June 30, 2018
Honorable Jenny A. Durkan
Mayor, City of Seattle
7th Floor, City Hall
600 4th Avenue
Seattle, WA 98104-1850
Subject: City Light Billing System Errors Create $1,216.84 Overcharge

Dear Mayor Durkan
Our most recent City Light bill dated April 26, 2018 is $2,002.04. We've never had another bill that was even remotely
close to that amount. Our next highest bill was in the Winter season of last year 2016-2017 when the bill dated February
27, 2017 was $608.74 . In this letter, we show through our observations including our own manual meter reads and
calculations that the extremely high bill was miscalculated; that it was caused entirely by City Light billing process and
billing system errors; and that, as a result, we were substantially overcharged on this bill. The net amount of the
overcharge and the correction due to our account is $1,216.84.
Moreover, we clearly demonstrate how the billing system incorporated a systematic procedural error that, in our case,
caused the high bill. This error is not unique because we've identified through the neighborhood biogs other cases where
the same problem has occurred. To confirm that this error occurs repeatedly in the City Light billing system, we
contacted the City Light customers connected to the blog entries and verified the three part sequence of events,
specifically one or more estimated bills, a meter exchange, and a high bill. We discovered that City Light has a lot of very
annoyed customers over this error in the billing system.
We have three requests: (1) We very much want to sit down with you and your staff and talk through the specific
problems identified in this letter. (2) We want a refund of the overcharge on this bill and any additional fees or charges
that accrue to our account as a result of this billing error. (3) We want you to understand the procedural errors that cause
these systematic overcharges to City Light customers like us who have one or more estimated bills coupled with a meter
exchange followed by a very high bill; and then to initiate the actions to correct the problem which could include an audit
of customer accounts.
We, the property owners, are recently retired City Light employees . During our tenure, we were customer advocates in
the Account Executive Office and devoted much of our time to the resolution of billing issues for the largest commercial
and industrial customers of the utility, organizations like Nucor, Boeing, Amazon and so forth. In addition, Linda was the
project manager of City Light's Advanced Metering Pilot Project in the South Lake Union Planning Area in 2005 to 2007
and the subsequent development of City Light's AMI Business Case. She was widely recognized as a metering and
billing process expert at City Light and in the utility industry. By her observation, this meter exchange-billing process error
has been occurring since 2005 and may be the "fact" behind the "myth" that when you get a new automated meter your
bill goes up. After so many years, it is time to correct the billing procedure so that Your Seattle City Light customers can
avoid this overcharge.
Issue No. 1: Billed Energy Consumption Was Estimated Over Three Consecutive Billing Cycles.
On the latest City Light bill dated April 26, 2018, there is a graph entitled Compare Your Electricity Usage. Inside that
graph, there are two vertical bars that show the difference between the per day energy use in the current year (black bar)
and in the previous year (gray bar) for the same billing cycle. For this bill, the estimated energy use in the current year
from the City Light billing system was 269 .3 kwh per day and in the previous year, the actual, measured energy use was
60.4 kwh per day . So the energy use is 4 to 5 times greater this year in comparison to the previous year, a whopping
change that is clearly visible on the right side of the graph because the comparative height of the two side-by-side vertical
bars is so different. This comparison prompted us to ask what occurred within the City Light billing process and system to
cause a bill to be so far out of whack?
Issue No. 2: Property Owners' Own Meter Reads Indicate Consistent Year-to-Year Energy Consumption. City Light Has
No Comparable Data.
When we received the City Light bill dated December 28, 2017 and observed that it was based on an estimated read, we
decided that we should take and record our own meter reads. As a result of this decision, we executed a read on the old
meter on February 19, 2018 and after a new meter was installed on February 27, 2018, we conducted daily reads on that
meter through the rest of the billing cycle, February 27, 2018 to April 20, 2018 . The meter data from our meter reads and
the estimated City Light meter reads appear in Table 1 entitled Energy Consumption over the Same Three Billing Cycles
in the Current Year, 2017-2018, and in the Two Prior Years, 2015-2016 and 2016-2017 from the Seattle City Light Meter
Reads and the Property Owners' Meter Reads. For the three consecutive billing cycles in the current year 2017-2018,

