Working on an audit for a manufacturing facility in Charleston taking service from Appalachian Power. They're currently on Schedule FP secondary service but the facility has two separate 750kVA customer-owned transformers fed from 12.47kV. Monthly demand averages 1,200kW. Appalachian's tariff shows a significant primary discount on both energy and demand charges. Has anyone successfully gotten AEP to reclassify a customer from secondary to primary after the fact? Their customer service rep claims it's not possible without a new service application.
Appalachian Power Secondary vs Primary - Tariff Question
Wanda, that's complete nonsense from AEP. If they're delivering at 12.47kV to customer-owned transformation, that's primary service by definition. The tariff classification should match the actual service delivery. I've forced several utilities to make this correction retroactively. Start with a formal written request citing the specific tariff language for primary voltage service.
Randy's absolutely right. Duke Energy tried the same "new service application" argument with me in Charlotte. The key is documenting that they've been delivering primary voltage all along. Get copies of the electrical service diagrams and metering configuration. Most utilities will correct the classification rather than face a regulatory complaint.
What's the rate differential looking like? Here in Tennessee, TVA primary vs secondary can be $2-3/kW on demand plus 0.5-0.8¢/kWh on energy. At 1,200kW demand that could be substantial monthly savings. Definitely worth pursuing if the numbers are similar.
Dale, the savings would be about $1,800/month - $1.50/kW demand discount plus 0.4¢/kWh energy difference. That's over $21,000 annually so definitely worth the fight. Randy, I've got the electrical drawings showing 12.47kV delivery to customer transformers. Should I start with their regulatory affairs department or stick with customer service?
Always start with a formal written complaint to customer service, copy regulatory affairs. Give them 30 days to respond. If they deny it, escalate to the West Virginia PSC. The beauty is you have 18-24 months of interval data showing primary voltage delivery - that's ironclad evidence they've been misclassifying the account.
Wanda, one thing to check - make sure there's no disconnect switch or other equipment between the utility meter and the customer transformers. Sometimes utilities will claim it's secondary service if there's any utility-owned equipment downstream of their primary lines. Dominion tried that argument with me once.
Bill, good catch. There is a utility-owned disconnect switch between their meter and our transformers. Does that change the classification? The customer still owns and maintains all transformation equipment, they just have a primary disconnect for safety.
The disconnect shouldn't matter - that's standard safety equipment. As long as the customer owns the transformers and takes delivery at primary voltage, it's primary service. The disconnect switch is just an isolation point, not a transformation point. Don't let AEP muddy the waters with that red herring.
Randy's correct about the disconnect. PPL has similar setups throughout Pennsylvania - primary voltage delivery with utility disconnect switches upstream of customer transformers. Still classified as primary service because the customer owns the transformation. The disconnect is just for maintenance and emergency isolation.
Update: sent formal request to AEP yesterday with electrical diagrams and 18 months of metering data. Referenced tariff sections defining primary service voltage and customer-owned transformation requirements. Requesting retroactive billing adjustment and prospective rate correction. Will keep everyone posted on their response.
Great approach Wanda. The documentation package sounds solid. In my experience, AEP is usually reasonable once you present clear evidence and cite specific tariff language. They know it's cheaper to fix the error than fight a regulatory complaint they'll likely lose.
Any update from AEP? Had a similar case with Green Mountain Power up here in Vermont last month. Took them exactly 28 days to approve the reclassification and issue a $31,000 refund check. Sometimes persistence pays off better than we expect.