Working on a CPS Energy water and wastewater audit for a large hotel property here in San Antonio and their rate structure is incredibly complex. They have separate charges for water service, wastewater treatment, drainage fees, and something called "system improvement charges" that seem to change quarterly. The client's monthly bills range from $18,000 to $31,000 depending on occupancy but the rate calculations don't seem to correlate properly with usage. Has anyone successfully audited CPS Energy water accounts? Their tariff documents are over 200 pages and I'm struggling to validate their billing methodology.
CPS Energy water/wastewater audit - complex rate structure nightmare
Angela, I feel your pain on complex municipal rate structures. CPS Energy has one of the most convoluted water billing systems I've encountered. The key is breaking down each component separately rather than trying to validate the total bill. Start with the base water volumetric charges, then tackle wastewater (which is usually calculated as a percentage of water usage), then the various fees. The system improvement charges are based on a separate formula tied to their capital improvement program.
I've audited several CPS Energy accounts and the trick is understanding their tier structure changes seasonally. Summer months (May-September) have different volumetric rates than winter months, and the tier thresholds are based on historical usage averages. For hotels, you also need to factor in their commercial laundry rates if applicable, and swimming pool/landscape irrigation which may be on separate meters with different rate classifications.
Angela, one thing to watch for with CPS Energy is their wastewater strength surcharges. If the hotel has restaurants or food service facilities, they might be getting charged additional fees for high BOD or grease content in their wastewater discharge. These charges often don't appear on the main bill summary but show up in the detail sections. I found $12,000 in incorrect strength surcharges on a resort property that had been going on for 3 years.
Thanks everyone, this is really helpful. Juan, you nailed it on the wastewater strength charges - I found $8,400 in what appears to be incorrect BOD surcharges. The hotel's restaurants have grease interceptors and their discharge should qualify for standard commercial rates, not industrial strength pricing. Albert, the seasonal tier structure explains why I was getting different results - I was using the summer rates for winter months. CPS Energy's customer service has been less than helpful so I may need to file a formal dispute.
Angela, if you end up filing a dispute with CPS Energy, make sure you have all your documentation in order first. Their disputes department is actually pretty thorough but they require detailed supporting calculations and evidence. I've had good success with CPS disputes when the case is well-documented. The key is showing exactly where their billing deviates from their published tariffs. Good luck with the audit - sounds like you're finding some real money for your client.