Working on a client here in Phoenix who's been taking service from APS at 12.47kV for eight years. They're on Schedule E-32 TOU primary rates and own two 1500kVA transformers. APS is now demanding proof of transformer ownership dating back to original installation. The client has the purchase invoices and installation records, but APS wants to see property tax records showing the transformers as customer assets. Is this normal? The rate difference is about $25,000 annually so it's worth fighting for.
APS primary service audit - need advice on transformer ownership documentation
APS has been getting much more aggressive about documentation requirements. They audited three of our clients last year and demanded everything - purchase orders, installation contracts, insurance policies listing the transformers, property tax assessments, and even depreciation schedules from tax returns. It's way beyond what their tariff actually requires. The tariff just says 'customer-owned and maintained' but doesn't specify documentation requirements.
Property tax records are actually good evidence of ownership, but they shouldn't be the only acceptable documentation. I'd push back on APS requiring specific types of records that aren't mentioned in their filed tariff. Purchase invoices, installation contracts, and insurance documentation should be sufficient. If they're being unreasonable, file a complaint with the Arizona Corporation Commission.
We had a similar issue with Alabama Power last year on a Huntsville account. They wanted to see the original purchase order from 2019, but our client had switched accounting systems and the old records were archived. We provided a notarized affidavit from the plant manager confirming ownership along with current insurance policies and maintenance records. Alabama Power accepted it after some back and forth. Don't let them make up requirements that aren't in the tariff.