SUPPORTS ITEM NO. 3 CS&B C0MMITTEE AGENDA APRIL 24, 1997 POLICY REPORT PROPERTY TAXATION Date: April 8, 1997 C.C. File No. 1551-1 TO: Standing Committee on City Services and Budgets FROM: Director of Finance SUBJECT: Additional Taxation Policy Considerations for 1997 RECOMMENDATIONS A. THAT Council instruct the Director of Finance to implement a 1997 Property Tax Limitation Program for Class 6 (business) properties, along the lines and with the qualification criteria discussed in this report. The Limitation Program would be enabled under Section 173 of the Vancouver Charter and would require that Council pass a requisite by-law with a t w o - t h i r d s m a j o r i t y . B. THAT Council instruct the Director of Legal Services to prepare a 1997 Property Tax Limitation by-law applicable to Class 6 (business) properties, containing the tax capping parameters outlined in this report, for submission to Council for approval May 13, 1997. C. THAT 1997 be the final year of the tax capping program for Class 6 (business) properties, and that this be indicated on the tax bills. CONSIDERATION The Director of Finance submits the following for CONSIDERATION. D. THAT Council approve a 3.0% increase to the tax levies of Class 2 (utilities), Class 4 (major industry), Class 5 (light industry) and Class 6 (business/other), and a 6.6% increase to the Class 1 (residential), Class 8 (seasonal/recreational) and Class 9 (farm) tax levies, representing an increase to the overall tax levy of 4.5%. The Citizens Advisory Group on Property Taxation submits the following recommendations for CONSIDERATION. The Chair and other members of the group may wish to address Council on this issue. An accompanying letter from the Chair (see Appendix E) elaborates on their position. E. THAT as an alternative to the differential tax increase described in Recommendation D, Council approve an across-the-board 4.5% tax increase, combined with a one percent tax burden shift from the non-residential to the residential classes. F. THAT Council approve a blended single tax rate to be applied to Class 5 (light industrial) and Class 6 (business) properties, and that this blended rate be phased in over a period of five years. GENERAL MANAGER S COMMENTS The General Manager of Corporate Services RECOMMENDS approval of A, B and C, and submits D for CONSIDERATION. Consideration items E and F are submitted by the Citizens Advisory Group on Property Taxation and are included in this present report in order to consolidate our presentation on additional taxation policy considerations for the 1997 taxation year. Item E is an alternative to item D and advances the premise outlined in the KPMG Consumption Report of gradually shifting the tax burden from non-residential properties to the residential class through an annual 1% shift over a five-year period. In tandem with the 1% shift, the Group is recommending a 4.5% across-the-board tax increase. I note for Council that the tax distribution curves produced by E are almost identical to the result produced by D, as shown in Charts 2 and 4 of Appendix D of this report. Given that Council did not approve a similar 1% burden shift recommendation last year, and if Council is disposed to approve a burden shift this year, I RECOMMEND approval of D. Item F deals with the notion of blending the tax rate for Class 6 (business and other) and Class 5 (light industrial) properties. The discussion later in this report develops the rationale for this position. Based on relative consumption of City services, a blended tax rate for the two classes of non-residential properties makes sense, especially after the City implements its sewer utility and the proposed TSS/BOD charge on sewerage at the regional level. Given that the Group is recommending a phase-in period of five years, my suggestion is for Council to defer action on this item until the sewer utility is in place (likely 1998) and instruct staff to report back on the tax burden impacts associated with the utility implementation alongside a staged phase-in of a blended tax rate. The dynamics of those initiatives may allow for a shorter phase-in period than is recommended. COUNCIL POLICY Council policy has been to keep property taxes at affordable levels by holding year-over-year tax increases to inflationary levels. In 1996, there was a 0.1% increase to the general tax levy. Given the recent provincial budget cutbacks in revenue-sharing, Council has made a decision to increase the City s general tax levy by 4.5% for 1997. On February 4, 1997, Council recommended that ... the Director of Finance be instructed to report back to Council with policy options around the implication of the 1997 property tax increase approved by Council this day, including an exploration of weighting the tax increase a little more on the residential sector. From 1983 to 1994, Council maintained the share of the taxation burden between property classes at the levels which existed in 1983, allowing for adjustments to the burden levels resulting from reclassification, new construction or zoning changes. In 1994, Council