Markle, Judge. When Barrow County (“the County”) and several municipalities within its jurisdiction reached an impasse regarding the approval of an update to their public service delivery strategy agreement, including the manner in which funds were collected for road maintenance and water services, the County sought resolution in the superior court, pursuant to OCGA § 36-70-25.1 (d). The City of Winder (“Winder”) appeals from the court’s orders on several motions, contending that the superior court erred by misinterpreting certain provisions of the Service Delivery Strategy Act (“the Act”), OCGA § 36-70-20 et seq., and by denying its motion to dismiss the County’s claim that Winder’s water rates for customers beyond its municipal boundaries amount to an impermissible tax. For the reasons that follow, we affirm. The Act requires local governments to develop strategy agreements for the provision and funding of public services to county and municipality residents in order “to minimize inefficiencies resulting from duplication of services and competition between local governments and to provide a mechanism to resolve disputes over local government service delivery, funding equity, and land use.” OCGA § 367020. Under this framework, when the County and several local municipalities, including Winder, could not agree on revisions to the existing county service delivery strategy (“SDS”) agreement,[1] they participated in several rounds of mediation. See OCGA § 36-70-25.1 (c).[2] Although the parties were able to resolve the large majority of their disputes, the County and Winder were unable to agree on two critical issues: funding for countywide road maintenance and Winder’s provision of, and rates assessed for, water utility service to unincorporated residents (i.e., county residents located beyond Winder’s limits). The County then filed its petition for judicial resolution pursuant to OCGA § 36-70-25.1 (d) (2),[3] raising four specific issues before the superior court: (1) whether the County was authorized to charge Winder residents for the maintenance of county-owned roads; (2) whether Winder impermissibly charged an arbitrary rate differential for water utility service based on customers’ location within or beyond the city limits; (3) whether the County was authorized to provide water utility service to Winder’s unincorporated customers; and (4) whether Winder’s water charges amounted to an illegal tax on its unincorporated customers. The superior court ordered the parties to mediate these issues, but mediation proved unsuccessful. Winder then moved for partial summary judgment on the issue of road funding, essentially contending that, under its reading of OCGA § 36-70-24 (3) (A), the geographic location of the roads determined which county residents could be charged for their maintenance. The County filed a cross-motion for summary judgment on this issue, claiming that road funding was dependent on who used the service — as opposed to the geographical location of the road. Thereafter, Winder filed a second motion for partial summary judgment, contending that the County’s sources of revenue to fund services for the unincorporated areas were limited solely to those enumerated under OCGA § 36-70-24 (3) (B). In addition, Winder filed a motion to dismiss the County’s claim regarding the alleged illegal tax, contending that it was beyond the scope of this statutory proceeding. Following a hearing, the trial court denied Winder’s motions, but granted the County’s motion for partial summary judgment on the road funding issue.[4] This appeal followed. 1. Winder first argues the superior court erred by denying its motion for partial summary judgment, and granting the County’s cross-motion, on the issue of road funding because the court misinterpreted OCGA § 36-70-24 (3) (A). Essentially, Winder contends that the Act prohibits the County from charging city residents for the maintenance of countywide roads that are located beyond the city limits; whereas the County contends the issue turns on usage as opposed to geographical location. We conclude the trial court properly interpreted the statute. This Court reviews de novo a grant or denial of summary judgment, viewing the evidence and all reasonable conclusions and inferences drawn from it in the light most favorable to the nonmovant. Summary judgment is proper when there is no genuine issue of material fact and the movant is entitled to judgment as a matter of law. Further, the interpretation of a statute is a question of law, which is reviewed de novo on appeal. (Citations and punctuation omitted.) Ridgewalk Holdings v. Atlanta Apartment Investment Corp., 358 Ga. App. 717, 719 (856 SE2d 75) (2021). Additionally, [o]ur interpretation and application of statutory language is guided by the following principles: A statute draws its meaning, of course, from its text. Under our wellestablished rules of statutory construction, we presume that the General Assembly meant what it said and said what it meant. To that end, we must afford the statutory text its plain and ordinary meaning, we must view the statutory text in