Anyone know if Tennessee changed their backbilling rules recently? I'm seeing KUB references to 24-month authority that I don't remember from before 2016. Used to be standard 12-month limit for utility errors under TPUC regulations. Working on a $23,500 case where they claim a meter reading error going back 22 months and want to collect the full amount.
Tennessee backbilling limits - changed in 2016?
Gary, you're right to be suspicious. TPUC did revise Rule 1220-04-04-.17 in late 2016. The 24-month window now applies to 'billing errors discovered through normal utility operations' but the 12-month limit still stands for errors caused by utility equipment failure. Key is proving their meter/CT equipment was defective versus claiming it was just a reading mistake.
I can confirm Terry's info - been dealing with Nashville Electric on this exact issue. The 2016 rule change expanded utility authority but they have to prove it wasn't equipment failure. If the meter was reading incorrectly due to hardware issues, you're still protected by the 12-month limit. Get KUB to document exactly what caused the error.
Perfect, thanks both. KUB is claiming the meter was 'functioning properly' but reading low due to CT phase rotation issues they didn't catch during routine testing. Sounds like equipment failure to me. Going to push them to admit the CTs were improperly installed/maintained and stick with the 12-month rule.
CT phase rotation is definitely equipment/installation error, not a billing mistake. Had Vermont Electric try similar logic last year - they wanted 20 months on a phase sequence problem they should have caught during commissioning. Regulatory staff agreed it was utility equipment failure. Tennessee PUC should rule the same way.