Been auditing church accounts for 4 years and never seen this before. The demand ratchet is being applied at 90% instead of the tariff's 70%. The Schedule GS-1 rate schedule clearly states demand measured at 15-min intervals, but the bill shows 30-min intervals being used.
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Anyone dealt with CPS Energy franchise fees?
Solid analysis. One thing I'd add is to verify the demand measured at 15-min intervals against the original service application.
I'd recommend requesting the meter test records from Kentucky Utilities. That's what cracked my case open.