altered the burden proportions slightly by shifting approximately one percent of total taxes from the business class to the residential class. In 1995, Council again shifted approximately one percent of the total tax burden, proportionately from the utilities, major industry, light industry and business classes to the residential class. The rationale for these shifts was based on the allocation of garbage collection and disposal costs to the appropriate customers. In 1996, the Citizens Advisory Group on Property Taxation recommended that Council shift an additional $3.2 million of the general tax burden proportionately from the non-residential classes to the residential class. Council, however, decided not to undertake a further shift in the tax burden for the 1996 taxation year. Since 1992, the residential, recreational and farm classes have been grouped together in order to establish a common tax rate for billing purposes. Since 1993, Council has used three-year averaged land values in the calculation of residential and business property taxes, as a means of buffering the tax impacts of large year-over-year changes in land values for individual properties. In February 1997, City Council recommended that land averaging be used to calculate taxable values in Class 1 and Class 6 for the 1997 taxation year. PURPOSE The purpose of this report is to recommend additional taxation policy considerations to Council for implementation in the 1997 taxation year. SUMMARY This report presents Council with several tax calculation options for the 1997 taxation year. Impacts of the following taxation options are analysed in this report: 1. a differential tax increase among property classes, 2. a single blended tax rate for the light industrial class and the business class, 3. a differential tax increase among property classes combined with a single blended tax rate for the light industrial class and the business class, and 4. a tax capping program for the business class (Class 6). While there are several options to choose from, none of the options drastically changes the tax rates for the business or the residential class. The largest impact of any of the options modelled for either of these classes is a two percent increase to the residential tax rate. Note that Option #1 is the only option that impacts residential properties. TABLE 1. Summary of 1997 Taxation Options for the Business Class (Class 6) Council- Blended Total Directed Rate Class 6 Average Increase Class 5 Tax Levy Class 6 General Scenario to Class & Class ($ Tax Rate Tax 6 Levy 6 millions Increase ) 4.5% No $185.8 $14.740 6.5% Base Case Option #1 - No $183.1 $14.529 5.0% Differential 3.0% Increase Option #2 - Blended Tax 4.5% Yes $188.0 $14.920 7.8% Rates Option #3 - Differential 3.0% $185.3 $14.706 6.3% Yes Increase & Blended Tax Rate Option #4 - Tax 4.5% $185.8 $14.762 6.7% No Capping/Base Case TABLE 2. Summary of 1997 Taxation Options for the Residential Class (Class 1) Council-Direct Total Blended Rate ed Increase to Class 1 Average Class 5 & Class 1 Levy Tax Levy Class 1 General Tax Class 6 Scenario ($ millions) Tax Rate Increase Base Scenario 4.5% n/a $146.4 $2.747 4.2% Option #1 - Differential Increase 6.6% n/a $149.3 $2.802 6.3% BACKGROUND In recent years, increases to the City of Vancouver tax levy have been equal to or lower than the rate of inflation. In spite of this, taxes on some individual properties have fluctuated greatly due to marked year-over-year changes in assessed values. In order to provide temporary relief from the biggest increases, City Council chose to limit tax increases in 1989. In each year from 1989 to 1995, tax increases were capped within the business and/or residential classes (see Appendix A for a history of tax capping). In 1995, tax capping for residential properties was eliminated, and a phase out program for commercial properties was implemented. This year s option for a differential tax increase has arisen out of the public consultation process undertaken by City Council to address the budget shortfall, which has resulted from sudden cutbacks in provincial revenue sharing. The option of creating a single tax rate for the light industrial and business classes has been proposed by the Citizens Advisory Group on Property Taxation. The Citizens Advisory Group on Property Taxation The Citizens Advisory Group on Property Taxation (CAGPT) was formed in March 1996. The mandate of this group is to provide Council with community input on taxation issues, by commenting on taxation matters as they appear before Council. The group is comprised of a balanced mix of business, residential and academic representatives, and all members are residents of Vancouver. The CAGPT is the successor to two earlier groups with similar mandates: the Property Tax Task Force (1993/1994) and the Property Tax Advisory Panel (1994/1995). The Property Tax Task Force submitted a report to Council in April 1994, which contained fourteen recommendations regarding the property taxation and assessment systems. Among these recommendations was one that a study of consumption of