Several Nashville Electric Service accounts I manage started showing a "System Infrastructure Fee" of $2.50 per month on residential accounts and $8.75 on small commercial accounts in January. This fee isn't mentioned anywhere in NES rate schedules and there was no public notice. Called NES billing and they claim it's for "system modernization" but can't cite any authority. Anyone else seeing similar fees from TVA distributors?
TVA distributors sneaking in "system upgrade" fees
Holly, Nashville Electric is not alone. I'm seeing a "Grid Modernization Charge" on Knoxville Utilities Board bills starting in December 2019. Same story - no tariff filing, no public notice. KUB claims it's approved under their "miscellaneous charges" authority but that seems like a stretch for what amounts to a general rate increase.
Ed's right about KUB. I filed a complaint with Tennessee Regulatory Authority arguing that any ongoing monthly fee for system improvements is essentially a rate increase that requires full regulatory review. TRA agreed and ordered KUB to suspend the charge pending a formal rate case. You might want to file similar complaints for NES.
Walt P, that's excellent news about TRA's ruling on KUB. Do you have the TRA order number? I'd like to reference it in complaints against NES. This feels like multiple TVA distributors coordinated this fee rollout thinking they could slip it past regulators.
TRA Order 20-00047 issued February 10, 2020. The key finding was that any recurring charge for capital improvements must be reviewed through formal rate proceedings, not implemented under general tariff authority. Should be good precedent for other TVA distributors trying the same thing.
Seeing similar issues with Memphis Light Gas & Water. They added a $4.25 monthly "Infrastructure Investment Fee" in November 2019 with zero public notice. Filed complaints with city council since MLGW is city-owned. The fee supposedly funds smart meter deployment but there's no breakdown of actual costs or timeline.
Terry, Memphis doing the same thing confirms this is coordinated across multiple TVA distributors. I've drafted formal complaints to TRA for NES using Walt's precedent order. The timing is too coincidental - all these fees started appearing within 2-3 months of each other.
Update on KUB situation: they've suspended the grid modernization charge and are providing refunds back to December. TRA is requiring them to file a formal rate case if they want to recover infrastructure costs through customer charges. Big win for ratepayers.
Ed, that's fantastic. I referenced your KUB victory in my TRA complaint against NES. Also sent copies to several other auditors dealing with TVA distributors. This coordinated fee rollout is exactly why we need to share information and strategies.
Following this thread with interest from Wisconsin. We don't have TVA up here but this coordinated fee strategy could spread to other utility holding companies. Documenting everything for potential future reference with WE Energies and Wisconsin Public Service.
Final update: TRA ruled in my favor on NES. They've ordered suspension of the system infrastructure fee and refunds to all affected customers. Thanks to everyone who shared information and strategies. This forum collaboration saved thousands of customers from unauthorized charges.
Holly, congratulations on the TRA victory. Between KUB and NES rulings, we've established solid precedent against these sneaky infrastructure fees. Other TVA distributors will think twice before trying similar schemes.