stakeholders and reviewing more than

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600 submissions, the Ministry of Government and Consumer Services adopted two of the five regulatory proposals it put forward for public feedback in the fall of 2017. The new rules will essentially limit the ability of boards to reject owner applications to install electric vehicle charging stations, as well as restrict the ability of owners to challenge board plans to do the same.

“Part of the problems that we’ve been dealing with is that for condo corporations that want to install it, depending on the cost, it would fall under the section 97 notice to owners,” said condo lawyer Denise Lash.

“With these new regulations, it will now be easier for boards of directors to have these stations installed at their discretion, and there won’t be that cumbersome process.”

Boards will still have to notify owners of plans to install electric vehicle charging stations, but owners won’t have the 30 days they are generally given to object to proposed changes to the common elements by forcing a meeting of owners where this type of proposal can be voted down. The only prerequisites for taking this route are that the costs of installation can’t add up to more than 10% of the corporation’s operating budget and the installation itself can’t be foreseen by the board to measurably diminish owners’ enjoyment and use of the property.

Similarly, owners who make applications to install electric vehicle charging stations that

satisfy these and several other requirements can expect to receive approval from their condo board.

“There will be certain provisions in the regulations that will deal with what a board can look at in order to determine whether or not to permit the electric vehicle station, so they can’t just arbitrarily refuse it,” said Lash.

The reasons a condo board can reject a condo owner’s application to install an electric vehicle charging station include that a professional qualified to do so has provided the opinion that it would conflict with electrical safety legislation or pose a serious risk of damaging the property or harming its residents. However, Lash said she’s been told a condo property can only accommodate so many electric vehicle charging stations — an issue echoed by Rob Detta Colli, manager of energy and sustainability at Crossbridge Condominium Services.

INFRASTRUCTURE CHALLENGES “From the electric vehicle owner’s perspective, I think it’s loud and clear that they will only accept a charger in their own spot. They do not want to move their vehicle back and forth,” said Detta Colli. “From the condo management perspective, and from the board’s perspective, that leads them down a road where you know you can honour the first request, the second request, maybe the fifth request, but the sixth person you’re going to have to say 'no' to.”

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Electrical capacity varies from building to building based on a variety of factors, including design and location. Detta Colli lists inadequate space in a building’s mechanical room for new infrastructure and lack of capacity at the transformer station supplying the building’s electricity as common constraints.

The new rules give condo boards some flexibility to ask owners to make changes C to their proposed installation, which may M indirectly provide options in cases where electrical capacity is a concern. Detta Y Colli explained that if it’s not possible to CM accommodate a charging station at a condo MY owner’s parking space, the condo board could CY suggest relocating the proposed installation CMY to a visitor's parking space, as an example.

Crossbridge Condominium Services K will be encouraging its clients to have the electrical capacity of their properties assessed so they have that information handy when they start fielding requests from owners under the new rules. Condo boards will be obligated to supply condo owners with the details needed to complete their written applications, which boards will have to respond to within 60 days. Condo boards that take the initiative to install electric vehicle charging stations that meet the prerequisites for using this expedited process will similarly be able to proceed 60 days after notifying owners of their plans.

Once a condo board has approved an owner’s application to install an electric vehicle charging station, the parties will have another 90 days to hash out an agreement that addresses who is responsible for costs, insurance and maintenance (owners are expected to absorb installation costs unless otherwise negotiated). Condo boards and owners who fail to come to an agreement could find themselves headed to mandatory mediation and arbitration, a costly process which Detta Colli said some condo managers worry owners may be eager to trigger.

Despite some outstanding obstacles, he said he sees the potential for the new rules to make it easier to install electric vehicle charging stations at condo properties by introducing a defined, step-by-step process for dealing with applications. Speaking at the press conference, MacCharles acknowledged some of the other, sweeping changes to Ontario’s condo laws that have started to roll out, which include mandatory licensing for condo managers and training for condo directors. ■

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ENERGY MANAGEMENT

LOCKING IN GLOBAL ADJUSTMENT COSTS Large commercial electricity customers prepare for new round of Industrial Conservation Initiative

BY BARBARA CARSS

M

any larger commercial electricity customers in Ontario recently got a look at their first peak demand report cards. Instead of a grade point average, though, they received a mathematical factor to calculate their share of the bucket of costs known as the global adjustment (GA) for the 12 months beginning July 1.

