Commonwealth Edison v. Illinois Property Tax Appeal Board

CourtAppellate Court of Illinois
DecidedJanuary 8, 2008
Docket2-06-0338 Rel
StatusPublished

This text of Commonwealth Edison v. Illinois Property Tax Appeal Board (Commonwealth Edison v. Illinois Property Tax Appeal Board) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth Edison v. Illinois Property Tax Appeal Board, (Ill. Ct. App. 2008).

Opinion

No. 2--06--0338 Filed: 1-8-08 ______________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

SECOND DISTRICT ______________________________________________________________________________

COMMONWEALTH EDISON COMPANY, ) Petition for review of an order of the ) Illinois Property Tax Appeal Board. Petitioner, ) ) v. ) PTAB Nos. 03--01740.001--C--3 through ) 03--01740.017--C--3 ILLINOIS PROPERTY TAX APPEAL ) 04--00658.001--C--3 through BOARD, ) 04--00658.017--C--3 ) Respondent ) ) (The Kane County Board of Review, ) Respondent). ) ______________________________________________________________________________

JUSTICE O'MALLEY delivered the opinion of the court:

Petitioner, Commonwealth Edison Company (ComEd), appeals the decision of respondent,

the Illinois Property Tax Appeal Board (PTAB), denying ComEd's consolidated appeals from the

property tax assessments for ComEd's Aurora Township segment of the Electric Junction to

Waterman issued by respondent, the Kane County Board of Review (Board of Review), for the 2003

and 2004 tax years. ComEd contends that PTAB used an improper method of valuation for the

subject property. We affirm.

The subject property consists of 20 parcels of land with 17 property identification numbers.

The parcels are generally narrow corridors of land averaging about 175 feet in width. Across the land

are evenly spaced pairs of towers used to suspend high-voltage tension wires. Each pair of towers No. 2--06--0338

is set about 300 feet from the next, and the towers and power lines are placed in the approximate

middle of the narrow corridor. The subject property totals just less than 107 acres. The subject

property is commonly known as the Aurora Township segment of the Electric Junction to Waterman

and comprises a part of ComEd's electrical transmission network or grid.

On April 13, 2004, ComEd filed a tax appeal for the 2003 tax year, seeking a reduction in the

property tax assessments for the subject property. The assessor had valued the subject property at

$1,351,054. The Board of Review had adjusted the assessment to $537,327. In its tax appeal,

ComEd asserted that the valuation of the subject property should have totaled $47,640, based on the

historic cost of the various parcels comprising the subject property.

ComEd premised its tax appeal on the idea that the subject property is owned by a regulated

utility. ComEd contended that the correct method for determining the fair market value of the subject

property was its historic cost. ComEd justified its contention by reasoning that no investor would

be willing to pay more for a property than the rate of return that the investor could earn would

support. According to ComEd, using the historic cost to determine the fair market value of the

property is appropriate because ComEd's rate of return is limited by regulation to an amount based

on the historic cost of the property, and because the property is highly specialized and is not the type

of property that is bought and sold on the open market.

The Board of Review asserted that any sale of the subject property was no longer regulated

following the enactment of the Electric Service Customer Choice and Rate Relief Law of 1997

(Customer Choice Law) (220 ILCS 5/16--101 et seq. (West 2004)) and pursuant to section 7--102(e)

of the Public Utilities Act (Act) (220 ILCS 5/7--102(e) (West 2004)), because the subject property

did not meet the threshold sales price of $5 million, which would require the approval of the Illinois

-2- No. 2--06--0338

Commerce Commission (ICC). From this, the Board of Review reasoned that the deregulation of

the sale of that type of property (valued at less than $5 million) invalidated the legal rationale for an

historic-cost assessment to determine the fair market value of the property.

Countering the Board of Review's position, ComEd maintained that the sale of the subject

property would nevertheless continue to be regulated. ComEd reasoned that a sale of the subject

property or a portion of it would disrupt the transmission and distribution network. According to

ComEd, the ICC would continue to oversee any proposed sale. Because the ICC also continued to

set rates based on the historic or original costs of the property and the infrastructure of the

transmission and distribution network, ComEd concluded that valuing the subject property using the

historic cost was still mandated.

During the pendency of the appeal of the 2003 tax year assessment, ComEd filed another

appeal, this time for tax year 2004. The Board of Review had refused to further adjust the assessed

valuation of the subject property, and ComEd raised substantially the same contentions as it had in

its appeal of the 2003 valuation.

On September 26, 2005, the PTAB conducted a consolidated administrative hearing on both

of ComEd's pending tax appeals. Dr. Karl McDermott testified for ComEd. McDermott was

employed as a vice president with National Economic Research Associates (NERA). With NERA,

McDermott directed studies of energy utilities, both nationally and internationally, and had

participated in numerous rate cases throughout the country, both for ComEd and for other utilities.

From 1992 to 1998, before taking employment with NERA, McDermott served as a commissioner

with the ICC. While a commissioner, McDermott's duties included determining the rates that various

utilities in Illinois could charge their customers. Also during his term as a commissioner, McDermott

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was significantly involved in the creation and implementation of the Customer Choice Law. Before

becoming a commissioner with the ICC, McDermott served as president of the Center for Regulatory

Studies, a nonprofit organization that evolved from the revision of the Act. McDermott testified that

he was involved in the revision of the Act. Before his tenure with the Center for Regulatory Studies,

McDermott was a staff employee of the ICC and a researcher for the National Regulatory Research

Institute. McDermott's academic credentials were concentrated in the field of regulatory affairs.

McDermott testified that the ICC was the agency charged with the responsibility of regulating

public utilities. With the passage of the Customer Choice Law, the ICC's role in regulating electrical

utilities was not extinguished; rather, the ICC continued to determine the rates that a public utility

may charge its customers and to prescribe the utility's operating measures to ensure that the utility

service remained safely and reliably delivered. McDermott testified that the Customer Choice Law

did not deregulate the electric utility industry but, rather, it restructured the industry by separating

the generation of electrical energy from the transmission and distribution of electrical service. The

point of the Customer Choice Law was to create competition in the generating sector of the industry

while leaving the transmission and distribution sector unchanged.

The Customer Choice Law caused ComEd and other electric utilities to restructure. The

electric utilities spun off their generation businesses into competitive subsidiaries or sold them to third

parties.

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