HomeMy WebLinkAboutStaff Report 9352
City of Palo Alto (ID # 9352)
Policy and Services Committee Staff Report
Report Type: Action Items Meeting Date: 6/21/2018
City of Palo Alto Page 1
Summary Title: Status Update for Audit Recommendations for Accuracy of
Water Metering Billing Audit
Title: Staff Recommendation That the Policy and Services Committee
Recommend the City Council Accept the Status Update on the Accuracy of
Water Meter Billing Audit
From: City Manager
Lead Department: Utilities
Recommendation
Staff recommends the Policy and Services Committee recommend that the Council
accept the attached Status of Audit Recommendations for the Accuracy of Water Meter
Billing Audit.
Background
The City Auditor’s Office previously issued an audit with objectives to determine if the
water utility customers were accurately billed for the water meter type, size, and related
adjustments. This will be the first update since the audit was presented to Council on
August 22, 2017. (https://www.cityofpaloalto.org/civicax/filebank/documents/62279)
The Utilities and Administrative Services Department have completed four of the eleven
recommendations. The recommendations and actions taken for completion are listed in
the attached document (Attachment A).
Recommendation 1.3 is in progress. Staff expects to issue a request for proposal (RFP)
in August 2018 to conduct a field audit of the metered services in the City; this field
audit will capture all meter sizes, including the recommended 2” and above meters. Due
to staffing constraints, Utilities has not been able to conduct the water cost of service
study for finding 1.4 regarding fixed meter charges. Staff expects to issue a water cost
of service RFP by end of calendar year 2018. For recommendation 2.1, staff will review
and update existing policies and procedures to inform Council of significant
infrastructure changes. Two of the recommendations 2.2 and 2.3 are related to
electronic water meters. Utilities is awaiting an adoption of an American Water Works
Association (AWWA) standard for electronic meters. The public comment period on the
City of Palo Alto Page 2
proposed new standards closed on April 29, 2018. Final publication of the standard
may take several months. Staff will notify Council if Utilities adopts the new
electromagnetic and ultrasonic water meter standards. For recommendations 3.1 and
3.2 The Administrative Services Division is currently working on incorporating the
nuances of the Sole Source process into Purchasing’s Policy and Procedures. Training is
currently being conducted on an as-needed basis. Formal training will be conducted
once the Policy and Procedures have been updated.
Attachments:
Water Meter Billing_June 2018 Final 5-31-18
STATUS OF AUDIT RECOMMENDATIONS
ACCURACY OF UTILITY WATER METER BILLING AUDIT – ISSUED 8/16/17
6055039 PAGE 1
The City Manager has agreed to take the following actions in response to the audit recommendations in this report. The City Manager will report progress on
implementation six months after the Council accepts the audit report, and every six months thereafter until all recommendations have been implemented.
Recommendation
Responsible
Department(s) Original Target Date and Response Current Status
Implementation Update and
Expected Completion Date
Finding 1: CPAU has not adequately prevented, detected, nor corrected water meter billing errors.
We recommend that CPAU:
1.1. Correct the billing errors
identified.
Utilities Concurrence: Agree
Target Date: November 2017
Action Plan: Utilities staff is
confirming the specific addresses and
errors cited in the audit. Staff will
then take immediate actions to
rectify the overcharge situation by
contacting the customers and
updating their accounts with the
correct meter charge as well as
reconciling the incorrect charges for
the past three years. For the
undercharge or backbill scenario,
staff plans to recommend Council
approval to modify current meter
billing policy and eliminate mandated
customer backbilling for utility-
caused metering errors under certain
circumstances.
Completed June 2018 Management Update:
In August 2017, staff notified 258 customers by letter of the water
meter billing error.
125 customers were overcharged. Staff updated the customer
accounts with the correct meter charges. The customer accounts
were credited of the overcharged amounts.
133 customers were undercharged. Staff updated the customer
accounts with the correct meter charges. Council approved an
amendment to Utility Rule and Regulation 11 “Billings,
Adjustments, and Payments of Bills” which allows Utilities to waive
undercharges of up to $500 per incident, subject to the three year
retroactive billing adjustment period. The undercharges for the
133 customers were waived because the City was responsible for
the billing error.
