07/27/2026
March 21, 2026
Subject: Sunshine Law Request – Billing Calculation Records (Clarification and Follow-Up)
Hello,
This is a request for public records under the Missouri Sunshine Law, Chapter 610, RSMo.
This request follows my prior Sunshine request dated January 26, 2026, and two prior informal requests (January 10 and January 15, 2026), which sought records describing how meter readings are converted into billed usage. The district’s response provided summary reports but did not include records describing the calculation logic or procedures used to generate billed gallons.
Since that time, ongoing meter tracking continues to show a consistent and measurable discrepancy between recorded usage and billed usage. For example, as of March 21, 2026 (five days into the current billing cycle), the company meter reflects 208.658 gallons while a parallel meter records 201.2 gallons, a difference of 7.458 gallons (+3.707%). The cumulative discrepancy since April 2025 is now +2.27%. This reinforces the need to obtain the records governing how raw meter data is processed into billed consumption.
Based on sustained, long-term comparative tracking, the observed discrepancy does not appear to be attributable to a single meter malfunction. Rather, the pattern suggests a consistent difference in how usage is calculated, processed, or aggregated prior to billing. This behavior has only become apparent through extended, side-by-side measurement over time and is not detectable from a single billing cycle or isolated reading. Accordingly, I am not requesting a meter test or replacement at this time.
I am requesting existing records only and am not requesting the creation of new records or explanations.
Please provide electronic copies (PDF or native format) of the following existing records:
1. Billing Calculation Rules (Meter → Bill)
Any existing records that define, govern, or describe how meter readings are converted into billed gallons, including but not limited to:
• rounding or truncation rules and the stage at which they are applied (interval, daily, or billing);
• minimum billing increments or resolution differences between recorded and billed usage;
• whether displayed interval usage reflects stored values or display-only rounding;
• any calculation logic, formulas, or system rules used in the billing process.
2. Billing Calculation Record / Audit Trail (Specific Billing Cycle)
For the billing cycle 12/15/2025–01/15/2026, any existing records used to generate billed usage for my account (Account #: 4444), including:
• starting and ending meter readings used for billing;
• total billed gallons;
• any intermediate calculation records, billing worksheets, system-generated calculation summaries, or audit trail records;
• any CIS, AMI, or MDMS screen outputs, exports, or reports that show how billed usage was derived from meter data.
3. System Configuration Records (If Applicable)
Any existing records reflecting configuration settings that affect billing calculations, including:
• AMI/AMR or MDMS configuration settings related to usage calculation;
• pulse resolution or unit conversion settings (e.g., gallons per pulse);
• aggregation intervals or data processing intervals used prior to billing.
4. Vendor-Related Records (If Applicable)
If billing calculations are performed or governed by third-party software or systems, please provide:
• any records in the district’s possession describing system functionality, calculation behavior, or configuration options;
• user manuals, system documentation, or configuration guides relied upon by the district;
• the name of the vendor(s) providing such systems.
Clarification Requirement
If no records exist that are responsive to any of the above items, please state that explicitly in writing.
If the district does not maintain billing calculation records, please clarify whether:
a) billing calculations are determined by third-party software or vendor systems;
b) the district has access to configuration settings governing billing calculations; and
c) any such records are maintained by a contractor or vendor on behalf of the district.
Delivery and Costs
Please provide records electronically by email.
If any fees are anticipated, please provide a written, itemized cost estimate (including hourly rate and estimated time) prior to fulfilling the request. I am requesting the minimum necessary search and duplication costs.
Custodian
If this request should be directed to a different records custodian, please forward it and confirm to whom it was forwarded.
For clarity, summary or output reports (e.g., usage reports, transaction summaries, or meter read reports) are not responsive to this request unless they contain or reflect the underlying calculation rules, configuration settings, or audit-level detail used to derive billed usage.
Thank you,
Jennifer Minor
Date: March 30, 2026
Event Type: Sunshine Law Response – Cost Estimate / Partial Compliance
Subject: Billing Calculation Records Request (Clarification and Follow-Up)
Event Description:
PWSD #3 issued a formal response to the March 21, 2026 Sunshine Law request seeking records related to billing calculation logic, system configuration, and audit trail documentation.
Instead of providing any responsive records, the district issued a $50.00 cost estimate, stating that the fee includes a copy of the “Continental Billing System for Microsoft Windows” getting started manual. The district further required prepayment of $25.00 before proceeding and indicated that a final bill would be adjusted after compilation.
Key Details:
• No billing calculation records, configuration records, or audit trail documentation were provided with the response
• No statement was made indicating whether responsive records exist or do not exist
• No itemized breakdown of time or cost was included
• The only identified material was a vendor “getting started” manual, not specific to district billing practices or configurations
• Production of records was made contingent on partial upfront payment
Context:
This response follows:
• A detailed Sunshine request explicitly seeking existing records only
• Prior district responses that substituted summary reports instead of calculation documentation
• A clear request requiring the district to state explicitly if no records exist
The request specifically excluded generic or non-responsive materials unless they reflected actual billing logic, configuration, or calculation methodology.
Analysis / Significance:
This response introduces several critical concerns:
1. Non-Responsive Substitution
The district identified a general vendor manual rather than records describing how billing calculations are performed within their system.
2. Failure to Address Record Existence
The district did not confirm whether requested records:
o exist
o do not exist
o or are maintained by a third party
3. Barrier to Access
The requirement for prepayment prior to identifying responsive records introduces a barrier to verifying whether relevant documentation exists.
4. Lack of Itemization
The cost estimate was not accompanied by a breakdown of:
o time required
o search scope
o specific tasks
5. Continued Lack of Transparency
The response does not clarify how meter readings are converted into billed usage, despite repeated requests and documented discrepancies.
Strategic Note:
This event strengthens the documented pattern that:
The district has not provided records sufficient to explain or verify how billed usage is calculated.
