Seattle City Light Customer Care

and Billing Audit

Jane A. Dunkel

David G. Jones, City Auditor

Seattle Office of City Auditor

April 3, 2020

Seattle City Light Customer

Care and Billing Audit

Report Highlights

Background

Seattle City Light (City Light), the City of Seattle's public electric utility,

serves about 461,500 customers in Seattle and surrounding

communities. In September 2016, City Light implemented a new billing

system, the Customer Care and Billing System (CCB) and in October

2016 began installing advanced meters. These two factors resulted in

many City Light customers receiving unexpected high bills due to

delayed and estimated bills. In response to numerous concerns from

City Light customers about alleged over-billing, Seattle City

Councilmember Teresa Mosqueda asked our office to review City

Light's billing and customer service practices.

What We Found

We found that City Light's implementation of a new billing system and

advanced meters resulted in customers receiving an increased number of

unexpected high bills due to estimated and delayed bills. City Light has

taken steps to reduce unexpected high bills but could further reduce

them by changing two key system parameters. City Light's dispute

resolution process can involve multiple hand-offs to resolve customer

complaints and lacks controls to ensure customers are informed that their

issue has been resolved. City Light also limits who can authorize payment

arrangements.

Recommendations

Our report contains 16 recommendations that address ways City Light

could decrease the number of unexpected high bills received by

customers, improve handling of customer complaints, make greater use

of technology to help customers manage their payments and energy use,

apply lessons learned from City Light's temporarily expanded escalation

team, and make it easier for customers to set up payment arrangements.

Department Response

In their formal, written response to our report City Light stated that

they generally concurred with the report findings. Appendix A contains

City Light's and Seattle Public Utilities' written responses to our

findings and recommendations.

WHY WE DID THIS

AUDIT

We conducted this audit in

response to Seattle City

Councilmember

Mosqueda's request to

review Seattle City Light's

billing and customer

services practices. We were

asked to examine how City

Light:

? Prevents erroneous

and/or unexpected high

bills

? Communicates with

customers about

unexpected high bills

? Resolves customer

complaints and appeals

? Provides payment

options, and

? Reimburses customers

who have been

overcharged.

HOW WE DID THIS

AUDIT

To accomplish the audit's

objectives, we:

? Analyzed City Light data

? Interviewed City Light

managers and staff

? Researched promising

practices

? Surveyed other utilities

? Conducted case studies

Seattle Office of City

Auditor

David G. Jones, City Auditor

www.seattle.gov/cityauditor

Seattle City Light Customer Care and Billing Audit

TABLE OF CONTENTS

INTRODUCTION .................................................................................................................................... 1

A NEW BILLING SYSTEM AND ADVANCED METERS CREATED BILLING ISSUES ................................. 2

CITY LIGHT COULD REDUCE THE NUMBER OF UNEXPECTED HIGH BILLS........................................ 11

ADVANCED METERS PROVIDE TOOLS TO ENHANCE CUSTOMER COMMUNICATION ..................... 16

CITY LIGHT'S ESCALATION TEAM COULD BE A MODEL FOR HANDLING COMPLAINTS.................. 19

CITY LIGHT COULD DO MORE TO HELP CUSTOMERS MANAGE PAYMENTS AND ENERGY USE ..... 23

OBJECTIVES, SCOPE, AND METHODOLOGY ....................................................................................... 27

APPENDIX A ........................................................................................................................................ 29

Departments' Responses ................................................................................................................................................ 29

APPENDIX B ........................................................................................................................................ 38

List of Recommendations ............................................................................................................................................... 38

APPENDIX C ........................................................................................................................................ 39

City Council Request Letter............................................................................................................................................ 39

APPENDIX D ....................................................................................................................................... 42

Template of Letter Sent to Customers ........................................................................................................................ 42

APPENDIX E ........................................................................................................................................ 43

City Light's Dispute Resolution Process ..................................................................................................................... 43

APPENDIX F ........................................................................................................................................ 44

Description of Payment Assistance Options ............................................................................................................. 44

APPENDIX G ........................................................................................................................................ 46

Most Refunds are Handled as Credits ........................................................................................................................ 46

APPENDIX H ....................................................................................................................................... 47

Who Was Affected by Consecutively Estimated Bills? ............................................................................................ 47

APPENDIX I ......................................................................................................................................... 49

Seattle Office of City Auditor Mission, Background, and Quality Assurance ................................................... 49

Seattle City Light Customer Care and Billing Audit

Page 1

INTRODUCTION

Audit Overview

In response to numerous concerns from Seattle City Light (City Light)

customers about alleged over-billing, City Councilmember Teresa

Mosqueda asked our office to perform an audit that addressed,

among other things, how City Light:

? Prevents erroneous and/or unexpected high bills,

? Communicates with customers about unexpected high bills,

? Resolves customer complaints and appeals,

? Provides payment options, and

? Reimburses customers who have been overcharged.

See Appendix C for a copy of the request letter.

In addition to answering Councilmember Mosqueda's questions, we

also analyzed data to assess if there was evidence of geographic or

income inequity in who receives consecutively estimated, and

therefore unexpected high catch-up, bills. Our analysis of this issue is

in Appendix H.

Acknowledgements

The Office of City Auditor would like to thank the utilities who

participated in our survey of payment arrangements. These include

Austin Energy, Avista Energy, BC Hydro, Burbank Water and Power,

Clark Public Utilities, Glendale Water and Power, Idaho Power, Los

Angeles Department of Water and Power, Portland General Electric,

Puget Sound Energy, Salt River Project Power and Water, and

Tacoma Power. We also thank the American Public Power Association

for sharing its training materials with us. Finally, we extend our

appreciation to the many Seattle City Light and Seattle Public

Utilities managers and staff who explained their processes and

procedures, provided us with information and data, and

demonstrated how they do their work.

Seattle City Light Customer Care and Billing Audit

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A NEW BILLING SYSTEM AND

ADVANCED METERS CREATED

BILLING ISSUES

Section Summary In September 2016, Seattle City Light (City Light), Seattle Public

Utilities (SPU), and the Seattle Information Technology Department

(Seattle IT) replaced the utilities' customer billing system.1 In October

2016 City Light began installing advanced meters on new residential

and small commercial construction projects. In July 2017 City Light

began exchanging manual meters for advanced meters for existing

accounts. The overlapping effect of these two occurrencesa new

customer billing system and the installation of advanced meters

resulted in City Light customers receiving more unexpected high

bills. Customer frustration with unexpected high bills increased the

volume of calls to the utility's customer service center, resulting in

long wait times for customers. Additionally, City Light's lack of

confidence in the accuracy of their bills affected their ability to

proceed with normal collection processes, creating large accounts

receivable balances.

How are manual

meters different from

advanced meters?

City Light began implementing advanced meters in October 2016.

City Light did this because advanced meters offer many benefits

compared to manual meters. Exhibit 1 outlines some of the main

differences between manual and advanced meters.

1 The Consolidated Customer Service System (CCSS) was replaced with the Customer Care and Billing system (CCB).

Seattle City Light Customer Care and Billing Audit

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Exhibit 1: With Advanced Meters, City Light Can Remotely

Read and Monitor Electricity Use

Source: Seattle Office of City Auditor analysis of Seattle City Light information.

