Water Works: An Investigation into Water Billing, Metering and Customer Service

The Issue

We have received ongoing complaints from residents about excessive bills for sudden, inexplicable water consumption.

Typically, these residents had called the City to ask why their water bill was suddenly so high. In response, City staff explained how they might have used more water, for example, because of a leak or additional people in the home and how they could have the water meter tested for accuracy. City staff told them that, if the meter was accurate and there was no City equipment or other error, the residents were responsible for the bill. Complainants found their consumption returned to previous levels in the next billing period, regardless of whether the meter was replaced.

Complainants said the City’s response implicitly suggested they were not telling the truth about their water consumption. They thought the City did not explain how their water use could suddenly increase so much and then return to the previous level. The City refused to adjust the bill unless the meter over­registered when it was tested, and then the adjustment was so small as to be meaningless. Some complainants said they were given no opportunity to appeal.

Our Investigation

As a part of our investigation, we interviewed Revenue Services and Toronto Water employees, a representative of the City’s metering contractor, technical staff in other municipalities, independent engineering experts, and complainants. We also reviewed applicable laws, policies, and procedures.

What We Found

Our investigation found that, on the whole, Toronto Water’s metering system functions well. However, the complaints we investigated raise serious issues and our review indicates some areas for improvement, including that:

• When meter estimates are required, Revenue Services waits until the resident’s account has been estimated six times before it requested an actual reading be provided. This represents a period of two years – it is unreasonable to rely on estimates for this length of time and then impose what may be an exorbitant bill on a customer.
• When a resident calls about an unusually high water bill and the cause is not identified, City staff sometimes insist that the water was nevertheless used at the premises. This can be perceived by residents as an insinuation that they are deliberately being untruthful about their water use.
• The City Manager stated that investigations of high water bills involve checking for water main relining work, however water main relining work is often not raised by the City when a customer asks about a high water bill.
• The City cannot conclusively demonstrate that the metered information on which these charges are based is absolutely reliable, yet it requires residents to demonstrate that their charges are incorrect before the City will adjust their bill.

Our Recommendations

Taking into account the results of our investigation, we made seven recommendations, including that:

• Revenue Services develop criteria by which it may identify and address exceptional cases;
• The City amend the Municipal Code so that Revenue Services has the discretion, based on a set of criteria and on a case-by-case basis, to adjust the account of a customer who has experienced a sudden large increase in water consumption not explained by a meter test or leak check;
• The Water Meter Program implement a standard by which it notifies customers of consumption spikes and dips;
• Revenue Services determine at the outset of an enquiry whether there has been area water main relining work and inform the customer of those facts;
• Until the automated system is fully operational, Revenue Services write to the customer after three consecutive bills based on estimates to request a reading.