This year, the Building Owners and Managers Association (BOMA) of Greater Toronto’s annual global adjustment workshop came at the end of a rookie season for many designated Class A customers participating in Ontario’s Industrial Conservation Initiative (ICI). Eligibility for the potential cost-saving program was broadened for 2017-18 to include commercial customers with a monthly peak demand of at least 1 megawatt (MW).

Previously, the vast majority of commercial customers — with the exception of very large accounts with monthly peak demand of at least 5 MW or data centres with peak demand of at least 3 MW — had been lumped into Class B, which pays the global adjustment on a straightforward per kilowatt-hour basis after the Class A allocation has been subtracted from the pot.

Class A customers’ monthly share is calculated with a consistent factor derived from their peak energy demand during the five hours in the 12-month period from May 1 to April 30 when the highest total system demand is recorded. Report cards released in late May affirmed the newbies’ skill, or luck, in foreseeing and responding to those five hours in 2017-18. June 15 was the formal date for opting in for 2018-19.

“The decision to be Class A or Class B could cost you or save you tens and tens of thousands of dollars,” Bala Gnanam, BOMA Toronto’s Vice President, Energy, Environment and Strategic Partnerships, told the gathering.

“We are seeing a tendency that Class A is achieving better savings than Class B, but it’s not universal,” cautioned Scott Rouse, Managing Partner with the consulting firm, Energy@Work, one of the slate of speakers outlining possible strategies for mitigating costs that are expected to be significant well into the future.

Last year, the global adjustment amounted to about $12 billion to cover energy supply contracts and a multitude of capital and carrying

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costs for generation and transmission assets. It now accounts for 80 to 90% of the commodity price of electricity, while the more modest component, known as the hourly Ontario energy price (HOEP), varies with the price of fuel.

“The only fuel cost in the Ontario system is for natural gas. Our view is the HOEP is going to be lower and lower,” observed Adam White, Chief Executive Officer of the energy consulting firm, Powerconsumer Inc. “Most of what we pay are out-of-market contract costs for regulated supply and assets. About $2 billion goes to solar, wind and conservation and the rest goes for nuclear and natural gas. All the natural gas [generating capacity] built and not used [most of the time], we’re paying for.”

OPERATIONAL STRATEGIES Class A status is no guarantee of savings. An upward blip in consumption could backfire, particularly since building energy loads already tend to align with system-wide demand.

Rouse cited an example of building operators unwittingly conducting power-intensive maintenance at the wrong time — a misstep that locked in a full year of higher costs — as a reminder of the importance of informing and preparing all key players in advance of likely peaks.

Outreach to tenants should also be central to the strategy since lease restrictions and/or concerns about comfort and the building’s reputation can limit the scope for shedding load.

Sophisticated modelling may now help forecast more precisely, but, as the peaks typically occur a few days into prolonged summer heat waves, this knowledge doesn’t necessarily make it easier to appease weary building occupants.

“Commercial buildings aren’t in the business of managing the GA,” Rouse acknowledged. “Industrial has a lot more advantage in being able to control their loads.”

“Our number one priority is really tenant comfort,” agreed Phillip Raffi, National Manager, Energy and Sustainability, with Colliers International, as he sketched out the rationale for investing in energy storage to

ENERGY MANAGEMENT unobtrusively reduce load. “I also didn’t want building operators having to run around doing 20 different things at the same time.”

The system was seen as a good fit for a west end Toronto complex that has peak demand of 1.4 MW, and is in keeping with energy management efforts and priorities across Colliers’ portfolio. “Any type of energy-saving opportunity we could undertake, we have done,” Raffi reported.

The technology provider, Matthew Sachs, Chief Operating Officer with Peak Power, sees software-based prognostics as central to the system’s effectiveness in forecasting and controlling the charging and discharging of batteries. “At the moment of peak demand, some of the energy is coming from the grid and some of the energy is coming from the battery,” he said.

He argued that other sections of the hydro bill also underpin the business case for the investment. Delivery charges are prorated to customers’ 15 minutes of peak monthly demand meaning that, combined with the five peaks, eight hours of the year exert direct influence on up to 70% of Class A customers’ electricity bills. Nor does he see a threat in the possibility that a new provincial government could dismantle the current system.

“Peak demand is a problem and there always has to be some market solution to reduce the problem,” Sachs hypothesized.