A new billing system

and advanced meters

created billing issues

We found that City Light's implementation of a new Customer Care and

Billing system (CCB) and advanced meters put pressure on their

customer care operations and created billing issues that are depicted in

Exhibit 2. First, some staff were still working through a backlog from the

old billing system when the new system went live. Second, some tasks in

the new system took more steps to complete than in the old system.

Third, some tasks took longer in the new system because staff were still

learning how to use it. Finally, fewer staff were available to read meters

to confirm actual electricity use. These factors resulted in more

estimated and delayed bills, which resulted in more calls from

customers with inquiries about their bills, which resulted in more tasks

assigned to staff, which resulted in continued and increasing backlogs

of bills to review, which resulted in more calls from customers.2

2 City Light officials told us that there were two additional factors that may have also contributed to the increased

number of estimated bills during CCB and advanced meter implementation: 1) differences in address syntax (Northwest

versus NW) in the customer billing system that prevent the system from matching a meter to a customer account, and 2)

time lags between when an advanced meter was installed and when the paperwork on the associated account was

processed.

Seattle City Light Customer Care and Billing Audit

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Exhibit 2: Implementation of a New Billing System and Advanced Meters Created Billing

Issues

Source: Seattle Office of City Auditor

How do customers

know if their bill is

based on an estimate

or not?

City Light customers can see if their bill is based on an estimate by

looking at the "detailed billing information" section of their statement.

As shown in Exhibit 3, an asterisk indicates that the electricity usage is

an estimate, and that the bill is not based on actual use.

Seattle City Light Customer Care and Billing Audit

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Exhibit 3: City Light Bills Indicate Whether or Not the Bill is Based on an Estimate

Source: Seattle Office of City Auditor

Why do estimated bills

result in unexpected

high bills?

We found that customers received unexpected high bills partially

because of City Light's new Meter Data Management (MDM) system,

which manages meter data. When City Light implemented MDM, City

Light set limits within MDM on the number of bills that could be

based on estimated meter reads. This limit meant that the following

bill had to be based on an actual meter read. If the multiple

estimated meter reads upon which the previous bills had been based

were consistently lower than actual use, the eventual catch-up bill

(based on an actual meter read), would result in a higher bill.

City Light officials told us that MDM estimates bills using

consumption data from the same meter for the same month from the

Seattle City Light Customer Care and Billing Audit

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previous year. There are many reasons why this historic consumption

may be lower than current consumption, including, among others:

1. The customer may be using more energy than they did in the

same period last year, due to more severe weather or other

factors,

2. The previous year's data may be based on a resident or

tenant who no longer resides at that address, or

3. There may be no usage data for the same month the previous

year, in which case the estimation is based on the last bill

period on the account, which may have been a lower use time

of year.

City Light officials told us that their old customer billing system did

not have a check on the number of estimated bills that could be

produced. As a result, one could have an infinite number of

estimates, which could lead to high dollar catch-up bills. Under the

new systems, Customer Care and Billing (CCB) and Meter Data

Management (MDM), the initial limit was set at three consecutive

estimated bills. Any bills over this number were screened by the

system and sent to City Light employees to review. These employees

then had to request actual meter reads so they could recalculate the

bill based on an actual read. A City Light manager told us that until

the new CCB system was implemented, City Light did not realize how

many customers' bills were based on estimated meter reads.

In August 2017, to reduce backlogs, City Light raised the allowable

number of consecutive estimated bills to 12. This meant that a

customer could go two years without having a bill based on an actual

meter read. As shown in Exhibit 4, the number of consecutively

estimated bills increased by 170 percent in 2017.

Additionally, City Light officials told us that in anticipation of

advanced meter implementation, the City Light staff who checked

meter reads on site were transitioning to new jobs. This may also

have contributed to the increase in estimated meter reads, as there

were fewer staff available to read meters.

Seattle City Light Customer Care and Billing Audit

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Exhibit 4: City Light Residential Customers with Two or More

Consecutive Estimated Bills

Source: Seattle Office of City Auditor analysis of Seattle City Light data.

Processing backlogs

also contributed to

unexpected high bills

We found that backlogs in processing new accounts and meter sets3

and validating meter reads created billing delays. For some

customers, this resulted in higher than normal bills because the bills

covered more than one billing period. For other customers, this

increased the number of estimated bills they received, which as

mentioned earlier, could result in large catch up bills.

A City Light manager told us that when the new CCB system went

live in September 2016, City Light had 4,368 service orders for new

accounts that needed to be processed. Consequently, staff had to

complete this backlog of 4,368 service orders before they could start

on incoming service orders. Even after finishing this work, the

backlog continued to accumulate because it was taking staff longer

to complete tasks in CCB. First, staff were still learning the system,

and second, the new system requires more steps to complete a task.

Additionally, CCB implementation occurred during late summer and

early fall, the highest demand seasons of the year for processing

moves.

Also, when the new billing system was implemented in 2016, it

reduced the amount of time staff had to validate meter reads. Before

2016, staff had seven days to validate the meter reads. After the new

CCB system went into effect, staff had three days to validate meter

3 New accounts and meter sets is the City Light workgroup responsible for processing residential electric service

applications (applications for new service), move adjustments, landlord owner agreements, and online account closures

and transfers. Throughout this report, we refer to this work as new accounts and moves.

-

10,000

20,000

30,000

40,000

50,000

60,000

2012 2013 2014 2015 2016 2017 2018

Limit set at 3

Limit increased to 12

Seattle City Light Customer Care and Billing Audit

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reads. Although this was an ambitious goal, in practice it meant that

initially many meter reads were not validated within the three-day

window. When the three-day window was missed, the software

program defaulted to sending the customer an estimated bill. If the

account was over the limit for the number of consecutively estimated

bills (three) the bill would be delayed (i.e., not sent to the customer)

until staff could review it.

City Light officials told us that backlogs of bill processing increased

dramatically in 2017 due to their inability to obtain adequate staffing

resources. According to these officials, delays in the hiring process

and limits on the use of temporary staff meant that the volume of

work far exceeded the workforce capacity.

City Light officials told us that, in the first quarter of 2018, they made

a concerted effort to reduce the backlogs and that by March 2018,

they had significantly reduced the number of pending moves outside

their fourteen-day processing target.

Customer calls about

high bills and new

accounts spiked in

2018

As shown in Exhibit 5, customer calls about City Light billing issues

increased by 33 percent from 2016 to 2018. During this same period,

the number of customer calls about new accounts and moves

increased by 57 percent. As a result, customers had to wait longer for

their calls to be answered and staff fell behind on reviewing accounts

and resolving issues.

Exhibit 5: Customer Contact Center4 Calls Related to High Bills

and Moves

Source: Seattle Office of City Auditor analysis of Seattle Public Utilities data.

4 Customer calls about City Light accounts are handled by Seattle Public Utilities' (SPU's) Customer Service Center. This

center is often referred to as "the Contact Center." SPU manages and staffs the Contact Center, which also handles calls

related to their services (water, drainage and sewer, garbage, recycling, and food and yard waste).

