Bluestem Telephone Co. v. Kansas Corporation Comm'n

CourtCourt of Appeals of Kansas
DecidedMay 13, 2016
Docket114639
StatusUnpublished

This text of Bluestem Telephone Co. v. Kansas Corporation Comm'n (Bluestem Telephone Co. v. Kansas Corporation Comm'n) is published on Counsel Stack Legal Research, covering Court of Appeals of Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bluestem Telephone Co. v. Kansas Corporation Comm'n, (kanctapp 2016).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 114,639

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

BLUESTEM TELEPHONE COMPANY, et al., Appellants,

v.

KANSAS CORPORATION COMMISSION, Appellee,

MEMORANDUM OPINION

Appeal from Nemaha District Court; JAMES A. PATTON, judge. Opinion filed May 13, 2016. Appeal dismissed.

Thomas E. Gleason, Jr., of Gleason & Doty, Chartered, of Lawrence, Colleen R. Jamison, of James M. Caplinger, Chartered, of Topeka, and Mark E. Caplinger, of Mark E. Caplinger, P.A. of Topeka, for appellants.

Brian G. Fedotin, deputy general counsel and chief appellate counsel, of Kansas Corporation Commission, for appellee.

Before MALONE, C.J., BUSER and BRUNS, JJ.

Per Curiam: To keep telephone rates in rural areas reasonably comparable to rates in more competitive urban markets, the Kansas Corporation Commission (KCC) established the Kansas Universal Service Fund (KUSF), from which funds are distributed to subsidize local telephone companies' actual costs of providing universal service when rural rates are insufficient to cover them. In 2013, the Kansas Legislature passed a bill that created a $30 million cap on KUSF distribution to companies that operate under rate- of-return regulation. After receiving inquiries regarding potential effects of the 1 legislation, the KCC opened a general investigative docket, identifying two proposed implementation strategies and soliciting comments and alternative suggestions. A group of several rural local exchange carriers (the RLECs, now appellants) entered appearances and filed comments suggesting that neither proposed strategy was acceptable. The KCC ultimately issued an order determining that when the cap was reached, the KCC would proportionately reduce the companies' KUSF support based on the amount of support they would have received absent the cap.

The RLECs filed a petition for judicial review. After receiving written and oral arguments from the parties, the district court denied the RLECs' petition, finding that their complaints did not merit setting aside the KCC order. The RLECs timely appealed to this court, arguing (1) the district court erred in finding that the KCC's chosen strategy did not violate the statutory requirement that rate-of-return carriers have the right to recover costs from the KUSF; (2) the district court erred in finding that it was permissible for the KCC to issue its order without first holding an evidentiary hearing; and (3) the district court erred by suggesting that the RLECs seek legislative clarification or amendment of the statute at issue.

After briefing was completed, this court ordered the parties to show cause why the appeal should not be dismissed for lack of justiciability, as it appears the case is not ripe for judicial review. After reviewing the parties' responses and considering their oral arguments, we conclude that this case is not ripe for adjudication for reasons set forth in this opinion. Moreover, we note that this appeal will be rendered moot when a new statute passed by the 2016 Kansas Legislature and signed by the governor becomes effective on July 1, 2016. Thus, we dismiss the RLECs' appeal.

2 FACTUAL AND PROCEDURAL BACKGROUND

In 1996, Congress passed the Telecommunications Act of 1996 (the Act) to further deregulate the telecommunications industry. Congress wanted to (1) ensure "universal service" to low-income consumers and those in high-cost areas and (2) promote competition in all markets. See Bluestem Telephone Co. v. Kansas Corporation Comm'n, 52 Kan. App. 2d 96, 98, 363 P.3d 1115 (2015). The Act required the federal government to create universal service funds to ensure that consumers in high-cost areas were offered rates reasonably comparable to those offered in more competitive markets. 52 Kan. App. 2d at 98. Under the Act, states could adopt their own mechanisms for universal intrastate service as long as those mechanisms were not inconsistent with federal law.

In response to the Act, Kansas passed the Kansas Telecommunications Act (KTA). 52 Kan. App. 2d at 98. The KTA required local telephone companies, also called local exchange carriers, to reduce their rates for intrastate access to a level equal or close to the rates for interstate access, which led to falling long-distance rates but higher local costs. 52 Kan. App. 2d at 99. Rates in more rural areas were required to be reasonably comparable to rates in more competitive urban markets, but sometimes the rural rates were then insufficient to cover the telephone companies' actual costs of providing the universal service the KTA and the Act required. Accordingly, the KCC established the KUSF to subsidize local telephone companies and keep local rates from increasing to an unaffordable level. 52 Kan. App. 2d at 99. When rural rates are insufficient to cover telephone companies' actual prudent costs of providing the universal service the KTA and the Act required, the fund administrator distributes KUSF funds to the companies. 52 Kan. App. 2d at 99.

Kansas statutes required Kansas local telephone companies to file with the KCC, between January 1, 1997, and January 1, 1998, a network infrastructure plan and a regulatory reform plan. See K.S.A. 2015 Supp. 66-2005(a) and (b). In its regulatory

3 reform plan, each local telephone company "elect[ed] traditional rate of return regulation or price cap regulation." K.S.A. 2015 Supp. 66-2005(b). Under rate-of-return regulation, which is based on cost, telephone companies "can charge rates no higher than necessary to obtain 'sufficient revenue to cover their costs and achieve a fair return on equity.' [Citation omitted.]" See National Rural Telecom Ass'n v. F.C.C., 988 F.2d 174, 177-78 (D.C. Cir. 1993). On the other hand, in price cap regulation, "the regulator sets a maximum price, and the firm selects rates at or below the cap." 988 F.2d at 178. Subject to certain conditions, both rate-of-return companies and price cap companies may receive monetary support from the KUSF. See K.S.A. 2015 Supp. 66-2008(c)(1), (e)(1).

K.S.A. 2015 Supp. 66-2008(e)(1) addresses the calculation of a company's eligibility for KUSF support, stating: "For each local exchange carrier electing . . . to operate under traditional rate of return regulation, all KUSF support, including any adjustment thereto pursuant to this section shall be based on such carrier's embedded costs, revenue requirements, investments and expenses." According to the KCC's arguments before the district court, KUSF support is calculated annually for the following year and funds are allocated to qualifying carriers in monthly installments. See K.S.A. 2015 Supp. 66-2009(b). Although statutorily the monthly installments are meant to be equal amounts, payment amounts may change based upon periodic audits conducted by the KCC or if the carrier applies for and is granted additional funds. See K.S.A. 2015 Supp. 66-2009(b).

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