I've got a client in Cleveland who's been billed on Schedule D for three years, but I'm convinced they should be on Schedule E based on their load profile. The demand charges alone would save them about $1,800 monthly. Problem is FirstEnergy is being stubborn and claiming the customer's secondary voltage disqualifies them. Has anyone successfully challenged their voltage classification criteria? Their tariff language seems deliberately vague on this point.
Anyone dealt with FirstEnergy's Schedule D vs Schedule E nightmare?
Frank, I've seen this exact issue with Ohio Edison (FirstEnergy subsidiary). The voltage thing is often a red herring. What's the customer's actual service voltage and what's their monthly peak demand? If they're taking service at 4kV or higher and hitting consistent demand above 300kW, Schedule E should definitely be on the table. The key is proving the service characteristics meet the tariff requirements regardless of how they want to interpret "secondary."
Had a similar fight with Georgia Power last year. They love to keep customers on the higher-cost schedules when there's any ambiguity. Document everything about the service setup - transformer ownership, metering configuration, actual voltage measurements. If you can prove the physical infrastructure meets Schedule E requirements, their billing classification becomes irrelevant. Fight it hard - $1,800 monthly adds up fast.
Jim, client is served at 4.16kV with customer-owned transformers, monthly demand averaging 425kW. Should be a slam dunk for Schedule E but FirstEnergy keeps citing some internal policy about "billing precedent." Derek, good point about documentation - I've got photos of the service setup and three years of interval data. Thinking about escalating to PUCO if they don't budge soon.
Frank, "billing precedent" is utility-speak for "we've been screwing this customer for years and don't want to admit it." I'd file the PUCO complaint sooner rather than later. Duke Energy tried similar games with a Charlotte client until the commission got involved. Once regulators start asking questions, utilities suddenly become much more reasonable about tariff interpretations. Your client's service characteristics clearly qualify for Schedule E.
I've dealt with this exact scenario with PECO (another FirstEnergy company). The voltage classification games are their go-to move when they want to keep a customer on higher rates. File a formal complaint citing tariff sections 2.3.1 and 2.3.2 - those spell out the actual service requirements pretty clearly. Also demand copies of their internal billing guidelines. Sometimes what they're doing doesn't even match their own procedures.
This is why I love working in LG&E territory - their tariffs are actually readable! But seriously, Frank, Phil's right about demanding their internal procedures. I caught Kentucky Power doing something similar by proving their own billing department was ignoring corporate policy. Got a $47K refund when they finally admitted the error. Don't let them hide behind "precedent" when their tariff clearly states otherwise.
Update: Filed the PUCO complaint yesterday. FirstEnergy's response is due in 30 days. Phil, great call on the internal procedures request - I'm adding that to my complaint amendment. Jack, you're lucky with LG&E! FirstEnergy's tariffs read like they were written by lawyers trying to confuse people. Will keep everyone posted on how this develops.
Frank, I'll be watching this one closely. TVA has been pulling similar stunts with some of our industrial schedules here in Knoxville. If PUCO rules in your favor, it could set precedent for other FirstEnergy territories. The utility industry seems to think tariff interpretation is optional these days. Keep fighting the good fight!
Following this thread with interest. Dominion has tried similar games here in Virginia, though they usually back down when you threaten SCC involvement. Frank, any chance you can share the PUCO complaint number once it's public? These cases create great reference material for future disputes. The more precedent we can build, the harder it gets for utilities to play these classification games.
Phil from Richmond - absolutely right about precedent value. I keep a database of all successful tariff challenges by utility and issue type. Frank, once this resolves I'd love to add your case details to the collection. These utilities count on us not sharing information, but when we do, patterns emerge that make future fights much easier. Solidarity through documentation!