residential and non-residential consumption of city services be undertaken. Council commissioned such a study, and in April 1995 KPMG Management Consulting submitted its report to Council, entitled Study of Consumption of Tax-Supported City Services. At that time, Council instructed the Director of Finance to report back on a longer-term taxation policy that would take into account the findings of this report, and the related recommendations of the Property Tax Advisory Panel. The formulation of a longer term taxation policy was to include the following considerations: taxation policy based on benefits, services and the ability to pay; tax write-off opportunities; and, differential tax rates within classes of property. These issues are among those now being considered by the CAGPT. Both the Property Tax Task Force report and the KPMG Consumption study are on file with the City Clerk. The CAGPT has made some recommendations relating to the issues contained in this present report. A letter from the Chairman of the group is circulated with this report, indicating the group s position on the issues of tax capping, blending light industrial and business class tax rates and, a differential tax increase among classes. The 1996 Taxation Year A summary of last year s taxation policies is provided here as background. In 1996, taxes for residential properties (Class 1) were based on three-year land averaged values (1996 improvement value plus average of 1994, 1995 and 1996 land values). No tax capping was applied to this class. Taxes for business properties (Class 6) were also based on three-year land averaged values, and a 20% cap was applied to year-over-year overall tax increases, under a phasing out methodology. A maximum credit of $7,500 was allowed. There was no shift in the tax burden among classes in 1996. DISCUSSION The impacts of statistical modelling of the following taxation options are presented in this report: (1) a differential (unequal) tax increase among the property classes, (2) a blended tax rate for the business and light industrial classes, (3) these first two options combined, and (4) a 25% tax cap for business class properties. Interpreting the Results In assessing the various taxation options, it should be noted that an option that is good for the class as a whole will not necessarily benefit an individual property. For example, capping large tax increases will result in less properties having extremely high year-over-year increases, but, those properties not receiving a tax cap will pay slightly higher taxes as a consequence. This is because the total tax levy collected from a class is the same with and without tax capping. Also, the various taxation options may have opposing impacts on an individual property. For example, tax capping can lower the total taxes paid by an individual business property, while at the same time blending the Class 5 and Class 6 tax rates will increase the taxes paid by that same property. Note that a Council-directed tax increase is the percentage increase by which Council chooses to increase the tax levy for each class. This is distinct from the average tax increase for each class, which is the mean change in year-over-year taxes for all properties in a class. While the first is a decision, the second is an outcome. Year-over-year changes in taxes paid by a property are a function of two variables: (i) the change in taxable value of that property, and (ii) the Council-directed tax increase for that property s class. For this reason, the Council-directed tax increase is not likely to be the same as the average tax increase for each class. All analyses are done on sub-samples of Class 1 and Class 6 properties, screened for those that have been transferred into the class in the last year, those that are exempt from taxation, and those that did not pay taxes in 1996. Properties are included in the sample, but are not eligible for a tax cap, if they have new construction or if they are vacant. A large proportion of both residential and business properties with the greatest year-over-year tax increases have at least one of these characteristics. OPTION #1: DIFFERENTIAL TAX INCREASE On February 20, 1997, Council approved a 4.5% increase to the general tax levy, and directed staff to explore weighting the tax increase slightly more on the residential sector. Historically, any increase to the general tax levy has been spread evenly across all classes. The option of a differential tax increase arose out of the City Choices public consultation process, the Mayor's Forum, and the Angus Reid survey of both residents and businesses. Angus Reid reported that ...68% of business community members surveyed believe the current level of property taxes they pay are too high , a full 22% more than for residents. Further, Angus Reid reported that over 60% of residents surveyed supported paying an additional eight percent in property taxes, to help maintain the level of services they currently receive. This compares to only one-third of all business respondents supporting a 4% tax increase. As an alternative