One of my clients in Memphis has a line item on their MLGW bill called "Infrastructure Recovery Surcharge" — $47.50/month on a $3,200/month commercial account. I cannot find this charge in the MLGW tariff book anywhere. It doesn't correspond to any approved rate rider or surcharge I can identify. The charge appeared about 18 months ago. Is this a legitimate charge or an unauthorized fee?
Mystery line item — "Infrastructure Recovery Surcharge" — is this even legal?
I've seen mystery surcharges like this pop up after utilities do system upgrades or infrastructure repairs and try to pass costs directly to customers outside the normal rate case process. Sometimes these are PUC-approved riders that just aren't well documented in the tariff book yet. Other times they're genuinely unauthorized. Your first step should be to call MLGW's commercial billing department and ask for the tariff authority for that specific line item. They should be able to cite a specific tariff provision, PUC order, or city council resolution that authorizes the charge. If they can't cite one, you've found an unauthorized charge.
Derek's advice is exactly right. Every charge on a regulated utility bill must be authorized by either the tariff, a PUC order, or a municipal ordinance for municipal utilities like MLGW. If the utility cannot point to a specific authorization, the charge is improper. For MLGW specifically, since it's a municipal utility governed by the Memphis city council rather than the Tennessee PUC, the authorization would come from a council resolution or the utility's board. Request a copy of the authorizing resolution. If they produce one, verify that the charge matches what was authorized. If they can't produce one, file a formal complaint with the MLGW board.
I had something similar with a "System Improvement Fee" on a PSO bill in Tulsa. Called and asked for the tariff citation. Turned out it was an approved rider but it was only supposed to apply to residential accounts. It was being applied to my commercial client's account incorrectly. Got 14 months of overcharges refunded. Always ask for the tariff citation — even if the charge is real, it might not apply to your client's account class.
Called MLGW. They said it was authorized by a board resolution in 2012 but couldn't immediately produce the resolution. I asked them to email me a copy. If the resolution doesn't match what's being billed, I'm filing a complaint. Will update.