-

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

2014 2015 2016 2017 2018 2019

High Consumption/Bill SCL Moves SCL Total

Seattle City Light Customer Care and Billing Audit

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To avoid shutting off

power to the wrong

customer, City Light

suspended collections

processes

City Light took steps to protect customers from unwarranted power

shut offs, but this had reputational and financial consequences for

the City. City Light's official collections policy directs staff to initiate

the electricity shut off process for accounts that are 31 or more days

past due and have balances equal to or greater than $300. However,

in September 2016, due to concerns about shutting off power to the

wrong customer, City Light halted its shutoff process for past due

accounts. These concerns arose from the fact that City Light had

backlogs in transferring accounts to new tenants, which meant they

could have turned off the current tenant's power when it was the

prior tenant who had not paid their bill.

In addition to halting shut offs, at CCB implementation, all past due

City Light customers were given a fresh start. That is, their accounts

were reset and not considered delinquent. Stopping shut offs and

resetting accounts meant that customers were not being penalized

for late payments, which likely contributed to an increase in unpaid

accounts.

In January 2017, to avoid accumulating a large balance of unpaid

accounts, City Light resumed seeking payments during its collections

process but stopped short of turning off power for customers who

did not make such payments. As part of this process, City Light sent

urgent and shutoff notices to customers who were behind on their

payments. However, City Light officials told us that they did not

follow through and shut off power on past due accounts because

they were still not confident that the bills were accurate. To avoid

confusing customers by telling them that power would be shut off

but not following through, in January 2018 City Light stopped

sending urgent and shut off notices.

Then, in November 2018, again to avoid accumulating a large

balance of unpaid accounts, City Light resumed sending urgent and

shutoff notices for past due accounts. However, as of January 2020,

City Light had not resumed shut offs for past due accounts.

While these policy changes protected customers, they have also had

negative consequences to:

1. City Light's reputation. By sending customers urgent and shut

off notices and not following through on them, City Light

risks both alarming customers unnecessarily and damaging

their credibility.

2. City Light's financial condition. City Light's year-end accounts

receivable balance rose from around $45 million in 2015 to

Seattle City Light Customer Care and Billing Audit

Page 10

around $82 million in 2018, an increase of 82 percent.5 Some

of this increase is likely due to changes City Light made in its

collections and shut off policies from 2016 through 2019.

City Light has reduced

estimated bills and

backlogs in processing

new accounts and

moves but could do

more to prevent

unexpected high bills

As shown in Exhibit 4, page 7, we found that customers receiving two

or more consecutive estimated bills decreased in 2018 compared to

2017. City Light officials also told us that they reduced backlogs in

processing new accounts and moves in the first quarter of 2018. Both

these changes should result in fewer estimated and delayed bills, and

fewer customers receiving unexpected high bills. As of January 6,

2020, City Light provided us with data showing that backlogs in

requests to process new customer move had been resolved. As of

January 2020, City Light staff were working to resolve 264 pending

requests in four other areas related to customer moves.

To build on lessons learned from City Light's experience with large

number of unexpected high customer bills, in the next four sections

of this report we discuss steps City Light could take to further reduce

the number of unexpected high bills customers receive, avoid

backlogs in functions that result in delayed bills, provide customers

with additional information that could help them manage their

electric bills, and make it easier for customers to resolve billing

problems and set up payment arrangements that meet their needs.

5 To address this increase, City Light increased its bad debt allowance from $2.8 million in 2015 to $20.8 million in 2018.

Seattle City Light Customer Care and Billing Audit

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CITY LIGHT COULD REDUCE THE

NUMBER OF UNEXPECTED HIGH BILLS

Section Summary We found that City Light relies primarily on automated software

screens in their Customer Care and Billing (CCB) and Meter Data

Management (MDM) systems to prevent erroneous or unexpected

high bills. Two of these key screens, 1) the limits on the number of

consecutive estimated bills and 2) the high bill variance, could be

reset to help prevent customers from receiving unexpected high bills.

Additionally, to prevent delayed, and therefore unexpected high bills,

City Light should continue to monitor the backlogs in new accounts

and moves and eliminate the backlog in processing returned mail.

City Light may still

need to estimate some

bills

Although the deployment of advanced meters will help reduce

unexpected high bills, City Light will still need to use estimates for

some customers. For example, 1,498 customers chose not to receive

advanced meters. Additionally, at any given time, some advanced

meters may be broken or unable to connect to the wireless network

needed to transmit meter data to City Light. A City Light official told

us that as of December 2019, there were still up to 24,000 meters

that will need to be read manually and could result in estimated bills.

This means that even with the widespread deployment of advanced

meters, City Light will still need to carefully consider the processing

of, and controls over, estimated bills.

City Light relies on

system screens to help

prevent unexpected

high bills

One of the benefits of MDM and CCB is that City Light has

programmed them to use automated screens and validation checks

to prevent erroneous or unexpected high bills. MDM, the program

that manages meter data, has limits on the number of consecutively

estimated bills, and flags high and low consumption levels. It also

notifies City Light if an account shows a negative energy

consumption or if there is no active account tied to the meter. CCB,

the program that manages billing, has a dollar threshold, and flags

bills for which the customer requested no estimates, or there is no

valid usage start date. Exhibit 6 illustrates the processes these

systems use to screen bills.

Seattle City Light Customer Care and Billing Audit

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Exhibit 6: Automated Software Checks Help Prevent Erroneous City Light Bills

Source: Seattle Office of City Auditor

Seattle City Light Customer Care and Billing Audit

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City Light's system

allows two years of

bills to be based on

estimated meter reads

As described earlier in this report, when CCB was first implemented

in September 2016, City Light set a limit such that a customer could

only receive three consecutive estimated bills. In August 2017, City

Light raised the allowable number of consecutive estimated bills to

12. City Light told us that they increased the allowable number of

consecutive estimated bills for two reasons. First, to reduce backlogs

in processing customer bills. Second, to prevent more delayed bills.

Since residential customers are billed every other month, allowing up

to 12 consecutive estimated bills means that a customer could

receive up to two years of bills based on estimated meter reads.

Because a customer's use of electricity can change over time, and

estimated bills are based on historic usage, this could mean that the

customer receives a very high bill when the account is finally

adjusted to reflect actual usage.

Now that advanced meter implementation is almost complete, and

there has been time for staff to learn the CCB system, City Light

should be able to allow fewer consecutive estimated bills without

causing a backlog. Reducing the number of consecutive estimated

bills also reduces the number of catch up bills and may reduce

customer complaints about high unexpected bills.

Recommendation 1 City Light should lower the current number of 12 consecutive

estimated bills allowed in their Meter Data Management system.

City Light's system

only catches bills with

large changes in the

customer's energy use

MDM has the capability of flagging bills with abnormally high

consumption that would trigger a review by City Light staff. However,

the current parameters in MDM for abnormally high consumption

rate are set so high that they may miss significant increases in energy

use. This is important because a spike in energy use could result in

an unexpected high bill, or also mean that the customer has an

electrical issue such as inadequately insulated walls or old,

inefficient appliances that results in wasted energy.

City Light staff only review excessive energy use that exceeds 600

percent of the previous meter read. This means that someone whose

average usage was 4,500-kilowatt hours per billing period could

receive a bill based on 26,955 kilowatt hours without the system

catching it. At November 2019 rates, this means their current bill

could be up to $2,000 more than their previous bill. A City Light

official told us that the high consumption limit was set during the

new CCB development process and was reviewed and approved by

the City's information technology consultant on the project and a

second consulting firm.

Seattle City Light Customer Care and Billing Audit

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Recommendation 2 City Light should lower the current high consumption variance

allowed in their Meter Data Management system.