to an evenly apportioned tax increase, the option considered here applies a 3.0% increase to each class, representing inflation and service growth factors in the budget. The remainder of the tax increase, representing Council s alternative to deeper service cuts, is applied proportionately to the residential, seasonal/recreational and farm classes. The effect of this is a three percent increase to the levy of each class except for the residential classes, which incur a 6.6% increase. Impacts of a Differential Tax Increase The application of a differential tax increase is essentially the equivalent of a moderate shift in the tax burden from all other classes onto the residential class, of $2.9 million. With a differential tax increase, a tax increase of $9.2 million is added to the residential tax levy, as compared to $6.3 million with an across-the-board increase. Correspondingly, with a differential increase, the increase to the business class levy is $5.3 million, as compared to an increase of $8.0 million with an across-the-board increase. The business class pays $2.7 million less than it otherwise would. Under this option, the other property classes collectively pay approximately $200,000 less than they otherwise would. The following tables show the impact of this option on overall tax levies and tax rates. TABLE 3. Implications of a Differential Tax Increase Among Property Classes, Tax Levy Tax Levy with Tax Levy with Across-the Board Differential Increase Increase Difference ($ millions) ($ millions) in Tax Levy Residential (1), Recreational (8) & Farm (9) $146.7 $149.6 + $2,900,000 Utilities (2) $7.1 $7.0 - $102,000 Major Industry (4) $4.1 $4.1 - $60,000 Light Industry (5) $5.0 $4.9 - $72,000 Business (6) $185.8 $183.1 - $2,666,000 Total $348.7 $348.7 $0 TABLE 4. Implications of a Differential Tax Increase Among Property Classes, Tax Rates Tax Rate Tax Rate Across-the-Board Differential Difference Increase Increase to Tax Rate Residential (1) $2.747 $2.802 + $0.06 Utilities (2) $31.826 $31.369 - $0.46 Major Industry (4) $31.444 $30.993 - $0.45 Light Industry (5) $27.127 $26.738 - $0.39 Business (6) $14.740 $14.529 - $0.21 Recreational (8) & Farm (9) $2.714 $2.767 +$0.05 Chart 1 of Appendix D shows the distribution of tax increases in the business class with an across-the-board 4.5% increase. Chart 2 compares this distribution to that resulting from a 3.0% increase to the Class 6 levy. The tax rate for Class 6 drops by 21 cents (1.4%) if the levy is increased by 3.0% rather than by 4.5%. The average increase in general taxes paid for Class 6 properties decreases to 5.0% with a differential increase, compared to 6.5% with an across-the-board increase. Chart 3 shows the distribution of tax increases in the residential class with an across-the-board 4.5% increase. Chart 4 compares this distribution to that resulting from a 6.6% increase to the Class 1 levy. The tax rate for Class 1 increases by 6 cents (2.0%) if the levy is increased by 6.6% rather than by 4.5%. The average increase in general taxes paid for Class 1 properties increases to 6.3% with a differential increase, compared to 4.3% with an across-the-board increase. Residential tax distributions are shown in the following table. It is noted that the large majority (approximately 90%) of those properties with a tax increase of over 20% are either vacant or have increased in value due to new construction. TABLE 5. Class 1 Tax Distribution, General Taxes # Properties # Properties Across-the-Boa Differential Overall Tax rd % of Increase % of Increase, Increase Sample (6.6%) Sample 1997/1996 (4.5%) <= 0% 13,526 11% 7,071 6% 0% - 2% 19,884 17% 6,137 5% 2% - 5% 48,794 41% 37,911 32% 5% - 7% 16,547 14% 30,118 25% 7% - 10% 12,173 10% 22,301 19% 10% - 20% 5,568 5% 12,581 11% 20% - 30% 737 1% 1,023 1% 30% - 50% 465 < 1% 501 < 1% > 50% 726 < 1% 777 < 1% 118,420 100% 118,420 100% OPTION #2: BLENDED TAX RATES FOR BUSINESS & LIGHT INDUSTRIAL CLASS A majority of the members of the Citizens Advisory Group on Property Taxation feel that there is not a good rationale for a discrepancy in the tax rates for light industrial and business properties, and has recommended that the rates for the two classes be blended to a single rate, through a multi-year phasing plan (see accompanying letter from the Chairman of the CAGPT). The rationale for this recommendation is based on the fact that there is very little distinction between properties classified as either business or light industrial. Properties in both classes are assessed at market value, and both are compatible with mixed use developments. In 1996, the general tax rate for the light industrial class (Class 5) was $25.9979 per $1,000 of taxable property value, and for the business class (Class 6) was $14.5581. The rate for the light industrial class was about 1.8 times higher than that for the business class. There are only 129 properties in Class 5, and the total assessed value of this class accounts for under one half of one percent of the total roll value. In 1996, the Class 5 share of the total tax levy was just under one