Working on a major account in Santa Clarita and discovered serious calculation errors in SCE's Wildfire Mitigation Plan Cost Recovery surcharge. They're charging $0.02847/kWh under tariff schedule TOU-8-CPP but the supporting CPUC filing shows the approved rate should be $0.02234/kWh. That's a 27% overcharge that's been running since October 2023. Anyone else caught SCE making "mistakes" on their wildfire surcharges? This affects every commercial customer in their high fire risk areas.
SoCal Edison wildfire mitigation surcharge calculation errors
Gordon, PG&E pulled similar garbage with their wildfire fund surcharge last year. They were using outdated rate calculations and overcharging customers by millions. The problem is these wildfire surcharges are so new that nobody's watching them closely. I caught PG&E including executive bonuses in their "wildfire mitigation costs" - apparently CEO compensation counts as fire prevention now. File a complaint with CPUC and demand full accounting of every dollar in their surcharge calculation.
This is happening nationwide with utility wildfire and extreme weather surcharges. Here in Washington, Avista tried to include shareholder insurance costs in their wildfire recovery mechanism. The utilities are using these "emergency" surcharges to recover costs that should come from shareholders, not ratepayers. Gordon, check if SCE is properly separating prudent wildfire mitigation costs from general system maintenance. Often they lump everything together.
Great catch Gordon! These wildfire surcharges are the new frontier for utility cost recovery abuse. They wrap everything in "public safety" language but it's often just rate increases by another name. Here in Memphis we don't have wildfire issues but MLGW is pushing similar "resilience" surcharges for storm hardening. The key is demanding granular project-level accounting and proving the costs are actually incremental to normal operations.
Update: Filed CPUC complaint A.24-01-012 and got immediate response from SCE. Turns out their billing system was using Q3 2023 surcharge rates instead of the updated Q4 rates approved in November. Classic utility "computer error" that always seems to benefit them, never the customer. They're providing refund credits totaling $18,400 across my client portfolio. Always verify the actual approved rates against what's being billed.
Excellent work Gordon! I'm dealing with similar billing system "errors" with Dominion Energy here in Virginia. Their Grid Transformation surcharge has been using wrong rate schedules for months. These utilities have sophisticated billing systems that can handle complex time-of-use rates but somehow can't get simple surcharge calculations right. It's suspicious how these errors always overcharge customers, never undercharge them.
Marcus hits the nail on the head - these "computer errors" are awfully convenient for utilities. I've never seen a billing error that undercharged customers for surcharges, have you? Gordon, your success with SCE gives me ammunition for my ongoing PG&E case. I'm going to demand they audit their entire wildfire surcharge billing for the past year. If there are systematic errors, the refunds could be massive.
This thread is why I love this forum! Florida doesn't have wildfire issues but FPL has similar "storm protection" surcharges that are constantly miscalculated. The pattern is always the same - complex rate structures that hide overcharges, billing system "errors" that favor the utility, and refunds only after customers complain. I'm adding surcharge rate verification to my standard audit checklist now.
Mike's smart to add this to his audit checklist. Here in Wisconsin, WEC Energy has multiple environmental and infrastructure surcharges that change quarterly. I created a spreadsheet tracking approved vs. billed rates for all major surcharges. Found $6,200 in overcharges last year just from rate calculation errors. The utilities bank on customers not cross-checking their tariff filings against actual bills.
Paul, would you share that spreadsheet template? I'm thinking we need a standardized approach for tracking surcharge rates across different utilities. The regulatory filings are all public record but buried in hundreds of pages of CPUC/PSC documents. If we could create a database of approved rates, it would make these overcharge audits much more efficient.
That's a brilliant idea Gordon. A collaborative database tracking utility surcharge rates would be incredibly valuable. Most of us are probably checking the same utilities and finding similar errors. If we could pool our research, we'd catch these overcharges much faster. Sarah in Washington PSC, Randy with Tennessee utilities, Paul in Wisconsin - we could cover most of the major markets.
Count me in for a surcharge tracking initiative. MLGW and TVA have several adjustment mechanisms that are ripe for calculation errors. The challenge is keeping up with quarterly rate changes across dozens of utilities, but that's exactly why we need to collaborate. If Gordon can lead this effort, I'll contribute Tennessee regulatory data and help with the database structure.
This could be game-changing for our industry. PG&E alone has eight different surcharges and adjustment clauses that change at different intervals. Tracking them manually is a nightmare, but a shared database would make it manageable. Gordon, if you set up a collaboration platform, I'll contribute California CPUC data and help with ongoing maintenance. This could save our clients millions in overcharges.
Absolutely in for this project! Dominion Energy Virginia has been expanding their rider portfolio every year - transmission, distribution, renewable energy, grid modernization, you name it. Having a central database to verify approved rates would streamline my audit process tremendously. Gordon, let me know what format you need for the Virginia PSC data. This collaboration could revolutionize how we approach surcharge audits.