Daily Sewer Usage Per Household In Pennsylvania
In West v. Hampton Twp. Sanitary Auth., 661 A.2d 459 (Pa. Cmwlth. 1995), to project daily sewer usage in 1990, the authority used a 350 gpd/edu figure based on 1950 and 1970 census figures, which indicated that there were 3.5 persons per household in Pennsylvania.
The 3.5 figure was then multiplied by the 100 gpd/per person guideline in the Department of Environmental Protection (DEP) Manual.
The Court noted in West, though, that the 1990 census indicated that there were only 2.57 persons in an average Pennsylvania household.
Consequently, the Court reasoned that because the legislature has determined that rates are to be "for the purpose of providing an actual benefit," it is improper for the authority to rely on a figure that is different from the more current numbers.
Failure to abide by the more current numbers would result in rates that are significantly higher than actually warranted. ... on remand, the authority should employ numbers that are indicative of more current figures. 661 A.2d at 468.