Finally ready to share this war story now that it's completely resolved. Hospital complex here in San Antonio got switched to TOU-8 rate schedule in 2015 without proper analysis of their load profile. CPS Energy claimed the customer requested it, but I found emails proving their rep recommended it based on faulty assumptions. The peak period charges were killing them - $43K extra per month because their backup generators were cycling during peak hours for testing. Three years of fighting, two rate cases, and one formal complaint later, we recovered $1.87 million. Never again will I trust a utility's "recommendation" without doing my own analysis.
CPS Energy time-of-use nightmare - 3 years to resolve
Angela, hospitals are tricky with TOU rates because of their critical backup systems. I had a similar case with AEP Texas where the customer's emergency generators were creating artificial peak demand during testing. Did you get CPS to acknowledge that their rep gave bad advice or did they fight that angle?
Brenda, they absolutely fought the "bad advice" angle initially. Their position was that customers are responsible for understanding their own rate schedules. But I had email chains showing their account rep specifically saying TOU would save them money based on their "typical commercial profile." The rep never asked about backup generators, medical equipment cycling, or any of the unique hospital load characteristics.
This is exactly why I always recommend load studies before any rate change. Dominion Energy here in Richmond pushes TOU rates hard, but they rarely do proper analysis of whether it actually benefits the customer. Angela, what was your smoking gun evidence that convinced them to settle?
Phil, the breakthrough came when I got their internal rate analysis software and ran the hospital's actual hourly data through it. Their own system showed the customer would pay $38K MORE per month on TOU-8 versus staying on the standard rate. When I presented that in mediation, their attorney's jaw literally dropped. Hard to argue against your own software recommendation.
Angela, how did you get access to their internal rate analysis software? That sounds like it would be proprietary or confidential. I'm dealing with Georgia Power on a similar issue and they claim their analysis tools are trade secrets.
Ray, it took a formal discovery request through the complaint process. CPS initially claimed privilege but the PUC ruled that rate calculation methodologies used for customer recommendations are not proprietary. The key was framing it as "how did you determine this rate was beneficial" rather than asking for trade secrets. Took 8 months but worth the wait.
Outstanding persistence Angela! That's the kind of deep-dive investigation that separates the pros from the amateurs in this business. I'm dealing with MLGW on a similar TOU issue and you've given me some great ideas for discovery requests. Did the hospital end up staying on their original rate or switching to something else?
Randy, they went back to the standard GS-4 rate they were on originally. The irony is that CPS actually has a specialized "Hospital/Medical" rate that would have saved them money, but their rep never mentioned it. Sometimes the best TOU rate is no TOU rate at all. The key lesson is never trust the utility's analysis without doing your own homework.
This thread should be required reading for anyone in this business. Angela, your methodical approach and documentation skills are impressive. I'm just starting out and cases like this show me how much detective work is really involved in major recoveries.
John, Angela's case is a perfect example of why persistence pays off in this business. I've seen too many auditors give up when the utility pushes back on the first challenge. The real money is in the complex cases that take years to resolve. Document everything and never assume the utility is right just because they say so.