the context in which it appears, and we must read the statutory text in its most natural and reasonable way, as an ordinary speaker of the English language would. Though we may review the text of the provision in question and its context within the larger legal framework to discern the intent of the legislature in enacting it, where the statutory text is clear and unambiguous, we attribute to the statute its plain meaning, and our search for statutory meaning ends. (Citations omitted.) Stockton v. Shadwick, 362 Ga. App. 779, 782-783 (1) (a) (870 SE2d 104) (2022). With these guiding principles in mind, we turn to the merits of Winder’s arguments. Winder argues that the plain language of OCGA § 36-70-24 (3) (A) supports its contention that its residents are excluded from paying for countywide road maintenance beyond its city limits. We disagree. OCGA § 36-70-24 addresses certain criteria that must be considered in the development of a service delivery strategy. Specifically, OCGA § 36-70-24 (3) (A) provides: The strategy shall ensure that the cost of any service which a county provides primarily for the benefit of the unincorporated area of the county shall be borne by the unincorporated area residents, individuals, and property owners who receive the service. Further, when the county and one or more municipalities jointly fund a countywide service, the county share of such funding shall be borne by the unincorporated residents, individuals, and property owners that receive the service. In its reading of this provision, Winder emphasizes the phrase “any service which a county provides primarily for the benefit of the unincorporated area.” OCGA § 36-70-24 (3) (A) (Emphasis supplied.). Under Winder’s interpretation of this phrase, if a road requires maintenance in the unincorporated area, it necessarily follows that the road maintenance service primarily benefits those residing in the unincorporated area (who are then solely responsible for bearing the costs of its upkeep because they “receive the service”). Id. By its proposed interpretation, the City attempts to dissociate usage (i.e., who uses the roads) from the term “benefit” in OCGA § 36-70-24 (3) (A). But these concepts are inextricably intertwined. The noun “benefit” is generally defined as “something that produces good or helpful results . . .; useful aid.” Merriam-webster.com/dictionary/benefit (last visited October 17, 2022); see Catoosa County v. Rome News Media, 349 Ga. App. 123, 128 (825 SE2d 507) (2019) (“Except when considering a technical term or term of art in a particular industry, Georgia courts often begin by considering how a word has been defined in dictionaries to determine its plain and ordinary meaning.”). And the transitive verb “to benefit” is generally defined as “to be useful or profitable to.” Merriam-webster.com/dictionary/benefit (last visited October 17, 2022) (as in “tax cuts that primarily benefit the wealthy”) (emphasis in original). Thus, Winder’s proposed statutory interpretation is unreasonable. See Stockton, 362 Ga. App. at 782 (1) (a) (“we must read the statutory text in its most natural and reasonable way”) (citations omitted). County roads, regardless of their specific geographic location, benefit all residents of the county — as does their upkeep. See generally DeKalb County v. City of Decatur, 247 Ga. 695, 697 (2) (279 SE2d 427) (1981) (“County taxpayers residing in municipalities enjoy the use of DeKalb County parks, roads and other facilities, and the protection of the DeKalb County police, while they are going about their business or enjoying their leisure time outside the boundaries of the municipalities in which they reside.”).[5] Under the plain language of the Code section above, because the county roads do not primarily benefit the unincorporated area, unincorporated residents are not solely burdened with the costs of their upkeep.[6] OCGA § 36-70-24 (3) (A). Our broader reading of this provision comports with the codified intent of the Act, “to provide a flexible framework within which local governments in each county can develop a service delivery system that is both efficient and responsive to citizens in their county. OCGA § 367020. As the County correctly argued, the focus of the Act is not on the geographical location of the public service, but on who uses (and thus benefits) from the service. See OCGA § 36-70-24 (3) (A). Thus, the superior court was correct in granting summary judgment to the County on the issue of road funding under the plain language of this Code section.