percent. Appendix B contains a listing of properties in this class, and Appendix C contains the legal definition of Class 5 property that is used by the BC Assessment Authority. Impacts of Blending the Tax Rates for the Light Industrial and Business Classes Blending Class 5 and Class 6 tax rates to a single rate is essentially the same as a shift in the tax burden from light industrial properties to business properties, of approximately $2.3 million. This represents an increase of about 18 cents (+1.2%) to the business class tax rate. Correspondingly, the light industrial tax rate would be decreased by $12.32 (-45%). Chart 5 of Appendix D compares the Class 6 tax distribution, comparing separate versus blended tax rates for the business and light industrial classes. TABLE 6: Impacts of Blending Tax Rates for the Light Industrial and the Business Class Class 5 Class 6 Light Industrial Class Business Class SEPARATE RATES Est. 1997 General Tax Rate1 $27.1270 $14.7404 Est. 1997 General Tax Levy $5.0 million $185.8 million BLENDED RATE Est. 1997 Blended Tax Rate2 $14.8093 $14.9199 Est. 1997 General Tax Levy $2.7 million $188.0 million IMPACTS Change in Tax Rate - 45.4% + 1.2% Tax Burden Shift - $2.3 million + $2.3 million 1 Assuming a 4.5% increase to the Class 5 and to the Class 6 levy; Class 6 rate based upon land averaged assessments. 2 Projected blended tax rates are different because Class 6 rate is based upon three-year land averaged taxable values, and Class 5 rate is based on unaveraged taxable values. Rates are first blended to calculate appropriate levy for each class, then Class 6 rate is adjusted for averaged taxable values. Council has the option of phasing the change from two separate tax rates for the light industrial and business class to a blended single tax rate for the two classes, which would moderate the year-over-year impact of this change on the business class. OPTION #3: COMBINED DIFFERENTIAL TAX INCREASE & BLENDED TAX RATES This option combines Option #1 and Option #2, each examined individually above. While a differential tax increase lowers the Class 6 tax burden, blending business and light industrial tax rates increases the Class 6 burden. Together, the effects of each almost negate each other. The decrease to the business class tax rate under this option is under 4 cents: $14.706 versus $14.747 with no intervention. Chart 6 of Appendix D shows that the base case tax distribution is almost identical to the one resulting from Option #3. OPTION #4: TAX CAPPING IN THE BUSINESS CLASS In 1994, the Property Tax Task Force reached a consensus that capping taxes to a determined percentage increase limit was appealing in the short term, in that this prevented taxes on individual properties from undergoing dramatic changes from year to year. The Task Force also recognized that capping taxes masks the real changes in market values that underlie tax increases and that once tax capping is lifted the adjustment back to market level taxation would be very difficult and painful. Given the foregoing, the Task Force concluded that: "Tax capping is not a tool that should be used by City Council on an ongoing basis to mask tax increases that are due to jumps in actual market values." The Task Force recommended that a plan to phase out the use of tax capping should be part of the proposed consumption study, leading to a new tax policy for the City. In response to this, in their report to Council entitled Study of Consumption of Tax-Supported City Services, KPMG Management Consulting recommended that Council confirm and implement an approach for phasing out tax capping. A phase-out program has been in place for the business class for the past two years, with an increasing cutoff for the cap each year, and a decreasing maximum credit value. There has been no tax capping in the residential class since 1994, and no capping is modelled or recommended for the residential class in this present report. Impacts of Tax Capping For 1997, tax capping has relatively minor implications for Class 6 properties. A small number of properties receive a cap, and the tax rate for the class is only slightly higher than it would be with no capping. As opposed to the first three options discussed above, the impacts of tax capping are assessed using total taxes as opposed to general taxes only. The City of Vancouver levy comprises only half of the taxes collected on the City of Vancouver property tax bill. Provincial school taxes account for most of the remainder, about 42% of the total. The other 8% is collected by the City of Vancouver on behalf of the following agencies: Greater Vancouver Hospital District, BC Assessment Authority, Municipal Finance Authority, GVRD and BC Transit. As with the other options, the modelling for tax capping is done using three-year land averaged values for calculating 1997 taxes. All non-City of Vancouver property tax levies are assumed to increase by 3% over 1996. The capping mechanism that is being recommended to Council this year for Class 6 is based on increasing the year-over-year bottom line tax increase