Staff Report:
https://www.cityofpaloalto.org/civicax/filebank/documents/64141
Status: Completed
1.2. Investigate each of the 123
water meters that do not
match the meter purchasing
record, determine if a record
or billing correction is
required, and correct
accordingly.
Utilities Concurrence: Agree
Target Date: November, 2017
Action Plan: Staff has completed an
initial inspection of the 123 meters in
the field. Staff will need to conduct
further investigation on a few of the
accounts to confirm meter type, pipe
connection size, and dial register.
Thus far, staff has confirmed 84
Completed June 2018 Management Update:
All 123 meters were field inspected and customer accounts have
been adjusted accordingly.
There were 70 undercharges, 6 overcharges, and 47 non-billing
errors such as incorrect meter size description. The undercharges
and overcharges have been rectified under finding 1.1.
STATUS OF AUDIT RECOMMENDATIONS
ACCURACY OF UTILITY WATER METER BILLING AUDIT – ISSUED 8/16/17
6055039 PAGE 2
Recommendation
Responsible
Department(s) Original Target Date and Response Current Status
Implementation Update and
Expected Completion Date
water meters did not match the
meter or billing record. Staff will take
the necessary actions to rectify the
overcharges and undercharges.
Status: Completed
1.3. Review and correct the meter
record errors identified for
meter sizes larger than 2
inches.
Utilities Concurrence: Agree
Target Date: December 2018
Action Plan: In preparation for the
new CIS Utility billing system and
potential advanced meter
deployment, staff will consider an in-
house or contract service audit of the
three metered services (electric, gas,
water). Staff will also review and
update as needed roles and
responsibilities for key staff involved
in ensuring meter accuracy, including
procurement, inventory, testing,
installation, and billing records
management.
In progress June 2018 Management Update:
Staff will be issuing an RFP for contract services to conduct a field
audit of 74,000 meters. One of the requirements is verification of
service connection size for 2” or greater water meters.
Expected Completion Date: June 2019
1.4. Explore options for
addressing equity when
making changes to customer
meter size rates and establish
a policy and process for
determining, documenting,
and notifying customers of
changes to their meter size
and, if appropriate, the rate
change associated with the
new meter size.
Utilities Concurrence: Agree
Target Date: July 2018
Action Plan: The audit’s questioning
of utility practices regarding changes
to meter sizes is based on a unique
situation that occurred 22 years ago
and does not reflect current policy or
process. The situation arising out of
Southgate was a unique case and
staff does not agree that this or
other meter replacement practices
raise equity issues.
In Progress June 2018 Management Update:
Due to staffing changes, the Utilities Department was not able to
engage with a consultant to begin the water cost of service study
in FY 2018. Staff expects to issue an RFP in the first half of FY 2019.
Options to consolidate the fixed rates for 5/8” and 1” meters will
be considered. The study results and staff recommendation will be
brought forth for Council review when completed.
Expected Completion Date: April 2019
STATUS OF AUDIT RECOMMENDATIONS
ACCURACY OF UTILITY WATER METER BILLING AUDIT – ISSUED 8/16/17
6055039 PAGE 3
Recommendation
Responsible
Department(s) Original Target Date and Response Current Status
Implementation Update and
Expected Completion Date
With regard to differential rates for
different meter sizes, staff is
currently reviewing policy options for
addressing this issue going forward,
and will develop options such as
consolidating the fixed rate for 5/8”
and 1” meters for consideration by
the City Council.
STATUS OF AUDIT RECOMMENDATIONS
ACCURACY OF UTILITY WATER METER BILLING AUDIT – ISSUED 8/16/17
6055039 PAGE 4
Recommendation
Responsible
Department(s) Original Target Date and Response Current Status
Implementation Update and
Expected Completion Date
1.5. With the understanding that
CPAU will be migrating to a
new ERP system:
a. Implement a temporary
monitoring or reporting
system to identify record
discrepancies that may
result in billing errors and
correct as discrepancies
are identified.
b. Ensure the new ERP
system will have
automated controls in
place to prevent such
discrepancies and identify
them if they do occur.