[7] 2. Winder next argues that the superior court erred by denying its second motion for partial summary judgment, regarding the viable sources of funding for countywide services, because the court misconstrued OCGA § 36-70-24 (3) (B). Again, we disagree. OCGA § 367024 (3) (B) provides: Such funding shall be derived from special service districts created by the county in which property taxes, insurance premium taxes, assessments, or user fees are levied or imposed or through such other mechanism agreed upon by the affected parties which complies with the intent of subparagraph (A) of this paragraph[.] Winder contends that the four enumerated sources of revenue listed in this Code section are the sole sources a county may draw on to fund services that are deemed primarily for the benefit of the unincorporated area or are jointly funded by a county and a municipality under OCGA § 36-70-24 (3) (A). The County disagrees, contending that OCGA § 367024 (3) (B) does not limit funding for such services to those four discrete items; rather it merely requires counties to form special service districts and then references general funding categories that are permitted within such districts.[8] Construing the plain language of OCGA § 36-70-24 (3) (B), the County’s interpretation of this statute is the most natural and reasonable. Stockton, 362 Ga. App. at 782-783 (1) (a). Under our reading of this Code section, when OCGA § 36-70-24 (3) (A) applies to a public service, the funding for such service must “derive from” a special service district.[9] OCGA § 36-70-24 (3) (B). In that special district, property taxes, insurance premium taxes, assessments or user fees are to be imposed or levied. Id. But nowhere in OCGA § 36-70-24 (3) (B) is a county directed to specifically apply these revenue sources to fund the service. Importantly, OCGA § 36-70-24 (3) (B) does not specify the nature of the user fees or assessments, or whether they necessarily arise from the given public service; these are general categories. Although Winder urges us to interpret the term “assessments” in OCGA § 36-70-24 (3) (B) as “special assessments” designated for a specific purpose, this Code section includes no such qualifier, and we may not rewrite the statute in this manner. Harris v. Mahone, 340 Ga. App. 415, 422 (797 SE2d 688) (2017) (“[T]his Court does not have the authority to rewrite statutes.”) (citation and punctuation omitted). We thus reject Winder’s contention that the list of revenue sources set forth in OCGA § 36-70-24 (3) (B) identifies the sole means by which the County may fund a public service under OCGA § 36-70-24 (3) (A). As such, the trial court properly denied Winder’s motion for summary judgment on this issue.[10] 3. Winder next contends that the trial court erred by denying its motion to dismiss the County’s claim that Winder’s water usage rates amounted to an illegal tax on its unincorporated water customers. We address Winder’s specific arguments in turn, and conclude that the trial court did not err. A motion to dismiss for failure to state a claim should not be sustained unless (1) the allegations of the complaint disclose with certainty that the claimant would not be entitled to relief under any state of provable facts asserted in support thereof; and (2) the movant establishes that the claimant could not possibly introduce evidence within the framework of the complaint sufficient to warrant a grant of the relief sought. Where, as here, a case turns on statutory interpretation and resolution of questions of law, we apply a de novo standard of review. (Citations omitted.) Stockton, 362 Ga. App. at 780. (a) Winder first argues that the trial court lacked authority to resolve this issue because OCGA § 36-70-25.1 (d) does not permit a trial court to issue an injunction or grant declaratory relief. This argument is unavailing. Once a petition for judicial resolution has been properly filed, OCGA § 36-70-25.1 (d) (2) authorizes the superior court to “conduct an evidentiary hearing . . . as such judge deems necessary and render a decision with regard to the disputed items.” That section further provides that the court, in its discretion, may impose or hold in abeyance the statutory sanctions under OCGA § 36-70-27 (a); use its contempt powers to ensure compliance with its decision; and impose costs if it determines a party has acted in bad faith. Id. Thus, although OCGA § 36-70-25.1 (d) (2) limits the remedies a court may impose, it places no such restriction on the “disputed items” the court is directed to resolve.[11] Moreover, nothing in the Act prohibits the trial judge from determining whether or not a charge for services amounts to an impermissible tax. Importantly, OCGA § 36-70-24 (2) (A) specifically provides that “water or sewer fees charged to customers located outside the geographic boundaries of a service provider shall not be arbitrarily higher than the fees charged to customers receiving such service which are located within the geographic boundaries of the service provider.” OCGA § 36-70-24 (2) (B) then sets forth a method for resolving “disputes [over] the reasonableness of water and sewer rate differentials,” including alternative dispute resolution. These Code sections do not preclude the trial court’s consideration, as Winder insists; rather, they demonstrate that water rate issues may become “disputed items” left for the superior court to resolve. OCGA § 36-70-25.1 (d) (2); see Lathan v. Hosp. Auth. of Charlton County, 343 Ga. App. 123, 128 (1) (805 SE2d 450) (2017) (“A statute must be construed in relation to other statutes of which it is a part, and all statutes relating to the same subjectmatter, briefly called statutes ‘in pari materia,’ are construed together, and harmonized wherever possible[.]