DIMINISHED SAVING PROSPECTS As relative latecomers to Class A, commercial customers likely face diminished prospects for savings compared to those that the small group of early enrollees enjoyed. The ICI originally served something of a dual function to reduce stress on the electricity system and to bolster some key sectors struggling with economic downturn and competition based in jurisdictions with cheaper production costs. White credits the program for both staving off blackouts and saving Ontario’s pulp and paper industry.

“We needed to give rate relief to manufacturers, and it has worked very well,” he submitted. “Power peaks are lower than they used to be.”

Today, with participation now open to thousands — commercial customers with peak demand of at least 1 MW and manufacturers with peak demand of at least 500 kilowatts — the dynamics have changed.

Concerted efforts to “chase the peaks” can trigger enough load reduction to alter their intensity and timing. Rouse noted, for example, that last year’s summer peaks all occurred between 4 and 5 p.m., a couple hours later than traditional expectations.

“The number of Class A participants is impacting the peak,” concurred Robert Edwards, Business Manager, Private Sector, with Ontario’s Independent Electricity System Operator.

Total system demand is the divisor for determining potential savings, and it is has been dropping. Last year’s peak hour of demand — 21,786 MW between 4 and 5 p.m. on September 25 — wouldn’t have cracked the top 10 five years earlier. And this trend may present a happier scenario for Class B customers.

“The more the Ontario peak goes down, all things being equal, the higher the peak demand factor will be,” White explained.

“One megawatt divided by 27,000 versus one megawatt divided by 21,000 gives different results. It’s not all moving to Class B. It’s an arbitrage. As it gets squeezed out, nobody is saving.”

Ultimately, the current best advice for Class B customers remains a sound message to all. Conservation should be the starting point of every strategy.

“There is still a lot of opportunity for Class B,” Rouse asserted.

“You don’t have to worry about chasing peaks. You can get your base load down.” ■

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MARKET TRENDS PROPERTY TAX

ONTARIO REVISES PROPERTY

ASSESSMENT SCHEDULE MPAC moves baseline evaluation date forward to enable more consultation

BY BARBARA CARSS

O

ntario property taxpayers have been promised more and easier input into the next province-wide reassessment.

The 2018 Ontario budget announced that the

base date for pegging property values will be moved one year forward, to January 1, 2019, to give the Municipal Property Assessment Corporation (MPAC) more time to consult and

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potentially adjust valuations before a new fouryear assessment cycle begins in 2021.

This advance disclosure framework was actually introduced during MPAC’s previous provincial valuation exercise in 2016, but, generally, only fairly large commercial and multi-residential landlords got the opportunity to see and dispute the numbers before finalized property assessment notices were mailed out. An earlier start is meant to support what the budget calls a “meaningful and open exchange of information among MPAC, property owners and municipalities”. As part of that, MPAC is also reviewing how it gathers data about building revenue and operating costs, which underpins commercial and multiresidential valuations.

“Our hope is that the longer gap [before values are finalized] will enable all of us to have better, more accurate assessments. We were also pleased with the announcement that MPAC is working on making it less onerous to submit information,” says Dean Karakasis, Executive Director of the Building Owners and Managers Association (BOMA) of Ottawa, which has been part of a working group providing MPAC with stakeholder feedback.

“Taking those two things in tandem, we would say that’s a good outcome.”

Nevertheless, industry insiders caution it could take awhile to work through some bottlenecks in the process. The launch of a new four-year cycle in 2017 spurred a wave

PROPERTY TAX

of assessment appeals as property owners reacted to often dramatic increases in value over the previous assessment, which had been based on the property value as of January 1, 2012. Compounding that, a new timetable for appealing to Ontario’s Assessment Review Board (ARB) was introduced last year.

“The problem we are going to run into in many cases is there is not going to be a conclusion of the 2016 appeals before the baseline of 2019,” predicts David Gibson, a Director with Yeoman & Company Paralegal Professional Corporation. “It may get complicated just because of the large volume of appeals that will likely still be before the board.”

While the new schedule stretches the time available for disclosure and discussion, assessors and ratepayers now face a tighter deadline for initial evaluations. “By the time we get into mid-year 2019, MPAC is going to be very busy with appeals arising from the fact there were effectively no ARB hearings during the 2017 calendar year due to introduction of the new board rules,” Gibson observes.

