Its been a year since COVID shutdowns ended for most commercial clients. Looking back at 2020-2021 billing for a Spokane client ? Avista Rate 25. The business was closed March 2020 through June 2020. During closure demand dropped from 220 kW to 18 kW. But Avista continued billing at the ratcheted demand of 176 kW for those four months. The client paid $7,040 in demand charges during a period when the business was closed by government order. Did any utilities waive ratchet provisions during COVID?
Demand billing during COVID ? were shutdowns handled correctly?
Ruth ? Wisconsin utilities were ordered by the PSC to suspend ratchet provisions for commercial accounts documenting COVID-related closures. We Energies, WPS, MG&E, and Alliant all complied. Demand billing reverted to actual metered demand during the closure period. If your Avista account is in Washington, check whether the Washington UTC issued similar orders.
Dorothy ? checking Washington UTC orders now. Finding several emergency orders from March-June 2020 but they focus on disconnection moratoriums and payment plans. Dont see a specific ratchet suspension order for Washington.
Connecticut PURA ordered ratchet suspension for all commercial accounts during the COVID emergency period. Eversource was required to bill actual demand for accounts demonstrating pandemic-related load reduction. The order was retroactive to March 2020. I filed claims for 8 clients and all received demand charge adjustments totaling $112,000.
Oklahoma Corporation Commission did NOT order ratchet suspension. OG&E and PSO continued normal ratchet billing throughout COVID. Several clients complained but the OCC position was that the tariff provisions remained in effect during the emergency. Oklahoma commercial clients had no relief from demand ratchets during shutdowns.
Utah PUC issued a general order allowing utilities to offer COVID bill relief programs but did not mandate ratchet suspension. Rocky Mountain Power voluntarily offered a 3-month ratchet reset for qualifying commercial accounts but required individual applications with documentation. Many clients didnt know the program existed and missed the application window.
Summary of what Ive found: COVID ratchet relief was inconsistent across states. Some PUCs ordered mandatory suspension (Wisconsin, Connecticut). Some utilities offered voluntary programs (Utah, some California utilities). Many states did nothing specific about demand ratchets (Oklahoma, Washington). For any client who was open during COVID but at reduced capacity, its worth checking whether retroactive ratchet relief was available and whether they applied for it.
Ruth has identified an important retrospective audit opportunity. COVID-era demand billing irregularities may still be recoverable depending on the jurisdictions statute of limitations for utility billing disputes. Key actions for auditors: 1) Review 2020-2021 demand billing for all commercial clients 2) Check your state PUC for COVID-specific demand relief orders 3) Identify clients who qualified but didnt apply 4) File retroactive claims where possible. The window for many of these claims is closing as we approach the 2-3 year lookback limit in most jurisdictions. Act quickly on any COVID-related demand claims.