 the energy use calculation from the City Light estimated meter reads and from the Property Owners' actual meter reads is
dramatically different; over that six month period, the City Light estimated use is 21,207 kwh or 115.9 kwh per day while
the owners calculated use is 12,448 kwh or 68.0 kwh per day. For the latest billing cycle, over that two month period, the
City Light estimated use is 269.3 kwh per day while the Property Owners' calculated use based upon the actual meter
reads is 59.5 kwh per day. So the City Light estimated consumption is 4.5 times greater than the actual use in the latest
period. Table 1: Energy Consumption has another important comparison as it shows very clearly that the actual City
Light meter reads over the same three billing cycles in the prior year 2016-2017 are very close to the Property Owners'
meter reads over the three billing cycles in the current year 2017-2018 . Nothing has changed. The total consumption or
use matches and so does the use pattern across the three billing cycles . The City Light actual meter reads indicate the
total use was 12,049 kwh or 64 .8 kwh per day in the prior year; our actual meter reads say the use was 12,448 kwh or
68 .0 kwh per day in the current year. Our energy use is consistent because our house is in the same basic
configuration. The key variable turns out to be the procedures and algorithms in the City Light billing system which are
not accurate and produce substantial errors.
Issue No. 3: City Light Billing Process Used No Actual Meter Data.
As soon as we observed the latest bill dated April 26, 2018 and realized that it was in many respects flawed, we called
the City Light customer contact center on April 30, 2018 . Over the course of the ensuing conversation between ourselves
and the customer service representative, Mimi Jones, she verified the following facts: (1) City Light meter reading staff
conducted the last actual read used for billing on Meter 821677 on October 19, 2017; thereafter no actual data was used
by the billing system; every subsequent bill was based on estimated reads over the next three billing cycles. (2) City
Light technical metering staff exchanged the meter at our premises on February 27, 2018. Two procedural errors
occurred in the meter exchange process. Initially, a final read was not recorded on the old meter; in fact, technical
metering staff cannot produce the photo of the read on the old meter which is standard City Light procedure upon the
removal of a meter. And then, the new meter was entered into the City Light billing system on March 27, 2018, a month
after the fact; this date, rather than the February 27, 2018 date of the physical installation, was then used to calculate the
actual consumption on the new meter for billing purposes, which in our case compressed the energy consumption into
half the actual days of use and, in essence, doubled the per day energy consumption for that time period. Table 1:
Energy Consumption clearly shows this outcome. For the time period, March 27, 2018 to April 20, 2018 the average
energy use calculated by the City Light billing system is 128.9 kwh per day; that calculated use rate is more than twice
the actual use from the Property Owners' manual reads, 53.0 kwh per day, in the current year and the City Light reads,
60.4 kwh per day, in the prior year.
Issue No. 4: City Light Customer Service Representative, Mimi Jones, Offers Proposed Solution Using Prior Year Energy
Consumption and Current Year Rate Schedule.
Given our evidence that the energy consumption or use over the three billing cycles in the current year, 2017-2018, is
very consistent and in line with the energy use over the same three billing cycles in the prior year, 2016-2017, and given
that City Light has no accurate data for the three billing cycles in the period October 19, 2017 to April 20, 2018, the
customer contact center staff, Mimi Jones, offered a solution . Her recommendation was to apply the rates in the current
year to the actual measured consumption in the prior year to find a solution that would resolve this billing problem
equitably. The property owners concur and accept a recalculated bill as a reasonable and fair solution. We performed
this calculation, as shown in the attached Table 2: Recalculated Seattle City Light Bill. The results are as follows: (1)
The recalculated bill over the three billing cycles that were estimated based on the energy consumption in the prior year,
2016-2017, and the City Light rates in the current year, 2017-2018, is $1,454.04. (2) Over the last three billing cycles,
we've made three payments totaling $1,096.84. (3) Therefore, the net amount due is $357.20 (4) For the current bill
dated April 26, 2018, the net amount of the overcharge is $1,216.84.
Issue No. 5: Together City Light Meter Exchange and Billing System Procedures Create Significant Billing Errors.
Our case study is a clear illustration of the billing problem created when a meter exchange occurs in the City Light billing
system. Here is our example. At 10:00 AM on February 27 , 2018, we were present when City Light meter technician
Andy Misoda installed a new AMI meter into the meter base at this premises . At the time of its installation , the new meter
was reading zero. Since February 27 we have recorded the reads from this meter every day at 11:00 AM and continue to
capture these reads in our database, so we have an accurate picture of our day-to-day energy use. According to Ms.
Jones, the information about that meter was actually entered into the City Light billing system on March 27, 2018. So
there was a 28-day gap between the meter's physical install date and the meter's data entry or "installation" date in the
billing system; that time gap is a very important factor in the subsequent billing problem. The billing system acted as
though the meter was actually installed on the billing system data entry date, March 27, 2018, and that the meter reading
on that date was zero. That assumption was incorrect because the reading was 1821 kwh on that date. Then 24 days