“) (citation omitted). We are also not persuaded by Winder’s contention that the trial court lacked subject matter jurisdiction to consider this claim, nor by its claim that the trial court failed to consider its motion to dismiss under OCGA § 9-11-12 (b) (1).[12] As we have explained, “the question of whether a plaintiff has a cause of action under a particular statute is an ordinary issue of statutory interpretation, not a jurisdictional question. . . . The scope of a statutory cause of action, then, is not an appropriate inquiry to consider on a OCGA § 91112 (b) (1) motion to dismiss.” Stillwell v. Topa Ins. Co., 363 Ga. App. 126, 131 (1) (871 SE2d 8) (2022). Accordingly, under our construction of the plain language of the Act, the trial court is authorized to consider this claim as a disputed item under OCGA § 36-70-25.1 (d) (2). (b) Winder next argues that this claim is precluded by binding case law that holds water usage charges are not taxes, and that nonresidents lack standing to challenge how water charges are spent. This argument is unavailing. First, we note that the cases cited by Winder predate the Act. See, e.g., City of Moultrie v. Burgess, 212 Ga. 22 (90 SE2d1) (1955); Messenheimer v. Windt, 211 Ga. 575 (87 SE2d 402) (1955); Alford v. City of Eatonton, 174 Ga. 169 (162 SE 495) (1932); see also City of Union Point, 303 Ga. at 449 (noting the Act became effective in 1997); Ga. L. 1997, p. 1567, § 1. Importantly, the Act implicitly acknowledges a governing authority’s standing to challenge water charges assessed in its jurisdiction by another governing authority, as the County does here. See OCGA § 36-70-24 (2) (B). Second, none of the cases relied on by the City establish a bright line rule that water fees may never amount to an illegal tax. See, e.g., Alford, 174 Ga. at 169 (2) (“The question of uniformity in taxation is therefore not presented.”); Messenheimer, 211 Ga. at 578 (1) (noting without further analysis that, because the petitioners were not residents of the city, the water fees they paid to the city did not amount to taxes). This argument is thus without merit, and the superior court did not err in denying the City’s motion to dismiss this claim.[13] Judgment affirmed. Mercier, J., concurs. Dillard, P. J., dissents. In the Court of Appeals of Georgia Dillard, Presiding Judge, dissenting. I respectfully dissent from the majority’s opinion and would reverse the trial court as to each of the City’s enumerated errors. 1. I begin by considering the meaning and application of the Service Delivery Strategy Act; and my analysis necessarily begins with the settled principles by which courts discern statutory meaning. A statute “draws its meaning from its text,”[14]1 and that meaning is fixed at the moment of its enactment.[15]2 Importantly, an appellate court must presume “the General Assembly meant what it said and said what it meant,”[16]3 and “read the statutory text in its most natural and reasonable way, as an ordinary speaker of the English language would.”[17]4 In doing so, we look to “the common and customary usages of words,” especially “as used in a legal context.”[18]5 Additionally, we may consider the standard rules of English grammar to aid us in understanding the relevant statutory text.[19]6 And context is, of course, a “primary determinant of meaning.”[20]7 So, when the meanings of words are uncertain, the other words appearing in the same statutory provision can inform their meaning;[21]8 and we may also “construe statutes in connection and in harmony with the existing law, and as a part of a general and uniform system of jurisprudence.”[22]9 With these guiding principles in mind, I turn now to the text and context of the statute at issue. The Service Delivery Strategy Act seeks to “minimize inefficiencies resulting from duplication of services and competition between local governments[.]“1[23]0 And to accomplish this goal, the Act directs each county and its municipal governments to reach an agreement about the geographic areas in which each government will provide particular services, as well as the means by which to fund those services.1[24]1 More specifically, the Act requires the various governments in each county to agree upon a “local government service delivery strategy,” which includes (1) An identification of all local government services presently provided or primarily funded by each general purpose local government and each authority within the county, or providing services within the county, and a description of the geographic area in which the identified services are provided by each jurisdiction; (2) An assignment of which local government or authority, pursuant to the requirements of this article, will provide each service, the geographic areas of the county in which such services are to be provided, and a description of any services to be provided by any local government to any geographic area outside its geographical boundaries. In the event two or more local governments within the county are assigned responsibility