Client’s monthly bills showed stable peak demand. Once we obtained the 15-minute data we found a single 30-minute spike each month caused by simultaneous compressor startups. That spike was setting the billing demand and, on this tariff, a 11-month ratchet. Correcting the control sequence dropped the ratchet exposure by roughly $1,400 per month. Interval data is no longer optional on any account with a demand or ratchet component. How are others structuring the LOA language so the interval extract arrives with the billing history instead of as a second request?