When I send an LOA to the utility, how many months of billing history should I request? I've been asking for 24 months. Is that enough?
How many months of billing history do you request?
I request 36 months minimum. Here's why: most state refund windows are 2-4 years. If you only have 24 months of data, you can identify the error but you can't quantify the full refund period. With 36 months you can prove the error existed for 3 years and claim the maximum refund in most states. Also, some errors are seasonal — a TOU rate that's wrong only shows up when you compare summer to winter, and 24 months gives you only two summers and one or two winters. 36 months gives you complete seasonal coverage.
Jim W. is right — 36 months is the standard I recommend. Some auditors request 48 or even 60 months, which can be useful if you're in a state with a longer refund window, but most utilities push back on requests beyond 36 months. The practical compromise: request 36 months of billing data and note in your LOA that you reserve the right to request additional history if errors are identified. That gives you the option to go deeper without fighting for 5 years of data up front.
I used to request 24 months and I definitely missed refund dollars because of it. Switched to 36 after reading a similar discussion on here. The extra year of data has paid for itself many times over.
36 months it is. Updating my LOA template today. Thanks everyone.