City Light has reduced

backlogs in processing

new accounts and

moves, but needs to

plan for times of high

demand

We found that City Light has taken steps to address backlogs in new

accounts and moves. For example, as of January 2, 2018, City Light

had 74,157 tasks related to refunds, move, or billing corrections and

adjustments in their backlog. Each one of these 74,157 tasks is an

account that needs to be reviewed by City Light staff. To reduce this

backlog, in the first quarter of 2018, City Light used employees from

other units to process new accounts and moves. City Light officials

told us that many of these employees voluntarily worked overtime

during this periodsome as much as 12 to 14 hours per dayseven

days a week, including weekends and holidays.

To reduce backlogs, City Light managers also made other changes,

including:

1. Cross-training employees so employees could be shifted

between groups based on workload demands,

2. Placing whiteboards near each work group to help them track

their workload and backlogs, and

3. Holding weekly meetings with each workgroup to review

progress and reassign staff among workgroups as needed.

Additionally, City Light recently modified CCB and MDM to make

processing new accounts and moves more efficient. For example,

when closing an account, staff no longer manually search for the

ending meter read in MDM and enter it into the customer's account

in CCB. Instead, this is done automatically by the systems. Another

change is that CCB will now automatically apply set up charges for

new accounts rather than having staff do this. Other system changes

added internal checks to ensure that work on the account is properly

documented and that all active meters are tied to an account.

Finally, City Light managers told us they created a task force to

explore opportunities to streamline the flow of tasks involved in

billing customers. This could result in further efficiencies that benefit

customers by expediting the bill process and helping to ensure

accurate bills.

Despite these improvements, City Light employees told us that there

are regular cycles in workload demand for processing new accounts

that result in backlogs. Specifically, they told us that April, June

through September and December through January are high demand

times. When fluctuations in demand can be anticipated, an

Seattle City Light Customer Care and Billing Audit

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organization could use a staffing plan to meet that demand. In the

absence of a plan, City Light appears unprepared for these increases

in workload, which results in adding to backlogs and increasing the

number of customer billing issues. As described earlier in this report,

the adverse impacts of large backlogs have included unexpected

high bills and dissatisfied customers.

Recommendation 3 City Light should track seasonal variations in the workload

related to processing new accounts and moves.

Recommendation 4 City Light should develop an annual staffing plan to

accommodate fluctuations in demand for processing new

accounts and moves.

Backlogs in returned

mail contribute to

billing delays

Backlogs in processing returned mail also contribute to billing delays

and unexpected high bills. A City Light official told us that there is a

large backlog in bills that were returned in the mail. Currently, City

Light Credit and Collections staff are responsible for following up on

these accounts, which are handled as a separate body of work and

are not integrated into the CCB system. The work is very timeconsuming

because it can require researching the account and

making multiple attempts to contact each customer to determine the

correct account holder and mailing address.

As of April 2019, City Light officials estimated that there were

approximately 8,700 pieces of returned mail waiting to be reviewed.

Because City Light cannot bill for these accounts until the correct

account holder's address is identified, this backlog contributes to

billing delays, potentially high catch-up bills, and past due accounts

that increase City Light's accounts receivables.

Recommendation 5 City Light should develop a system for managing returned mail

and explore how this body of work could be handled in the

Customer Care and Billing system.

Seattle City Light Customer Care and Billing Audit

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ADVANCED METERS PROVIDE TOOLS

TO ENHANCE CUSTOMER

COMMUNICATION

Section Summary We found that City Light's current communication strategies related

to informing customers about unexpected high bills are primarily

reactive and were not designed to address the volume of complaints

experienced during the implementation of a new customer care and

billing system and the installation of advanced meters. Additionally,

although in August 2018 City Light made an extra effort to inform

customers about unexpected high bills, because City Light does not

conduct regular customer satisfaction surveys, they had no way to

know how successful these efforts were in reducing customer

frustration. Based on our research of promising practices in other

utilities, City Light could make better use of technology to help

customers manage their energy use and avoid surprises by alerting

them to potentially high bills.

City Light uses

multiple channels to

provide customers

with information

City Light uses multiple channels to provide customers with

information. For example, City Light produces a bimonthly customer

newsletter, has a website, and uses social media such as Facebook,

Twitter, and Instagram to communicate with customers. City Light

will be implementing an upgrade to their outage management

system to give customers real time information on outages via text,

email and robocalls.

City Light managers told us that they are planning additional

communication improvements in 2020. These are summarized in

Exhibit 7.

Exhibit 7: Planned Customer Communication Improvements

Improvement Estimated

Completion Date

New public facing website

December 2020

New customer web portal

December 2020

Automated email marketing platform to

focus communications by customer

characteristics

March 2020

Bill redesign

2022 after other

upgrades completed

Source: Seattle City Light's Director of Communications

Seattle City Light Customer Care and Billing Audit

Page 17

City Light does not

know if their efforts to

alert customers to high

bills was effective

City Light's Directors of Customer Care and Customer Operations

may authorize individualized customer communication on an asneeded

basis. For example, starting in August 2018, City Light's

Director of Customer Care required all billing adjustments involving

two or more billing periods to be accompanied by one of two letters.

Each of these letters stated: "we regret to inform you that your bill

may be larger than expected." The letters varied based on the reason

for the unexpected high bill. Both letters apologize for the

inconvenience and offer the customer options to extend the payment

deadline or make payment arrangements. See Appendix D for a copy

of one of these letters. Although these letters may have reduced

frustration for some customers, because City Light does not conduct

regular customer satisfaction surveys, its management can't tell if

these efforts are making a difference on customer attitudes about

City Light.

Recommendation 6 To understand the impact changes in its policies and procedures

are having on customer satisfaction, City Light should conduct

regular customer satisfaction surveys.

City Light could use

new technologies to

give customers timely

data about bills

With advanced meters, City Light could communicate even more

proactively with customers. Other utilities use promising proactive

customer communication practices. Based on our research of

practices in other utilities, we found two main areas where City Light

could enhance customer communication through greater use of

technology. This communication could help customers better

understand and manage their energy use, reduce their surprise when

they receive a high bill, and increase customer satisfaction.

First, City Light could provide customers with tools that alert them

about potentially high bills and help them manage their energy use.

Second, City Light could expand its use of social media, text, email,

and smart phone applications to prepare customers for what's

coming during periods of exceptionally hot or cold weather.

For example, some utilities send alerts via email, text or phone to let

customers know how they are doing against their monthly energy

spending goal, including alerting them when their usage is higher

than normal. Others have a secure online web portal where

customers can access historical billing, payment, and electric usage

data, including bill-to-date, projected next bill, budget assistance

(including the ability to create a custom savings plan), and energy

use by category (e.g., heating, lighting). The portal is translated into

multiple languages, so it is accessible to as many populations as

possible.

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Still other utilities provide a High Energy Alert service to residential

and business customers with 13 or more months of customer history.

Alerts are sent if a customer is trending toward increased energy use

30 percent or more over that of same period during the previous

year. Additionally, these alerts can be customized. For example, they

can be sent by email instead of text.

Recommendation 7 City Light should enhance its use of new technologies to

proactively provide customers with data about their accounts.

