Electronics manufacturer in Riverside got denied for SCE's manufacturing rate discount. They claim client doesn't qualify because some operations are assembly rather than true manufacturing. Plant does circuit board assembly and testing. Anyone dealt with this before?
SCE manufacturing exemption denied - help!
California's manufacturing definition is pretty broad. Circuit board assembly usually qualifies if there's actual physical transformation of components. Check the CPUC manufacturing rate eligibility rules - they're detailed.
Had same issue with SDG&E and aerospace parts manufacturer. Key was showing that assembly process creates new products with different characteristics than input materials. Filed appeal and won.
Document the manufacturing process step by step. Show how raw components get transformed into finished products. NAICS code classification can help support the manufacturing designation. Don't give up on first denial.