Letter urges City Council to hold a public hearing before implementing AMI water meter system opt-out provisions


Image: Water meter interpreter register | Itron.com

Hello Council Members!

Bellevue Utilities rate payers have been paying for the acquisition of the AMI water meter system since about 2014/2015, when the Department began including the Department’s early-study costs for an AMI water meter system, and the system’s acquisition cost, in Bellevue utility water and sewer rates. 

Since that time, various issues have cropped up, one of which concerns the ability of rate payers to ‘opt out’ of the system (provisions that allow certain water customers to have an AMI meter installed without its data telemetry transceiver). At the 6 May 2021 City Environmental Services Commission's (ESC) virtual meeting, Commissioners received a briefing on the staff’s proposed AMI system 'opt-out' procedure. After some limited Q&A, the Commission voted 4-2 to recommend (to the staff and Council) not to approve any opt-out procedures for the AMI project.

Why this vote was of any import is a mystery since most, if not all, single-family residential water meters are owned, operated, and maintained by the City’s Utilities Department; and are installed on City right-of-way (or other City-owned) property. Thus, it would seem that the Utilities Department could have simply proceeded with AMI meter/transceiver installations and ignored the expression of a minuscule amount of objection to such action by a few residents. 

Nevertheless, the Utilities staff decided to study the issue further, and to present an updated recommendation at a later date. At the ESC’s 6 January 2022 virtual meeting the Utilities Department staff presented a current status report on the AMI water meter project, and the Department’s proposed, somewhat updated ‘opt-out’ procedure for that project (see attached pdf).

The Department’s contractor (Itron) has installed about 21,000 AMI large and residential water meters without transceivers due to transceiver production delays; installations of transceivers and meter/transceiver units are presumably currently just beginning to be made. The City’s AMI project includes about 37,000 ‘end-point’ (meters and transceivers) installations in Bellevue, and about 3,000 installations in municipalities outside Bellevue (in Medina, Clyde Hill, Hunts Point, etc.).

According to the Department’s updated opt-out presentation at the ECS’s 6 January 2022 meeting, Bellevue utilities customers who opt-out will suffer the following penalties: (1), no access to near real-time water use data; (2), no reception of important/automatic ‘alerts’ regarding water leaks and back flow; (3), ineligibility for bill adjustments due to after-the-meter water leaks; (4), additional one-time and monthly costs; and (5), opt-out customers will impose incremental costs on the Utilities Department.

Neither the staff nor the ESC have made any effort to obtain public comment and input on the updated/proposed opt-out regulations and policy (the same deficiency occurred before and after the first opt-out review in May 2021). 

The updated policy was first published when the agenda for the ESC’s 6 January 2022 meeting was posted on the ESC’s web site (27 December 2021). There is no mention of the policy on the project web site, and there was no coverage of the subject in the May-December 2021 or the most recent (January 2022) issues of Neighborhood News. Similarly, no information on the opt-out policy was provided in the February, June, and October issues of It’s Your City; and there is no mention of an opt-out policy in the project's 11 May 2020 AMI project communication plan prepared by the Department’s contractor, PRR. 

Thus it is clear that neither the Utilities Department’s staff or the Environmental Services Commission have any interest in obtaining inputs from City utilities rate payers on the proposed opt-out policies. 

In addition, the newly proposed regulations and policy were only published a short time before the ESC's 6 January 2022 meeting, thus interested citizens had essentially no time to review them and make comments to the ESC; this is especially true since it is not possible to communicate with the ESC commissioners or the staff on any sort of effective basis.

There are a number of misleading assertions in the staff’s 6 January 2022 presentation materials; the staff and the ESC should correct these errors by publishing some sort of ‘white paper’ on the proposed opt-out policies in various City on-line and print media:

(1), No access to near real-time water use data: this is totally incorrect - single-family rate payers can obtain such data by simply observing their water meter face plate and recording the volume readings as frequently as they desire;

(2), No reception of important/automatic ‘alerts’ regarding water leaks and back flow: Single family rate payers receive notices in their bi-monthly bills and should expect to continue to receive such notices under any adopted opt-out procedures. After-the-meter leaks and back-flow events can be detected by observing the indicators on the AMI meter face, and by following simple procedures (shut off all water supply to the residence and observe meter flow indications, etc.);

(3), Not eligible for bill adjustments due to after-the-meter water leaks: this is a purely punitive policy with no rational justification and should be eliminated from the proposed opt-out policy set. Single-family customers will still be able to detect after-the-meter leaks by simply inspecting their meter’s face plate at a reasonable frequency and will face the same requirements for identifying the location, and correcting the leaks as will all other water utility customers. Opt-out customers should be treated the same as all other customers under the provisions of City ordinance 5454.

(4), Additional one-time and monthly costs: the costs proposed by the Utilities staff have no rational basis or justification, as opt-out customers could easily report their water-use values to the City on a monthly or bi-monthly basis (via mail, email, or telephone), with a true-up reading by the Utilities Department staff annually or, say, every 6 months. The Department already has the billing procedures in place for customers who do not have an AMI transceiver or meter/transceiver installed; these procedures can be used for opt-out customers;

(5), Maintenance of an incremental number of staff and vehicles to service opt-out customers: The staff has released no information that shows that the Department would require an incremental number of staff and vehicles to service a few opt-out customers. Since there are very few customers that might choose the opt-out option, it seems unlikely that they would impose any significant incremental workload or vehicle requirements on the utility. The utility staff should provide their analysis to substantiate their assertion so that rate payers can understand the basis for this outlandish claim.

(6), Decreased AMI project “efficiency”: the Utilities Department has never established any measure(s)/metric(s) of “efficiency” for the AMI project, and there is no credible basis for this outlandish provision. If the Utilities Department has established some sort of ‘efficiency’ metric for the AMI meter system/project they should identify the metric, and explain how it is affected by opt-out customers.

All Bellevue utility customers are paying for the AMI system in their existing water and sewer rates, and these rates will be increasing over the 20-30 year life of the AMI system to cover AMI ownership costs.  There is no credible reason to penalize certain customers because they opt out of the City’s wasteful and unneeded AMI water metering system. 

I urge the Council to direct the City Manager to require the Utilities Department to review the proposed opt-out policies, and develop answers to the above comments for Council consideration. This should include significant and extensive contact and notification to utility rate payers about the proposed opt-out policies, and holding a public hearing on the AMI system policies, procedures, and opt-out policy before they are implemented by the Utilities Department.

David F. Plummer

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