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CITY LIGHT'S ESCALATION TEAM

COULD BE A MODEL FOR HANDLING

COMPLAINTS

Section Summary

We found that City Light uses both formal and informal processes to

respond to customer complaints. These processes may require

multiple steps and do not ensure customers are informed about how

their complaint was resolved. Our case studies revealed instances

when City Light customers were not satisfied with the way their

complaints were handled or resolved.

To improve customer service, in October 2019, City Light temporarily

expanded their escalation team to include a supervisor and three

additional customer service representatives. City Light plans to

further increase staff so that there are eight customer service

representatives on the team. We found that the description of the

duties these team members perform incorporates leading practices

and addresses weaknesses in City Light's past practice. We

recommend that City Light evaluate the effectiveness of its

temporarily expanded escalation team, and incorporate lessons

learned from this team into its permanent policies and practices.

City Light customer

complaint processes

can require multiple

hand-offs

We found that City Light's process for handling customer inquiries is

cumbersome for customers and results in delayed resolution of

billing problems. City Light's processes6 for responding to customer

inquiries involve tasks performed by different City Light units and/or

staff, and do not always provide customers with information that

their issue has been resolved.

If a customer calls the Customer Contact Center with an inquiry

about their bill, the customer service representative who answers

their call will research the account and try to resolve the issue.

However, if the customer service representative cannot resolve the

problem, they create a task in the CCB system (a "To Do") that is sent

to City Light's staff for review and resolution. For example, when

customers call the Customer Contact Center to report that the movein

or move-out dates on their bill are incorrect, the customer service

representative will create a task in CCB for City Light's new accounts

and meter sets staff. Hand-offs like this mean that customers wait

longer for their issues to be resolved. When there are backlogs in the

6 City Light has both formal and informal processes for resolving customer disputes. These are described in Appendix E.

"When things are going

well, a customer may

have little direct

interaction with the

utility, but when things

go wrong, it is critical the

utility respond

effectively."

American Public Power

Association training materials

Seattle City Light Customer Care and Billing Audit

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work assigned to staff in specialized units, the wait can be even

longer.

Customers not always

informed how their

complaint was

resolved

City Light lacks controls that ensure customers are informed in a

timely way that their issue has been resolved. As a result, when City

Light staff resolve a customer's issue, the customer does not always

get immediate feedback on the resolution. Rather, an adjustment

shows up on the customer's next bill. City Light staff told us that

when bill adjustments are made, new bills are produced and sent as

soon as the issue is resolved. This means the customer should see

the adjusted bill within a week. In the meantime, the customer may

still wonder what is happening with the account or not understand

the adjustments on the bill they receive.

City Light staff may follow up directly with customers via telephone,

email or by using letter templates in the CCB system. However, this

communication varies on a case-by-case basis and is based on the

customer service representative's discretion. Because there is no

formal policy requiring staff to do follow up with customers, City

Light management cannot ensure that this practice is consistent.

Recommendation 8 City Light should revise its policies and procedures so that all

customers whose inquiries require further research are contacted

when the issue has been resolved.

Some customers were

dissatisfied with how

their complaints were

handled

We conducted four in-depth case studies of customers who had

escalated complaints about high, unexpected City Light bills. We

found that these customers received high, unexpected bills for

different reasons. In some cases, there were high catch-up bills

following low estimated bills. In other cases, bills were delayed and

covered more than one billing period.

However, regardless of cause, customers' experiences were

negatively impacted by:

1. Their inability to obtain satisfactory explanations for what was

going on with their account,

2. Perceived lack of empathy on the part of the City Light

employees with whom they interacted,

3. Unclear or inconsistent policies and procedures related to

payment arrangements, and

4. Lack of follow through by City Light employees.

In Exhibit 8 we describe the experiences of two City Light customers

who were trying to resolve situations with unexpected high bills.

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We concluded from our case studies that City Light could improve

how it resolves customer complaints by providing customers with:

1. One easily accessible point of contact for the customer,

2. Thorough and clear explanations of account activity, in terms

lay persons can understand,

3. Flexible options for payment arrangements,

4. Options for understanding variations in electricity use

(including on site energy conservation assessments), and

5. Proactive, timely, follow through to assure customers that

appropriate account adjustments have been made and/or

plans are in place to resolve the issue.

City Light's escalation

team may be a model

for handling customer

complaints

To improve customer service and reduce the number of customer

complaints that go into formal dispute resolution, in October 2019,

City Light temporarily expanded its customer escalation team to

include a supervisor and three customer service representatives. City

Light plans to further increase staff so that there are eight customer

service representatives on the team. City Light's September 2019

memorandum, Creating a Customer-Centric Culture, explains the

functions of this newly expanded team:

Exhibit 8: Customer Case Studies

We interviewed four City Light customers who had escalated complaints about high, unexpected City

Light bills. Below are examples of what two of these customers encountered:

High catch up bills are challenging for customers

Customer A is a senior citizen with a fixed income, sharing a 1,090 square foot house with a sibling. Over a

period of two years, the customer had three estimated bills that resulted in large catch-up bills. The catchup

bills ranged from 15 to 76 percent higher than the average bill during this same period. The customer

never heard from City Light after submitting an initial complaint and decided to just pay the bill. The

customer noted that "financially, it was a hit," and that to pay the unexpected high bills required use of

funds from the customer's 401k plan. When asked what City Light could have done differently, the

customer said, "They could have provided a response and explanation of what was going on."

City Light customer service experience varies, and significantly impacts customer satisfaction

Customer B is a homeowner who received unexpected high bills due to estimated and delayed bills. The

first customer service representative with whom the customer spoke could not explain why the bills were

estimated for such long periods or why no one had read the meter. Additionally, the customer service

representative did not seem to understand the burden the unexpected high bills placed on the customer.

The customer found this very frustrating. However, in a subsequent call, a second customer service

representative demonstrated empathy for the customer's situation, and this made a big difference to the

customer.

Source: Seattle Office of City Auditor based on case study interviews.

Seattle City Light Customer Care and Billing Audit

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"These employees will be dedicated to proactively identifying

potential billing concerns and working with customers start-to-finish

to address those concerns. In addition to performing a quality

assurance analysis of all residential bills that are larger than the

threshold amount, the team will proactively reach out to these

customers to explain why the bill is high and provide information

about energy efficiency ideas, rate assistance programs, budget

billing, and payment plans."

"The expanded customer escalation team will staff a customer hotline

with chat feature and an email address that will be dedicated to

helping customers resolve billing issues. This team will work with the

customer from start until finish to address their concerns and ensure

that the customer is aware of the resources available to them. The

team will identify and track root causes of billing issues. This

information will be utilized for further process improvement and

performance management opportunities."

City Light managers told us that they are also working on a high bill

resolution procedure and template for all customer service

representatives to use. Ideally, this guidance will provide a tool to

help customer service representatives explain account information to

customers in a simple, clear and consistent way. This tool, along with

the expanded escalation team, addresses some of the weaknesses we

identified in City Light's dispute resolution processes by providing:

1. A single, consistent, point-of-contact for the customer,

2. A tool to facilitate clear explanations of account activity, and

3. Proactive, timely follow through.

Recommendation 9 City Light should evaluate the effectiveness of its temporarily

expanded escalation team.

Recommendation 10 City Light should incorporate lessons learned from the

evaluation of its temporarily expanded escalation team into its

permanent policies and practices.