Utilities Concurrence: Agree
Target Date: December 2019
Action Plan:
a. Staff has established a
monthly reconciliation
report to monitor and
identify inconsistent billing
and meter attributes which
will ensure comprehensive
detection of potential error
sources across inventory,
meter change activity, and
billing databases.
b. Elimination of redundant
manual entry has already
been identified as a system
requirement for the new CIS
system. Staff will monitor
the ongoing procurement
for a new customer
information system and
enterprise resource
planning system to ensure
system requirements
continue to prioritize
minimizing manual entry
through integration across
databases and automated
data entry.
Completed with
Alternate
Implementation
Plan
June 2018 Management Update:
a. Staff has been running a monthly reconciliation report
since August 2017 to monitor and identify inconsistent or
incorrect meter billing data. To date, staff has identified
five non-billing data discrepancies and one incorrect
billing type. Since these errors were corrected in a timely
manner, no billing adjustment was required.
Status: Completed
b. Elimination of redundant manual entry in SAP will require
a large customization effort which will be resource
intensive and costly.
Since the City is in the process of upgrading or replacing
the ERP and CIS systems, customization of the existing
system is not a good return on investment. Elimination of
redundant entries and reduction of manual entries are
key criteria in the ERP and CIS system evaluation process.
Expected Completion Date: February 2021
STATUS OF AUDIT RECOMMENDATIONS
ACCURACY OF UTILITY WATER METER BILLING AUDIT – ISSUED 8/16/17
6055039 PAGE 5
Recommendation
Responsible
Department(s) Original Target Date and Response Current Status
Implementation Update and
Expected Completion Date
Finding 2: CPAU has installed 1,178 water eMeters throughout the City’ however, there are no testing standards, and the accuracy, performance, and reliability of these
meters are uncertain.
We recommend that CPAU:
2.1. Develop a policy and
procedure to transparently
report significant, systemic,
infrastructure changes to
Council and update any CPAU
Rules and Regulations that
may be outdated to current
practice or affected by policy
changes.
Utilities Concurrence: Agree
Target Date: Immediately
Action Plan: Major infrastructure
changes are presented to Council for
approval. However, standards are
technical documents that provide
the general conditions and
specifications for the construction of
the Water Gas and Wastewater
System. Updates to standards are
subject to multiple levels of
professional review including
engineering, procurement and legal.
Updated standards will be
communicated to Council as
informational when substantive.
In Progress June 2018 Management Update:
The Utilities Department will inform Council when technical
standards are substantive. Since August 2017, the department has
not updated the technical standards for electric, gas or water.
American Water Works Association (AWWA) has drafted new
standards for electromagnetic and ultrasonic type water meters.
The public comment period on the proposed new standards closed
on April 29, 2018. Final publication of the standard may take
several months. Staff will notify Council if Utilities adopts the new
electromagnetic and ultrasonic water meter standards.
Staff will review and update existing policies and procedures if
applicable.
Expected Completion Date: June 2019
2.2. Seek direction and approval
from Council before
proceeding further with the
future installation of eMeters
or any electronic meters.
Utilities Concurrence: Agree
Target Date: Ongoing
Action Plan: Procurement and
installation of e-meters will remain
suspended until adoption of an
AWWA standard for testing and the
availability of independent test
resources (either in-house or
contracted). It is expected that a
final standard for testing of E-meters
will be available at the end of 2017.
The new standards are not expected
to change the accuracy requirements
In Progress June 2018 Management Update:
American Water Works Association (AWWA) has drafted new
standards for electromagnetic and ultrasonic type water meters.
The public comment period on the proposed new standards closed
on April 29, 2018. Final publication of the standard may take
several months. Staff will notify Council if Utilities adopts the new
electromagnetic and ultrasonic water meter standards or seeks to
install additional eMeters.
Expected Completion Date: June 2019
STATUS OF AUDIT RECOMMENDATIONS
ACCURACY OF UTILITY WATER METER BILLING AUDIT – ISSUED 8/16/17
6055039 PAGE 6
Recommendation
Responsible
Department(s) Original Target Date and Response Current Status
Implementation Update and
Expected Completion Date
from those expected of the positive
displacement meter with the
exception that there will likely be an
extended range of accuracy for low
flows. It should be noted the E-
Meters is a specific product line, and
mechanical meters may also have
electronic components.
