City of Baltimore
Baltimore City Code

§ 2-17. Office of Water-Customer Advocacy and Appeals – Office established; Nature, purposes; Primary functions.

(a) Office established.

There is an Office of Water-Customer Advocacy and Appeals in the Department of Public Works.

(b) Nature and purposes of Office.

(1) The Office is a neutral intermediary created to promote fairness to customers dealing with water and wastewater billing disputes.

(2) The purposes of the Office are:

(i) to provide a problem-solving resolution process for disputes between customers and the Department of Public Works about water and wastewater billings, assistance under the Water-for-All Discount Program, and assistance under any other Baltimore Water Assistance Programs; and

(ii) to provide guidance on broader rules, regulations, policies, and procedures of the Department that relate to customer issues with water and wastewater billings.

(3) The Office is entitled to the full cooperation and collaboration of the Department of Public Works' staff and contractors, including access to all customer records and the ability to confer with Department leadership, staff, and contractors.

(c) Primary functions.

The Office serves the following three primary functions:

(1) serving as a customer advocate, by conducting problem-solving investigations and implementing solutions, including:

(i) investigating the causes of and solutions to billing disputes between customers and the Department of Public Works, even if the customer has not yet exhausted options for dispute resolution offered by the Department;

(ii) investigating the causes of and solutions to disputes between customers and the Department of Public Works over Water-for-All Discount Program determinations or other Department actions or decisions related to water and wastewater billing, service cut-offs, or lack of notice of billing-related issues;

(iii) connecting customers to complementary social services;

(iv) investigating and improving communications between customers and the Department of Public Works, by investigating whether notices should be in other languages, ensuring that customers receive timely and complete notice of payments due, and ensuring that customers receive timely and complete notice of options for reducing payments under all existing programs; and

(v) adjusting customer bills when warranted;

(2) conducting appeals hearings on request of aggrieved customers after a problem-solving determination has been made; and

(3) reporting at least semi-annually to the Committee for Office Oversight established under § 2-23 {"Office ... - Committee for Office Oversight"} of this subtitle, on:

(i) Office operations and activities, including:

(A) data on the Office's customer-advocacy investigation and problem-solving efforts and its appeals function, as set fort in subsection (d) of this section; and

(B) examples of common customer complaints, the methods by which the Department of Public Works addresses those complaints, an assessment of those methods, and recommendations for alternative approaches; and

(ii) recommendations that the Office has for:

(A) changes to the department's rules, regulations, policies, or procedures that will promote fairness to customers and resolve customer concerns;

(B) task forces and additional Office staff; and

(C) any other options for promoting fairness to customers and resolving customer concerns.

(d) Data and metrics.

(1) Data and metrics shall be used to enable:

(i) an understanding of the problems experienced by customers and by DPW;

(ii) the design of workable solutions; and

(iii) the evaluation of whether reforms implemented are successful.

(2) Significant data shall be collected from individuals participating in the various dispute resolution processes under this subtitle, which will reduce data collection costs and emphasize customers' direct experiences.

(3) Data shall be collected that reveals the nature and frequency of:

(i) customer concerns raised on matters of all kinds;

(ii) methods used by Office Advocates to investigate problems, to assess DPW's responses, and to create solutions promoting customer fairness;

(iii) dispute resolution outcomes and justifications, including bill adjustment dollar amounts, orders regarding enrollment in discount and affordability programs, referrals to social service agencies, complaints left unaddressed, and other outcome es;

(iv) decisions of the Public Works Director that overrule an Office Advocate or the ECB;

(v) communications among billing analysts, the Office, the ECB, and customers;

(vi) data collection efforts;

(vii) customer feedback (from customers both participating in dispute resolution systems and not participating in them);

(viii) ideas solicited from customers about potential causes of problems and potential solutions that would promote customer fairness;

(ix) input from social service organizations that serve customers; and

(x) with respect to discount and affordability programs, application and enrollment numbers compared to the anticipated number of eligible customers, reasons for denials, and the relative success of different outreach methods.

(4) When reporting to the Committee for Office Oversight, the Office shall explain how data derived directly from customer experiences was given great weight in designing reform proposals that promote customer fairness, and shall define metrics to be used to measure the effectiveness of the future reforms. As reforms are implemented, additional data shall be collected to evaluate the effectiveness of the reforms, and the Office shall, as appropriate, propose further improvements to the reforms or to the metrics to be used to assess them.