In Howard Jarvis Taxpayers Assn. v. City of Roseville (2002) 97 Cal.App.4th 637, the Court considered a challenge to an in-lieu payment at a flat 4 percent of the annual budgets of three of Roseville's municipal utilities that provided water, sewer, and garbage collection. (Id. at p. 648.) In considering the constitutional validity of the in-lieu payment, we acknowledged that "of course," the city could recoup "what it costs to provide such services including all the required costs of providing service, short-term and long-term, including operation, maintenance, financial, and capital expenditures." (Id. at pp. 647-648.) Even so, the Court concluded the "fee does not represent costs. It is a flat fee. It is imposed on the utilities' budgets, presumably after their total costs have been accounted for in the budget process. If the budget of a utility increases because of a cost increase unrelated to the in-lieu fee, the in-lieu revenues, as a flat percentage of that increased budget, increase as well. The in-lieu fee is the same percentage applied to each budget, regardless of varying uses of streets, alleys and rights-of-way by the individual utilities. It cannot be said that this flat fee on budgets coincides with these costs." (Id. at p. 648.) In Roseville, the in-lieu payment violated Proposition 218 because the "'revenue from the in-lieu franchise fee is ... placed in Roseville's general fund to pay for general governmental services. It has not been pledged, formally or informally, for any specific purpose.'" (Roseville, supra, 97 Cal.App.4th at p. 650.) This practice ran "afoul of section 6(b)(2) that 'revenues derived from the fee or charge shall not be used for any purpose other than that for which the fee or charge was imposed.' It also contravened section 6(b)(5) that 'no fee or charge may be imposed for general governmental services ... .'" (Ibid.)