The "Regulation on the methodology for setting the prices of services of compulsory municipal utilities for environmental protection" (URL 87/2012 and 109/2012) provides, inter alia, for the separate charging of: a) the discharge and treatment of urban waste water and of precipitation waste water from public areas, and b) the discharge and treatment of precipitation waste water from roofs. The unit of measurement for the activities under (a) shall be m3 of water consumed or supplied through a water meter, and for the activities under (b) shall be m3 determined as the average rainfall over the last five years according to the data of the competent institution for the defined area. As the 'Regulation' as such sets out and defines in detail all the essential elements necessary for the determination of the final water supply and disposal price to be paid by the user for any of the cases referred to in the 'Regulation', it is not clear whether the 'Regulation' is intended to be applied to all the cases referred to in the 'Regulation'. meaningful provision as to why the discharge (and treatment) of rainwater from public areas is charged according to the unit of m3 of water consumed or supplied through a water meter, since the quantity of water supplied through a water meter has absolutely no dependence on the quantity of rainwater discharged (and treated) from public areas. This description still leaves out the discharge of rainwater from paved private areas, the discharge of stormwater through sewerage systems, etc. In fact, from the content of the "Regulation" it can be concluded that the discharge (and treatment) of rainwater from, among other things, highway surfaces is partly financed depending on the consumption of (drinking ?) water through water meters, which in all likelihood does not "hold water".  Thus, in view of the otherwise well-defined and defined elements necessary for the determination of the final price of the service, it is not understandable why the grantor does not define as separate items the discharge (and treatment) of rainwater from public road surfaces, from public and private paved surfaces and the discharge of storm water. A layman's view of the urban areas that are sewered allows an estimate that of the total urban area, roof areas account for about 40%, paved areas for about 30% and road areas (excluding motorways) for the remaining 30%. Thus, the "Regulation" in question treats separately the basically cleanest storm water from roofs (the word "waste" is deliberately not used), which "needs" to be treated only if it is discharged through a mixed sewerage system; but does not treat separately as an essential element the waste water from public areas (roads, paved areas, not to mention parts of motorways), which needs to be treated and (it is estimated) accounts for about 60% of the surface area and thus also the quantity. Furthermore, it is necessary to point out the problem inherent in the definition of the utilisation rate of the public service infrastructure capacity as the ratio between the actual utilisation of the public service infrastructure capacity and the maximum design capacity of the public service infrastructure. In the case of the sizing of storm water sewers, the rules apply, which are probably also known to the grantor, that the sewerage system should be sized for a 50 or 100 year return period (depending on the economic viability of the area in question). By the way: no depreciation rate of the materials or equipment installed shall be less than 2%, which implies a 50 year return period. This fact therefore makes it possible to charge more for the operation of 'overpriced' (100-year return flows) but correctly sized sewerage systems than they were technically designed and built correctly. This problem is even worse in the case of a mixed sewerage system, where the 100% (and, as explained earlier, in all likelihood oversized) capacity of the sewer is technically divided into 5-10% for the discharge of urban wastewater and 90-95% for the discharge of rainwater (!?) Could this "oversizing" in the area of depreciation be sensibly used as part of the price element of the "special service provided by the contractor" price (Art. 11) ? These problems are not defined in the "Regulation" in question, nor are the starting points for their uniform treatment given, and leave a lot to be desired by municipalities, both as owners of the municipal infrastructure and as providers of this type of public service, to achieve, in the new pricing of municipal services, virtually whatever prices they want for the "new" services that they are already providing under the existing prices, which are (or should be) also under the scrutiny of the competent authorities, if all the other provisions are correctly observed (i.e. legally speaking) when setting the new prices for municipal services. We can be sure that the revenues of both the municipality and the provider of this type of public service, once the new (different ?) prices are established, will be significantly higher than the current ones for the provision of the same services to the same extent as before. It is true, however, that the operators of this type of public service will (have) to go to a considerable amount of work and unnecessary expense to determine the value of the unknown, which has hitherto been the total surface area of all roofs, by establishing how and where the rain is discharged, in other words, given that at least the public areas are already fairly well defined. And public areas are used by everyone, not just those connected to the sewerage system.  The proposed solution: a) the discharge and treatment of rainwater from public areas is charged at the recognised cost of the public service operator, i.e. for discharge via separate storm sewers, without taking into account depreciation or rental equivalent as defined in this 'Regulation'; and for the discharge and treatment of rainwater via a mixed sewerage system, with depreciation or rental equivalent taken into account. The activity is financed from the municipal budget (use of public areas is not limited to individual users of the sewerage system) b) the discharge of rainwater from roofs is charged at the recognised costs of the public service operator, namely for discharge via separate storm sewers without taking into account depreciation or rental equivalent as defined in this 'Regulation'; for discharge of rainwater via a mixed sewerage system, with depreciation or rental equivalent taken into account. The activity shall be financed by monthly payments from the users according to the following simplified method: A = monthly cost to the user B = total area of the sewered area of the municipality (100%) C = total area of public areas D = total area of roofs E = roof area of the user F = recognised annual total cost of the public service operator G = depreciation A = (F : D x E) : 12 and A = ((F+G) : D x E) : 12 Note: To the extent that the issue raised is misunderstood on my part and may not even exist, I apologise.