Submitted an LOA to Tucson Water for a strip mall client and they flat out refused it. Said they don't accept third-party authorizations for commercial accounts. The customer service supervisor confirmed it's their policy. The client called themselves and was told they can request their own records but can't designate a third party. Is this even legal? How do I get the data?
Using FOIA requests when a utility refuses your LOA entirely
Tucson Water is a city department so they're subject to Arizona public records laws. Have the client submit a public records request for their own account data. Arizona Revised Statutes 39-121 gives the public access to government records. The client's own billing records aren't exempt. I've used this approach with Phoenix water department too. They can't refuse a public records request the way they can refuse an LOA. The client makes the request, gets the records, and hands them to you.
Sarah's right about the public records angle. I've also had success in Arizona by going up the chain at the utility. Sometimes the front-line policy doesn't reflect what management is willing to do. I called Tucson Electric Power about an LOA issue once and the customer service rep said no. I asked for the commercial accounts manager, explained what I was doing, and she processed it personally. Municipal water departments tend to be more rigid than IOUs but it's always worth escalating.
The public records approach is your strongest tool for municipal utilities that refuse third-party authorizations. The client is requesting their own records from a government entity — there is no legal basis to refuse that. Once the client has the records they can share them with whoever they choose. Keep this strategy in your toolkit for any municipal utility that gives you trouble. It works in every state that has open records laws, which is all of them.