Recommendation 11 City Light should report on the results of the evaluation and

related policy changes to the Seattle City Council by December

2020.

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CITY LIGHT COULD DO MORE TO HELP

CUSTOMERS MANAGE PAYMENTS

AND ENERGY USE

Section Summary We found that City Light offers payment plans and payment

arrangements to assist customers in keeping current on their bills.

City Light increased the use of these payment arrangements in 2018

and 2019 in response to the increase in the number of customers

receiving unexpected high bills. However, City Light could make it

easier for customers to set up payment arrangements and could

further support customers in making on time payments and

managing their energy use by implementing promising practices

from other jurisdictions.

City Light offers

customers payment

options and assistance

We found that City Light offers two types of payment options for

customers who need more time to pay their bills:

1. Payment Plans

Payment plans are short-term agreements that prorate an

account balance over several (e.g., one to two) billing periods

to pay down a large balance. Customer Contact Center

customer service representatives, City Light Credit and

Collections staff, and Emergency Low Income Assistance

(ELIA) staff can work with customers to set up payment plans

(see Appendix F for a description of the ELIA program).

2. Payment Arrangements

Payment arrangements are long-term agreements that

prorate a high bill over longer billing periods, such as six to

twelve months. These came into effect when unexpected high

bills based on estimated meter reads became an issue for City

Light customers. Only City Light's Credit and Collections

manager is authorized to set up payment arrangements. He

told us that the bill can only be amortized over the same

period covered by the estimated reads.

In addition to payment plans and arrangements, staff may refer lowincome

customers to other programs for financial assistance. These

programs include: The Emergency Low Income Assistance (ELIA)

program, 211, Project Share, and the Utility Discount Program.

Customers must income qualify for these programs. City Light may

also refer low income customers to external agencies that may be

able to provide other forms of assistance. See Appendix F for a

description of these programs.

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City Light increased

payment arrangements

in response to billing

issues

City Light increased the use of payment arrangements in the last

two years to accommodate customers who received unexpected

high bills. Exhibit 9 shows the number of customers who entered

into payment arrangements with City Light in 2017, 2018 and the

first half of 2019. As you can see from the Exhibit, the number of

customers with payment arrangements increased 775 percent

from 2017 to 2018 and 38 percent from 2018 to 2019. These

payment arrangements should make it easier for customers to

manage unexpected high bills, as they spread the high payment over

subsequent billing periods.

Exhibit 9: Number of Seattle City Light Customer Payment

Arrangements

Source: Seattle Office of City Auditor analysis of Seattle City Light data.

City Light could make

it easier for customers

to set up payment

arrangements

Contact Center and City Light staff can set up short-term payment

plans but not long-term payment arrangements. For payment

arrangements, staff create a task in CCB for Credit and Collections. At

the time of our review, only the manager of the Credit and

Collections unit was authorized to process these tasks, which involve

setting up payment arrangements.

According to the American Public Power Association, front-line

employees need to be empowered to provide excellent service to

utility customers. Specifically, they need:

? The right skills and the ability to act upon those skills,

? The ability to take ownership of any problem that appears in

front of them,

? The skills and experience to understand the issue being

presented and how the utility's policies and options apply to it,

and

79

691

953

2017 2018 First Half 2019

Seattle City Light Customer Care and Billing Audit

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? The ability to see the issue through to resolution.

Because Contact Center employees must forward requests for

payment arrangements to City Light's Credit and Collections group,

and the number of employees who can approve these arrangements

is limited, it takes longer for customers to resolve their issues and

get back on track paying their bills. City Light could make it easier

and more efficient for customers who need to set up payment

arrangements by expanding the number of employees authorized to

do this line of work.

Recommendation 12 City Light should give customer service representatives the

training and authority to set up payment arrangements.

Recommendation 13 To prevent fraud and ensure equity, City Light should institute

appropriate internal controls at the same time as this authority is

granted.7

City Light does not

translate online

payment arrangement

options into multiple

languages

City Light does not offer online language translation options on its

website. As a result, the webpages that contain information about

payment plans, payment arrangements, and payment assistance are

not accessible to customers with limited English proficiency.

Consequently, these customers may not know about, or be able to

take advantage of, available payment options. This could cause the

customers to fall further behind on their payments and risk having

their electricity shut off. We offer two recommendations for how City

Light could address this inequity.

Recommendation 14 City Light should provide language translation options for the

online information it provides about payment plans, payment

arrangements, and payment assistance.

Recommendation 15 City Light should conduct targeted outreach in the City's top tier

languages8 to inform customers about the availability of

payment plans, payment arrangements, and payment assistance.

7 Examples of internal controls City Light may want to consider include: 1) review of weekly or monthly payment

arrangement reports to identify irregular patterns, and 2) periodic surprise audits of a random sample of payment report

authorizations.

8 Seattle top tier languages are languages other than English spoken by the largest number of city residents. These

languages are broken into two tiers. The first tier are ones spoken by at least 10,000 residents. The second tier are

spoken by at least 5,000 residents. For more information see https://www.seattle.gov/iandraffairs/LA.

Seattle City Light Customer Care and Billing Audit

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City Light should

consider promising

practices from other

utilities

Our research on promising practices from other jurisdictions

identified ways utilities can make it easy for customers to pay their

bills and offer payment assistance and energy saving opportunities

to low-and moderate-income customers. In Exhibit 10 we describe

the promising practice, its benefit to customers, and whether City

Light offers the same service.

Exhibit 10: Promising Practices to Help Customers Pay Bills and Manage Energy Use

Promising Practice Benefit to Customers

Offered

by City

Light

Set up payment plan online

Offer customers the chance to create a standard online bill

payment agreement.

Expedites process for

creating a payment plan and

avoiding service

disconnection.

Yes

Incentivize energy efficiency improvements in rental

units.

Provide multiple family property owner and building

managers with a centralized source for energy-related

funding to make improvements in rental units.

Lowers cost of energy for

tenants.

Yes9

Tailor payment arrangements to individual customer

needs

Offer customers an analytics-determined payment

arrangement that establishes a monthly budget payment

based on the customer's billing history.

Makes it easier for customers

to stay current on their

payments and avoid past due

bills.

No

Allow customers to give assistance agencies direct access

to their account

Allow customers to give energy assistance agencies direct

access to their account through a secure online portal.

Expedites financial assistance

payments for low income

customers and prevents

accounts from going past

due.

No

Forgive the final payment for low-income customers who

make regular payments on their past due accounts

Forgive the final payment for low income customers who

make on-time, monthly payments on their past due balances

for 12 consecutive months.

Provides incentives for

customers to keep current

with their payments and

establish good consumer

payment habits.

No

Help low- and moderate-income customers manage their

energy use

Provide smart thermostats to income-eligible low-andmoderate

income customers using local and Women and

Minority-owned Business Enterprise (WMBE) suppliers to

install these thermostats.

Provides tools to low-andmoderate

income customers

to help them manage their

energy use and its cost.

No

Source: Emerging Solutions for Residential Customers: Case Studies, June 2019, Edison Electric Institute

Recommendation 16 City Light should implement promising practices from other

utilities.