2.3. Determine if the 1,178
installed eMeters should be
uninstalled and replaced with
the original displacement
meter and if billing
adjustments are required.
Utilities Concurrence: Agree
Target Date: July 2018
Action Plan: All customers with e-
meters installed will be immediately
notified of this audit, and that
additional information will be
provided as available. For eMeter
testing, staff will send a sampling of
eMeters to independent testing
companies to determine if they are
performing per manufacturer
specification, and based on these
results will determine next steps. In
addition, the Water Meter Shop has
staffing challenges and does not
currently have the resources
required to undertake this
replacement project. At this time,
staff will continue to monitor the
meter reads for irregularities of both
the installed positive displacement
and eMeters as part of the billing
exception process. Staff is also
developing a customer plan for
addressing any accuracy concerns
with the e-meters already installed.
In Progress June 2018 Management Update:
The Utilities department sent letters to the 1,178 residents with
installed eMeters. In response, 55 customers requested their
meters to be exchanged. A couple credit adjustments were
required for the eMeter exchanges. As of June 2018, the City has
1,122 eMeters installed.
Status: Completed
Staff hired a contractor to test a sampling of eMeters. The
contractor tested the eMeters under four different scenarios.
Overall, the testing results measured correctly within the
manufacturer’s specifications and guidelines of +/- 1.5%.
After AWWA publishes the final standards for electromagnetic and
ultrasonic type meters, staff will meet with other water agencies
to determine the pros and cons of these meters. Staff will make a
determination in 2019 on whether to standardize displacement
and/or ultrasonic type meters.
Expected Completion Date: June 2019
STATUS OF AUDIT RECOMMENDATIONS
ACCURACY OF UTILITY WATER METER BILLING AUDIT – ISSUED 8/16/17
6055039 PAGE 7
Recommendation
Responsible
Department(s) Original Target Date and Response Current Status
Implementation Update and
Expected Completion Date
Finding 3: Purchase of water eMeters did not meet purchasing policy and eMeter expenditures were not monitored.
We recommend that ASD Purchasing Division:
3.1. ASD Purchasing to clarify its
purchasing policy and
procedures for new and
renewals of product
standardization.
ASD Concurrence: Agree
Target Date: December 2017
Action Plan: Staff will update the
policy and coordinate with
stakeholders to ensure the policy is
clear and easy to follow. Staff will
then finalize the policy and
disseminate to departments.
In Progress June 2018 Management Update:
This is in the queue for development to update Purchasing’s Policy
and Procedures. Purchasing has the “Solicitation Plan Checklist”
already and the nuances of the process are currently being
written. The current Exemption Form addresses the
“Standardization” process in the P&P. The “How To” and step-by-
step self-learning tool regarding standardization are in
development.
Expected Completion Date: Q4 of FY18
3.2. ASD Purchasing to retrain
appropriate ASD and CPAU
staff on Purchasing policies
and procedures, and
completion of required forms.
ASD Concurrence: Agree
Target Date: January 2018
Action Plan: In conjunction with 3.1
staff will provide training.
In Progress June 2018 Management Update:
Training is being done on an as needed basis. Purchasing will
conduct formal training once item 3.1 is complete.
Expected Completion Date: Q2 of FY19
3.3. ASD Purchasing to determine
roles and responsibilities and
develop a procedure for
tracking Sole Source
purchases to prevent the
overspending of approved
amounts.
ASD Concurrence: Agree
Target Date: March 2018
Action Plan: The SAP system does
not currently provide an automated
check on sole source spending. Staff
will evaluate whether the system can
be configured to allow for this. If
not, staff will implement manual
procedures to track sole source
spending.
Complete with
Alternative
Implementation
June 2018 Management Update:
Purchasing staff is tracking through a manual spreadsheet-type
process, which is complete. The department is in development on
how to track sole source purchases and spend within the current
ERP system (SAP), if possible, and in the future replacement RFP.
Expected Completion Date: Manual tracking is complete.
Automation tracking is expected to be complete in 2021 as part of
the new ERP.