Found a systematic error in Southwest Gas baseline calculations for large commercial accounts on Schedule G-41 in the Phoenix area. They're using a 12-month rolling average that includes abnormally high usage from a equipment malfunction period in 2017, inflating baseline by about 30%. This affects the tier pricing structure and is costing my client an extra $2,800 per month in higher-tier charges. The tariff says they should exclude 'abnormal usage periods' when calculating baseline, but their billing system apparently doesn't flag these automatically. Anyone dealt with Southwest Gas baseline adjustment requests before?
Southwest Gas Phoenix Tariff Schedule G-41 Summer Baseline Calculation Error
Kim, I've fought this same battle with Southwest Gas on G-41 accounts. The key is getting them to acknowledge what constitutes 'abnormal usage.' In Arizona, if usage exceeds 150% of the previous year's average for the same billing period, it should be excluded from baseline calculations. You need to file a formal baseline adjustment request with supporting documentation showing the equipment malfunction. I had success getting 18 months of charges corrected for a hotel client in Scottsdale. Took about 4 months to resolve but got back $47,000 in overcharges.
Here in Dallas we see similar issues with Atmos Energy on their large commercial rates. The trick is proving the malfunction wasn't due to customer negligence. Southwest Gas will try to claim equipment failures are the customer's responsibility and shouldn't be excluded from baseline. You need maintenance records showing the malfunction was sudden and unforeseeable, not gradual deterioration. Also helpful if you can show the customer took immediate action to fix it once discovered.
Thanks Sarah and Marcus. I have all the maintenance records showing a sudden boiler control failure that wasn't detected for six weeks due to a faulty sensor. Usage jumped from typical 15,000 therms/month to over 45,000 therms during that period. Customer fixed it immediately once discovered and usage returned to normal. Sounds like I have a solid case for baseline adjustment. Sarah, did your hotel client have to pay any fees for the adjustment review, or did Southwest Gas absorb the administrative costs?
Southwest Gas didn't charge any fees for the baseline review, but they did require a certified engineer's report confirming the equipment failure timeline. Cost about $1,200 for the engineering analysis, but well worth it for $47K in recovered overcharges. Your case sounds even stronger with the sensor failure documentation. Just be prepared for them to take their sweet time reviewing it. They have 90 days under the tariff but usually stretch it to the full period.