9 See https://energysolutions.seattle.gov/your-business/multi-family-buildings/

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OBJECTIVES, SCOPE, AND

METHODOLOGY

Objectives We conducted this audit in response to Seattle City Councilmember

Teresa Mosqueda's request to review Seattle City Light's (City Light)

billing and customer services practices. Specifically, we were asked to

examine how City Light:

? Prevents erroneous and/or unexpected high bills,

? Communicates with customers about unexpected high bills,

? Resolves customer complaints and appeals,

? Provides payment options, and

? Reimburses customers who have been overcharged.

Additionally, we wanted to understand why City Light customers

received unexpected high bills and identify promising practices from

other utilities.

Scope The scope of this audit focused on City Light's customer care and

billing practices from September 2016, when the new Customer Care

and Billing system was implemented, through November 2019. The

periods covered by our data analysis varied based on available data

and the purpose of the analysis. See Methodology section below.

Methodology To understand the timing and extent of City Light's billing problems,

we analyzed data on:

1. The number of consecutive estimated bills City Light

produced from 2012 through 2018,

2. The number of moves waiting to be processed that fell

outside City Light's 14-day target for processing from

October 2017 through June 2019,

3. The number of calls Seattle Public Utilities'(SPU) Contact

Center received related to inquiries about City Light's high

bills and new accounts and moves from 2014 through June

30, 2019, and

4. The number of customer payment arrangements in effect

from 2017 through June 2019.

To understand City Light's billing processes and procedures and

factors that may have contributed to customers receiving unexpected

Seattle City Light Customer Care and Billing Audit

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high bills, we reviewed State of Washington and City of Seattle laws

and City Light's formal and informal policies and procedures,

interviewed City Light managers and staff, and observed SPU Contact

Center staff and City Light customer service representatives at work.

To understand how City Light handles customer complaints, we

reviewed City Light's policies and procedures related to dispute

resolution, interviewed the City Light analyst in charge of handling

escalated complaints and City Light's Hearing Officer, and reviewed

their records and selected case files.

To understand the customer experience, we conducted four in-depth

case studies of customers who had made complaints to either our

office or the Seattle City Council about unexpected high bills. For

each of these case studies, we documented the customer's

correspondence with City officials, gathered and analyzed their

account data, and interviewed each customer. We also analyzed data

to assess if there was evidence of geographic or income inequity in

who receives consecutively estimated, and therefore unexpected

high catch-up, bills. See Appendix H for a description of our

methodology.

We researched promising practices related to how electric utilities

communicate to customers about billing issues, such as incorrect or

unusually high bills. This included reviewing information from the

American Public Power Association (APPA), Edison Electric Institute

(EEI), and the United States Department of Energy.

To understand other utilities' policies and procedures related to

payment arrangements, we surveyed twelve utilities. To identify

comparable utilities, we selected a sample of 15 potential

respondents based on those used by Cuthbert Consulting for their

December 17, 2018 Review of Electric Utility Rate Design Options.

Twelve utilities responded to our requests for information. To

document these utilities' policies and procedures, we reviewed online

information, interviewed utility managers and staff and reviewed

documents they provided to us.

We conducted this performance audit in accordance with generally

accepted government auditing standards. Those standards require

that we plan and perform the audit to obtain sufficient, appropriate

evidence to provide a reasonable basis for our finding and

conclusions based on our audit objectives. We believe that the

evidence obtained provides a reasonable basis for our finding and

conclusions based on our audit objectives.

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APPENDIX A

Departments' Responses

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APPENDIX B

List of Recommendations

1. City Light should lower the current number of 12 consecutive estimated bills allowed in their

Meter Data Management system.

2. City Light should lower the current high consumption variance allowed in their Meter Data

Management system.

3. City Light should track seasonal variations in the workload of related to processing new accounts

and moves.

4. City Light should develop an annual staffing plan to accommodate fluctuations in demand for

processing new accounts and moves.

5. City Light should develop a system for managing returned mail and explore how this body of

work could be handled in the Customer Care and Billing system.

6. To understand the impact changes in its policies and procedures are having on customer

satisfaction, City Light should conduct regular customer satisfaction surveys.

7. City Light should enhance its use of new technologies to proactively provide customers with data

about their accounts.

8. City Light should revise its policies and procedures so that all customers whose inquiries require

further research are contacted when the issue has been resolved.

9. City Light should evaluate the effectiveness of its temporarily expanded escalation team.

10. City Light should incorporate lessons learned from the evaluation of its temporarily expanded

escalation team into its permanent policies and practices.

11. City Light should report on the results of the evaluation and related policy changes to the Seattle

City Council by December 2020.

12. City Light should give customer service representatives the training and authority to set up

payment arrangements.

13. To prevent fraud and ensure equity, City Light should institute appropriate internal controls at

the same time as this authority is granted.

14. City Light should provide language translation options for the online information it provides

about payment plans, payment arrangements, and payment assistance.

15. City Light should conduct targeted outreach in the City's top tier languages10 to inform

customers about the availability of payment plans, payment arrangements, and payment

assistance.

16. City Light should implement promising practices from other utilities.

10 Seattle top tier languages are languages other than English spoken by the largest number of city residents, based

upon data from the U.S. Census Bureau, American Community Survey, Seattle Public Schools, Seattle Municipal Court,

and departmental data. These languages are broken into two tiers. The first tier are ones spoken by at least 10,000

residents. The second tier are spoken by at least 5,000 residents.

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APPENDIX C

City Council Request Letter

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APPENDIX D

Template of Letter Sent to Customers

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APPENDIX E

City Light's Dispute Resolution Process

Before July 2019, City Light's policy for customer dispute resolution consisted of two steps:

Step 1: Informal Dispute Conference

Disputed bills are reviewed by City Light staff for accuracy and equitable application of municipal

laws and department policies.

Step 2: Formal Appeal for City Light Hearing Officer Review

If the disputed issue was not resolved during the informal dispute conference, then the customer

could initiate a formal appeal by submitting a written request for a City Light Hearing Officer

review.

In July 2019, City Light adopted a new Department Policy and Procedure on the customer dispute

resolution and utility Hearing Officer process. This policy outlines a progressive resolution process with

four steps. At each step of the process, the City Light reviewer analyzes the dispute and communicates

with the customer, with the goal of resolving the customer's dispute without the need for further review.

Step 1: Informal Dispute Resolution:

Initial Conference Review. Bill dispute is reviewed by a City Light representative for accuracy,

correction of inaccuracies or billing problems, and equitable application of laws, policies and

procedures.

Step 2: Informal Dispute Resolution:

Supervisor Review. A customer may request a second review by a supervisor if dissatisfied with

the outcome of the Step 1 review.

Step 3: Informal Dispute Resolution:

Manager Review. A customer may request an additional review by a City Light Manager

(designated by the Officer/Director) if dissatisfied with the outcome of the Step 2 review.

Step 4: Formal Dispute Conference:

City Light Hearing Officer Review. A customer may request a final administrative review if

dissatisfied with the outcome of the Step 3 review by filing an appeal with the City Light Hearing

Officer.