He favours more frequent assessments, such as in British Columbia where they occur annually. Or, if that would be too labourintensive across Ontario’s approximately 5.4 million properties, a two-year interval should Untitled-4 still deliver more consistent values from one property assessment to the next.

“The huge swings we’re seeing in assessed value may be right, but owners put them under appeal just because they’re so extreme,” Gibson says. “I don’t think we’re solving that by moving the baseline date.”

A city of Toronto report confirms that commercial property values increased 33.6%, on average, between the 2012 and 2016 assessments, while average multi-residential values climbed an even more startling 54.4%. “Individual properties, particularly those located in high-demand areas or in redevelopment areas (e.g., Yonge Street) saw assessment increases far in excess of the average,” the report states.

In Ottawa, Karakasis has heard no notable outcry for more frequent reassessment, but acknowledges there could be some benefits.

“I think the first step is to make it less onerous to comply with MPAC’s requirements.

Right now, we’re okay with the timing,” he says.

“Sometimes, though, a building goes down in value, and you don’t want to be caught midcycle having to jump through hoops to make the point.” ■

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2016-06-08 4:11 PM

PROPERTY TAX

VACANT DWELLING TAX DEEMED COSTLY TO COLLECT Toronto lacks data to easily identify empty homes among 752,000 residential accounts

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tax on vacant residential units would be costly to collect and do little to increase Toronto’s supply of affordable housing, a recent report to City Council’s executive committee concludes.

Provincial legislation enacted last year gives Toronto the flexibility to impose a special levy on houses and condominium units that owners have purposely left unoccupied, but financial policy staff advise that won’t be a straightforward task. They recommend more study, including monitoring the results of similar taxes now being rolled out in Vancouver and Melbourne, Australia, before council makes a decision.

“There is no reliable estimate for the number of residential units that may be vacant in Toronto, but could otherwise be rentable,” the report states. “If homes that are rentable, but are intentionally being left vacant could be readily identified, then a vacant home tax would be simpler to implement and would be a sensible tool to apply to achieve the policy objectives of increasing housing supply or providing a source of funds for housing initiatives, or both.”

In contrast, the report outlines the many complications that could push administrative costs above expected revenue. Much of the data that might indicate if a unit is vacant comes from fragmented sources, is not currently

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collected or inaccessible due to privacy issues, and is frequently inconclusive.

For example, recent Toronto hydro and water data reveals 15,000 to 28,000 residential units with low consumption levels, but that could be attributable to various reasons.

Owners could be travelling, convalescing in a health care facility or simply frugal. The city also issues thousands of residential building permits every year, which often means units are vacant because they are under renovation.

Vancouver’s methodology — requiring all householders to annually declare whether a property is their principal residence or be subject to an automatic surcharge on their tax bills — would be much more unwieldy across Toronto’s approximately 752,000 residential tax accounts. “It is difficult to anticipate the significant administrative challenges associated with adoption of such an approach for Toronto,” the report observes.

Drawing on more than 8,000 survey responses from the public consultation conducted last year, about three quarters of respondents favour the general concept of a vacant dwelling tax. However, only 39% would support the tax if it generated less revenue than the cost to administer it.

Beyond the challenge of identifying who should be taxed, the report questions how vacant residential units relate to the dearth of affordable supply and if a tax would motivate owners to release vacant housing to

the market. It hypothesizes that owners who have already chosen to forego approximately $32,000 in annual rental income that a two-bedroom condo unit could typically command in the Toronto market may not be swayed by an additional $4,000 to $5,000 in tax. Owners of vacant units who responded to the city’s consultation also confirmed they would be unlikely to offer them for affordable rents.

“The hallmarks of a good tax tool is that it is shared in a fair and objective manner having regard for capacity to pay, that it can be provided at a low administrative cost with an objective assessment mechanism, that tax avoidance will be negligible and that the tax will be accepted by the public,” the report states. “Based on this evaluation, a vacant home tax does not meet many of the principles of a good tax.”

Local governments in New York and London appear to have drawn the same conclusion, as they considered then rejected the imposition of a vacant unit tax.

Toronto policy advisors will be observing and assessing outcomes in Vancouver and Melbourne, where 2018 will be the first year a vacant dwelling tax will be collected. Already, the costs to implement Vancouver’s program have increased from the 2016 estimate of $4.7 million to $7.4 million across a base of approximately 225,000 residential taxpayers. ■

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