My client in Pennsylvania has been on PPL's Rate Schedule LP-4 for at least 8 years. Just discovered that PPL eliminated LP-4 in their 2019 rate case and migrated everyone to LP-5. But the migration changed the rate structure — LP-4 had a declining block energy charge while LP-5 is a flat rate. My client's high usage meant the declining block was significantly cheaper. They've been overpaying by about $3,200/month since the migration. Is there anything I can do or is this just a legitimate rate increase?
Tariff update just eliminated my client's rate class
When a utility eliminates a rate schedule during a rate case, the PUC approves a transition plan. Check the PUC order for the rate case — it should specify how existing LP-4 customers were supposed to be transitioned. Sometimes there's a grandfathering provision that lets existing customers stay on the old rate structure for a period. Other times there's a transition credit to phase in the increase. If PPL was supposed to provide a transition mechanism and didn't, that's an error in how the rate case order was implemented, not just a rate increase.
Phil is exactly right. Rate case orders almost always include transition provisions when a rate class is eliminated. Pull the PUC order — it's available on the Pennsylvania PUC's docket search. Look for language about "transition," "grandfathering," or "migration credits" for customers moving from LP-4 to LP-5. If the order included a transition credit and PPL didn't apply it, that's a billing error with a potentially large refund. Also check whether LP-5 was truly the most favorable available rate for your client. The rate case may have created a new schedule that would be more advantageous than either the old LP-4 or the new LP-5.
I went through this with a National Grid customer in upstate New York when they eliminated SC-3A. The PUC order included a 3-year phase-in credit that National Grid never applied. Recovered $41,000 for the client. The PUC order is absolutely the document you need.
Found the PUC order. There IS a transition credit for LP-4 to LP-5 customers — a declining credit over 36 months. PPL never applied it. Three years of credits at roughly $2,000/month in the first year declining from there. This is going to be a major recovery. Thank you all.