hurdle rate from 20% to 25%, and reducing the maximum amount of tax credit from $7,500 to $5,000. This would increase the Class 6 tax rate by approximately two cents or 0.1% to $14.762 per thousand dollars of taxable value. The number of properties in this class that would benefit from capping this year (about 230 properties) is reduced from the approximately 760 properties that received a benefit in 1996. The essential features of the proposed tax capping program are: i. A 25% cap on each property s year-over-year bottom line tax increase. ii. A $5,000 limit on the tax credit to an individual property. iii. Exclusion from capping for an individual property if: ™ the property does not qualify for land assessment averaging in 1997 pursuant to By-law No. 7712, or ™ the property did not have an assessed value for improvements in both the 1996 and 1997 taxation years, or ™ the property was exempt from real property taxation in 1996, or ™ the 1997 assessed improvement value of the property has increased by more than 10% over its 1996 improvement assessment and such increase is, according to the records of the BC Assessment Authority, attributable to a change in the physical characteristics of the improvement. iv. Capping does not apply to sewer, water, local improvement or other charges. This tax capping option is consistent with the phase-out approach recommended by KPMG Management Consulting, and recommend that this be the last year of tax capping in the business class to complete the phase-out program that was implemented three years ago. The following table shows the effect of a 25% tax cap on the tax distribution for the business class. After capping, 650 properties incur a tax increase of over 20%, but less than half of those properties are eligible for a tax cap. Only six of the 193 properties with an increase over 30% are eligible for a cap. Chart 7 of Appendix D shows the Class 6 base distribution of year-over-year increases to all taxes (that is, not just general taxes). Chart 8 compares this distribution to that produced with the application of a 25% tax cap. TABLE 7. Class 6 Tax Distribution, All Property Taxes Overall Tax No % of 25% Cap % of Increase, 1997/1996 Capping Sample # Sample # Propertie Propertie s s <= 0% 1,827 24% 1,810 24% 0% - 2% 2,669 35% 2,645 35% 2% - 5% 989 13% 1,019 13% 5% - 7% 354 5% 354 5% 7% - 10% 425 6% 432 6% 10% - 20% 711 9% 710 9% 20% - 30% 315 4% 457 6% 30% - 50% 207 3% 123 1% > 50% 123 1% 70 1% 7,620 100% 7,620 100% Tax Capping and Other Taxation Options The tax capping analysis shown in Option #4 applies to existing taxation policy. Neither a differential tax rate nor blended Class 5 and Class 6 tax rates are assumed. Tax capping can also be applied in conjunction with any of the first three taxation options presented in this report. In the case of a differential tax increase, which lowers the Class 6 tax rate, fewer properties would receive a cap than shown here. In the case of blending the Class 5 and Class 6 tax rates, the business class tax rate is increased, and more properties would receive a cap. However, because neither Option #1, Option #2 nor Option #3 change the business class tax rate significantly, the impacts of capping combined with any of these options will not vary greatly from those shown here. SOCIAL IMPLICATIONS Property taxation policy has a direct impact on children and families. In order to make owned and rented housing as affordable as possible, Council has attempted to dampen large year-over-year tax increases, which are driven by real estate market conditions in the city, since 1989. Council action to date has also capped the growth of business taxes with a view to preserving the business/residential character of Vancouver s neighbourhoods. CONCLUSION This report outlines additional taxation policy options for Council consideration before appropriate 1997 tax rates are struck to reflect a balanced operating budget. In continuing to phase out the tax cap in the business class, a 25% tax cap with a $5,000 tax credit limit is recommended. The impacts of a tax cap are moderate, with under 300 properties receiving a cap, and the tax rate is increased by only two cents. The impact of a differential tax increase is presented for consideration, applying a 6.6% increase to the residential class levies, and a 3.0% increase to non-residential class levies. This results in a 4.5% increase to the overall tax levy, and is consistent with the results of the public consultation process Council undertook earlier this year. Such a differential tax increase adds two percent to the general taxes paid by each Class 1 property. The adoption of Consideration E submitted by the Citizens Advisory Group on Property Taxation would produce a similar result. At the request of the Citizens Advisory Group on Property Taxation, the option of blending the tax rates for the light industrial and business classes to a single rate is presented for consideration. This change would result in a $2.3 million burden shift onto Class 6, which would be phased in over a period of up to five years. * * * * *