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APPENDIX F

Description of Payment Assistance Options

A description of the energy assistance programs City Light offers can be found at

http://www.seattle.gov/light/paymybill/arrangements.asp. These include:

The Utility Discount Program (UDP)

The Utility Discount Program helps income qualified Seattle City Light customers lower their electric bills

by 60 percent. Seattle Public Utilities customers will also receive 50 percent off their water, sewer, and

garbage bills if enrolled in this program. Seattle City Light customers are eligible if their total household

income for the past month does not exceed seventy percent of the State of Washington's median

income. Customers are directed to call (206) 684-0268 for more information or can click on a website

link to begin the application process. See http://www.seattle.gov/light/assistance/

Emergency Low Income Assistance (ELIA)

The Emergency Low Income Assistance (ELIA) program is for customers who have received an "Urgent"

or "Shut-Off' notice on balances of $250 or more. If the notice was received during the portion of the

year that the federally-funded Low Income Home Energy Program (LIHEAP) is operating, the customer is

encouraged to apply for assistance from LIHEAP as well.

To participate, the customer must first make the payment that is due to avoid disconnection, as well as

make payment arrangements on the remaining balance. Participants may receive up to $200. Assistance

is limited to once every twelve months. Customers are directed to call (206) 684-3688 or email

SCL_InfoELIA@seattle.gov. for more information or can download an application to the program at

http://www.seattle.gov/light/assistance/

Project SHARE

Project Share is funded by City Light customers' donations and is available to customers who have

participated in LIHEAP and ELIA. Initially, it will pay up to $250 towards the customer's City Light bill. If

the customer makes a payment within two weeks of referral or interview, Project Share will contribute a

matching pledge of $1 for every $1 the customer pays, with $500 being the maximum amount available.

Customers are directed to call (206) 684-3000 for more information or can download an application to

the program from the Assistance Programs page of Seattle City Light's website. See

http://www.seattle.gov/light/assistance/assistance.asp

HomeWise

Income qualified customers may also be eligible for HomeWise, the City of Seattle's weatherization

program. Improvements like insulation and heating system replacement or repair, can help customers

save energy, lower heating and cooling costs, and save money on their bills. Customers are directed to

call (206) 684-0244 or visit www.seattle.gov/housing/homewise.

City Light's website (see http://www.seattle.gov/light/assistance/assistance.asp) also provides links to

information about external assistance programs, such as:

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Federal Energy Assistance Program (LIHEAP)

This is for customers whose main source of heat is electricity, gas, or heating oil, and need help paying

their utility bill during the winter season. These customers are directed to the following contacts,

depending on where they reside:

? Residents of Seattle - call 206-486-6828 or schedule online at Byrd Barr Place's website

? Residents of South King County - call 253-517-2263 or schedule online at https://mschelps.org/

? Residents of North & East King County - call 425-658-2592 or schedule online at

https://www.hopelink.org/need-help/energy

In addition to energy assistance, this federally funded program offers energy education, budget

counselling, and weatherization services

2-1-1

Seattle City Light customers in need of utility assistance and/or health and human services, can call 2-1-

1. The 2-1-1 Community Resources line is a shortcut to locating information, agencies, and support

services within a zip code. 2-1-1 specialists can provide referrals to utility, food, shelter, housing,

employment, rental assistance, financial assistance and governmental assistance. To learn more about 2-

1-1, either call 2-1-1 or visit online.

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APPENDIX G

Most Refunds are Handled as Credits

Generally, all overcharges on Seattle City Light customer accounts are handled by giving account credits

on the customer's next bill. However, any customer with a credit balance on their bill can request a

refund check if they would like one. Additionally, in the following cases, City Light issues refund checks,

rather than credits:

1. Closed accounts these customers are sent refund checks unless they paid by credit card, in

which case overpayments will be refunded to the card that was used to make the payments.

2. Utility credit refunds for the Utility Discount Program (UDP) these customers are sent checks

annually when the monthly credits applied to the account are reconciled with the monthly

charges for electricity.11

3. Escrow accounts12 these customers are sent refund checks.

11 This reconciliation can result in a credit balance due the customer because the UDP was intended to cover both the

costs of electricity and water, wastewater and solid waste. In cases when a customer's landlord pays for water,

wastewater and solid waste, the UDP assumes this cost was included in the rent. Accordingly, the annual credit due the

customer from City Light is intended to help cover these costs.

12 Escrow accounts are financial instruments whereby an asset or escrow money is held by a third party on behalf of two

other parties that are in the process of completing a transaction. When a property is being sold, an escrow company will

request a final closing bill from City Light so the amount can be deducted from the proceeds of the sale.

Seattle City Light Customer Care and Billing Audit

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APPENDIX H

Who Was Affected by Consecutively Estimated Bills?

We asked City Light to map the number of residential customers who received estimated bills by zip

code as of November 28, 2018. See Exhibit 11 on the next page. To determine if specific subpopulations

were adversely impacted by estimated bills, for each of the zip codes for which we had estimated bill

data, we used U.S. Census data to calculate:

1. The percent of the population in each zip code that was non-white, and

2. The percent of the population in each zip code that was 200 percent or more below the federal

poverty level.

We found that almost 81,000 estimated bills, or about 28 percent of the estimated bills sent by City

Light in our sample period, were sent to zip codes where 50 percent or more of the population was nonwhite.

Additionally, we found that over 23,000 estimated bills, or about 8 percent of the estimated bills

sent by City Light in our sample period, were sent to zip codes where 40 percent or more of the

populations was 200 percent or more below the federal level.

We then ran a regression analysis to determine if there was a relationship between the number of

estimated bills sent to City Light customers in each zip code and the percent of the population in the zip

code that was non-white.

We also plotted scatter grams to further assess if there were any relationships between these two

variables or between the number of estimated bills sent to City Light customers and the percent of the

population that is 200 percent or more below the poverty level.

We did not find evidence of a relationship between the number of estimated bills sent to City Light and

either of these variables. However, because this analysis was based on aggregate data by zip code, and

populations vary within zip codes, we cannot determine conclusively that there was no correlation

between consecutively estimated bills and non-white or low-income persons.

Seattle City Light Customer Care and Billing Audit

Page 48

Exhibit 11: Estimated Residential Bills by Zip Code, September 2016 through November 2018

Source: Seattle City Light

Seattle City Light Customer Care and Billing Audit

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APPENDIX I

Seattle Office of City Auditor Mission, Background, and Quality

Assurance

Our Mission:

To help the City of Seattle achieve honest, efficient management and full accountability throughout City

government. We serve the public interest by providing the City Council, Mayor and City department

heads with accurate information, unbiased analysis, and objective recommendations on how best to use

public resources in support of the well-being of Seattle residents.

Background:

Seattle voters established our office by a 1991 amendment to the City Charter. The office is an

independent department within the legislative branch of City government. The City Auditor reports to

the City Council and has a four-year term to ensure the City Auditor's independence in deciding what

work the office should perform and reporting the results of this work. The Office of City Auditor

conducts performance audits and non-audit projects covering City of Seattle programs, departments,

grants, and contracts. The City Auditor's goal is to ensure that the City of Seattle is run as effectively,

efficiently, and equitably as possible in compliance with applicable laws and regulations.

How We Ensure Quality:

The office's work is performed in accordance with the Government Auditing Standards issued by the

Comptroller General of the United States. These standards provide guidelines for audit planning,

fieldwork, quality control systems, staff training, and reporting of results. In addition, the standards

require that external auditors periodically review our office's policies, procedures, and activities to

ensure that we adhere to these professional standards.

Seattle Office of City Auditor

700 Fifth Avenue, Suite 2410

Seattle WA 98124-4729

Ph: 206-233-3801

www.seattle.gov/cityauditor