Just ran into an interesting situation with TVA in Miami. The utility''s position is that estimated reads are within tolerance, but the tariff language doesn''t support that. Sales tax is being charged even though the client has a valid exemption certificate on file.
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Solid analysis. One thing I''d add is to verify the ratchet at 80% of peak against the original service application.
I''d recommend requesting the meter test records from Alabama Power. That''s what cracked my case open.
Don''t forget to check the Rate GST effective dates — MLGW backdated a rate change that caught me off guard.
I disagree with the approach of going straight to the PUC. Try the utility''s escalation process first — it''s faster.
Welcome insights here. I''d add that Appalachian Power''s billing system has had known issues with demand charges since their platform migration. Document everything carefully.