 Mayor Jenny A. Durkan
City Light Billing System Errors Create $1,261.84 Overcharge
June 30, 2018
Page 3
later, on April 20, 2018, a City Light meter reader took the next recorded read on that meter at the end of the billing cycle;
the recorded read was 3093 kwh.
So now let's review the activity on our bill for that billing cycle. See the attached bill dated April 26, 2018. The City Light
billing system assumed all of the consumption, 3093 kwh, occurred between March 27, 2018 and April 20, 2018 . The
system then observed that it had no data between the physical meter install date, February 27, 2018, and March 27,
2018; and as a result, it inserted an estimated consumption into the bill for the 28 missing days . So in the end, the bill
included (1) the actual consumption between February 27, 2018 and April 20, 2018 from the meter read, and (2) the
estimated consumption between February 27, 2018 and March 27, 2018, from the data entry time gap and missing data
calculation. In our case, there was a double accounting. As was stated earlier, the really sad part is that the data entry
time gap and missing data calculation increases the bill amount after every meter exchange, because that is the
procedure used at City Light.
This time gap and missing data calculation occurs every time, but the net effect varies and depends upon the number of
days the new meter was in use at the premises before it was entered, or in City Light terminology, was "installed" or "set"
into the billing system. This procedural error results in a billing overcharge after every meter exchange. The accurate
procedure would be to enter the actual date of the new meter's physical installation at the premises; for example, take a
time-stamped picture of the new meter at installation and then use that date information when the paperwork process
catches up.
Final Comments
The $1261.84 overcharge was caused entirely by City Light billing process and system errors. It was definitely not, by
any means, the fault of the City Light customers in this specific location. City Light should do what is right; admit that its
staff didn't follow the standard procedures and that the billing system badly miscalculated the estimated consumption;
and then remedy the billing error, in this specific case, the $1261.84 overcharge on this bill.
We submit that City Light should never send out a bill to a customer that has an error of this magnitude where the
estimated energy consumption over a single billing cycle is five times greater than the actual, measured consumption in
the same billing cycle in the prior year. It conveys the message that the City Light billing system has no checks and no
quality control.
We have real due process concerns about the City Light review of our high bill complaint which was rejected two different
times, once by the City Light Hearing Officer Ivonne Golborne and then again by the Interim General Manager and Chief
Executive Officer James Baggs. In the one case, the City Light customer service rep, Mimi Jones advised us in our
original call to City Light on Monday, April 30, 2018 that we could appeal the high bill amount to the City Light Hearing
Officer. She then said: "I'll put the appeal form in the mail to you; you should have it later this week." We received the
form on Thursday, May 3, 2018 and as we read the form, we were notified that the appeal process has a five day time
limit. Given the complexity of our case, it took us three days to prepare and fill out the form. We mailed it, postmarked
May 8, 2018. The Hearing Officer received the completed appeal form on Friday, May 11, 2018 and rejected it that same
day because it was postmarked one day late. After all that effort, our case was simply dismissed. We didn't realize that
the five day clock was already ticking when we hung up the phone on Monday, April 30, 2018 and as the form arrived in
the mail on Thursday, May 3, 2018, we were already three days into the process and the five day time limit. This five day
time limit is unduly restrictive and unfair especially where the appeal requires a lot of analysis . Simply put: Justice
constrained is justice denied. In the other case, we wrote a follow-up letter to the Interim General Manager James
Baggs. That letter carefully documented the problems in the City Light billing system and the effect those problems had
on our bill calculation. That letter was sent on May 21, 2018 and received via certified mail and an accompanying signed
and returned receipt on May 23, 2018 . Now, six weeks later, we have no response from him or from anyone at City Light.
So in the end, we were simply kicked to the curb and ignored. The neighborhood biogs echo this sentiment over and
over again. In case you have any doubt, conduct a search on the NextDoor blog; use the keywords: City Light
Overbilling.
We would very much like to sit down with you and your staff and talk through these issues as it is important to us to know
that City Light will correct the errors on our recent bill, and that City Light will tackle the long-time billing system errors that
caused the problems on our bill and apparently on many others. The NextDoor neighborhood biogs are full of similar
complaints that have the same cause, a meter exchange followed by an extremely high bill. Should you concur and wish
to set up a meeting, you may contact us either by phone -------: or -------- or through our respective email addresses ------.

 Sincerely,

Attachments
City Light Bill dated April 26, 2018
City Light Bill dated April 26, 2017
Table 1: Energy Consumption over Same Three Billing Cycles in Current Year and Two Prior Years
Table 2: Recalculated City Light Bill Given Prior Year Energy Consumption and Current Year Rate Schedule
Hearing Officer Appeal Form dated May 7, 2018
Hearing Officer Appeal Letter dated May 11, 2018