for providing identical services within the same geographic area, the strategy shall include an explanation of such arrangement; (3) A description of the source of the funding for each service identified pursuant to paragraph (2) of this Code section; and (4) An identification of the mechanisms to be utilized to facilitate the implementation of the services and funding responsibilities identified pursuant to paragraphs (2) and (3) of this Code section.1[25]2 The Service Delivery Strategy Act, then, prescribes certain criteria that a service delivery strategy must satisfy, including that it must “promote the delivery of local government services in the most efficient, effective, and responsive manner.”1[26]3And with respect to “any service which a county provides primarily for the benefit of the unincorporated area of the county,”1[27]4 the strategy must ensure the service cost is “borne by the unincorporated area residents, individuals, and property owners who receive the service.”1[28]5 Here, the parties dispute whether the construction and maintenance of the Barrow County road system is a service that is “primarily for the benefit of the unincorporated area of the county” within the meaning of OCGA § 367024 (3) (A). The superior court concluded the construction and maintenance of Barrow County roads is not a service primarily for the benefit of the unincorporated area of the county, and the majority agrees with this interpretation of the statute. I do not.1[29]6 For starters, the “primary benefit” clause of OCGA § 367024 (3) (A) categorically requires a geographic inquiry, providing, inter alia, that “[t]he strategy shall ensure that the cost of any service which a county provides primarily for the benefit of the unincorporated area of the county shall be borne by the unincorporated area residents, individuals, and property owners who receive the service.”1[30]7 In its ordinary sense, “area” refers to geography, not people.1[31]8 Furthermore, a “benefit” may flow to a person, thing, activity, or place1[32]9—which is also true in Georgia law.2[33]0 OCGA § 36-70-24 (3) (A) also describes the subjects of the distinct determinations differently. Indeed, the initial determination references geography (“the unincorporated area of the county”), and the subsequent determination references people (“the unincorporated area residents, individuals, and property owners who receive the service”). This further highlights that the initial determination is distinctly geographic in nature.2[34]1 And for purposes of OCGA § 367024 (3) (A), the dispositive element is the geographic area a service benefits and not the place where the service is performed. To be sure, some government services are performed at centralized locations to benefit a wider area (e.g., courthouses, libraries, parks, recreation centers, art and science facilities, public hospitals); but other government services are distributed across wide areas (e.g., police and fire protection, garbage and solidwaste collection and disposal, stormwater and sewage collection and disposal, water distribution, construction and maintenance of public roads). Thus, the geographic area a service benefits is crucial to the assessment required under the statute. Additionally, the initial determination under OCGA § 367024 (3) (A) requires the identification of the geographic area that receives not just any benefit from a particular service but the primary benefit.2[35]2 In some sense, the entirety of a county—and for that matter, all of our state and country—benefits from well constructed and maintained public roads. But in a geographic sense (which is contemplated by the plain meaning of the statute), a road system primarily benefits the places to which it provides direct, immediate access.2[36]3 As a result, the construction and maintenance of a county road system that is entirely or predominantly within a county’s unincorporated—which appears to be undisputed in this case2[37]4—is a service primarily for the benefit of that unincorporated area.2[38]5 In reaching the opposite conclusion, the majority relies on DeKalb County v. City of Decatur,2[39]6 which predates both the Act and the Constitution of 1983. DeKalb County concerns the interpretation and application of a local constitutional amendment, which established special services tax districts in DeKalb County and directed the county to assess, levy, and collect taxes and fees in each district “in accordance with the kind, character, type and degree of district services provided by the county within such special services tax district.”2[40]7 This local amendment does not appear to have contemplated the area that particular services primarily benefitted, which is the very determination the Act plainly requires.2[41]8 Moreover, the local amendment at issue in DeKalb County did not strictly limit the funding of services provided primarily for the benefit of a particular special district to revenues raised within that district, unlike the Act before us.2[42]9 Accordingly, DeKalb County does not properly inform the meaning of OCGA § 36-70-24 (3) (A). For all these reasons, I would reverse the trial court’s grant of summary judgment on this issue. 2. I also disagree with the majority’s interpretation of “assessments” as used in OCGA § 367024 (3) (B), which provides that the funding of services provided by a county primarily for the benefit of the unincorporated area “shall be derived from special service districts created by the county in which property taxes, insurance premium taxes, assessments, or user fees are levied or imposed or through such other mechanism agreed upon by the affected parties.”3[43]0 The majority concludes that “assessments” means revenue measures of every kind, by which a county may then use any source of revenue to fund these services, so long as the revenue is collected from the unincorporated part of the county. Again, I disagree. Contrary to the majority’s conclusion, OCGA § 36-70-24 (3) (B) specifically identifies four particular revenue measures—i.e., ad valorem property taxes, insurance premium taxes, assessments, and user fees—that may be used to fund the relevant services. This list is exhaustive. “Property taxes,” “insurance premium taxes,” and “user fees” unambiguously refer to certain and specific revenue measures, and under the canon of noscitur a sociis, “assessments” must likewise refer to a particular revenue measure or a class of revenue measures.3[44]1 And when “assessment” is used in this way, it is most commonly understood to refer to a “special assessment.”3[45]2 Furthermore, if “assessments” were understood to mean revenue measures of any kind, the specific inclusion of other revenue measures in OCGA § 36-70-24 (3) (B)—i.e., property taxes, insurance premium taxes, and user fees—would be mere surplusage. And the subsequent reference to “such other mechanism agreed upon by the affected parties” would be entirely unnecessary if “assessments” meant any revenue measure. But it is well established that “courts must seek to avoid a construction that makes some language of a statute mere surplusage.”3[46]3 Suffice it to say, “assessments” is most reasonably understood to refer to “special assessments” in this statutory context, which is an understanding that properly attaches meaning to every word of this statutory provision.3[47]4 Accordingly, I would reverse the trial court’s grant of summary judgment on this question as well. 3. Finally, I disagree with the majority’s conclusion that the trial court properly denied the City’s motion to dismiss when, in its amended petition under the Act, the County sought a declaratory judgment that the City’s use of revenue earned from the sale of municipal water for general revenue purposes is an “illegal tax” collection. Setting aside the merits of this claim, the Act does not authorize such a declaratory judgment. The Service Delivery Strategy Act prescribes certain criteria that a service delivery strategy must satisfy, including that it must “promote the delivery of local government services in the most efficient, effective, and responsive manner.”3[48]5 And as to any water and sewer services provided by a county or municipality beyond its own boundaries, the strategy must ensure that “water or sewer fees charged to customers located outside the geographic boundaries of a service provider [are] not arbitrarily higher than the fees charged to customers receiving such service which are located within the geographic boundaries of the service provider.”3[49]6 The scope of judicial review under the Service Delivery Strategy Act, then, is limited, and under it, a superior court is not authorized to decide that municipal water charges constitute an “illegal tax” simply because the municipality uses those charges for general revenue purposes. Importantly, the Act limits relief to specific remedies.3[50]7 And as to judicial dispute resolution, under the Act, a superior court may “render a decision with regard to disputed items,” hold statutory sanctions in abeyance pending completion of the dispute resolution process, use “its contempt powers to obtain compliance with its decision relating to the disputed items,” and award costs against any party acting in bad faith.3[51]8 Thus, under the clear terms of the Act, a superior court’s power to resolve “disputed items” is limited to disputes concerning the criteria for a service delivery strategy that are delineated in OCGA § 367024.3[52]9 The Act does not permit a county to challenge a municipal water charge as an “illegal tax” because of how a municipality uses the revenues. Indeed, as explained by the City of Valdosta in its amicus brief, OCGA § 367024 (2) is “the only criterion that even pertains to municipal water charges, and it specifically authorizes a county only to seek judicial review of arbitrary rate discrimination between customers in the municipality and those outside the municipality.”4[53]0 As a result, even if the County can pursue declaratory relief in another proceeding, it is not entitled to do so in a proceeding under the Act. I disagree, then, with the majority and would reverse the trial court on this question as well. For all of these reasons, I respectfully dissent.
