Delaware Division of the Public Advocate v. Delaware Public Service Commission

CourtSuperior Court of Delaware
DecidedMarch 24, 2023
DocketK22A-02-005 RLG
StatusPublished

This text of Delaware Division of the Public Advocate v. Delaware Public Service Commission (Delaware Division of the Public Advocate v. Delaware Public Service Commission) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Delaware Division of the Public Advocate v. Delaware Public Service Commission, (Del. Ct. App. 2023).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

THE DELAWARE DIVISION OF ) THE PUBLIC ADVOCATE, ) ) Appellant, ) ) v. ) C.A. No.: K22A-02-005 RLG ) THE DELAWARE PUBLIC ) SERVICE COMMISSION and ) DELMARVA POWER & LIGHT ) COMPANY, ) ) Appellees. )

MEMORANDUM OPINION AND ORDER

Submitted: November 4, 2022 Decided: March 24, 2023

Upon Appellant’s Appeal from a Decision of the Delaware Public Service Commission – REVERSED AND REMANDED.

Regina A. Iorii, Esquire, Department of Justice, Wilmington, Delaware, Attorney for Appellant.

James McC. Geddes, Esquire, Ashby & Geddes, Wilmington, Delaware, Attorney for Appellee The Delaware Public Service Commission.

Jessica M. Jones, Esquire & Marisa R. De Feo, Esquire, Saul Ewing Arnstein & Lehr LLP, Wilmington, Delaware, Attorney for Appellee Delmarva Power & Light Company.

GREEN-STREETT, J. Introduction

The instant appeal stems from The Delaware Public Service Commission’s

(“Commission”) decision to grant Delmarva Power & Light Company’s

(“Delmarva”) request to include its Prepaid Pension Asset (“PPA”) and liability for

Other Post-Retirement Employment Benefits (“OPEB”) within its rate base. Citing

precedent, the Commission found that the PPA and OPEB liability balances should

be included in Delmarva’s rate base. The Delaware Division of the Public Advocate

(“DPA”), an entity created by the General Assembly to advocate on behalf of

residential and small commercial utility customers,1 contends that the Commission’s

finding is not supported by substantial evidence and constitutes legal error. For the

reasons set forth below, the Commission’s decision is reversed and remanded.

Background

This case involves the inimitable and complicated intersection of utility law

and accounting. While largely undisputed, the complexity of some of the underlying

concepts and principles of this case compels the Court to provide an overview of the

relevant facts, terminology, and procedural history. All accounting principles

referenced conform to Generally Accepted Accounting Principles (“GAAP”) and

Financial Accounting Standards (“FAS”).

1 29 Del. C. §§ 8716(e)(1) & (2). 2 A. Delaware’s Utility Regulatory Scheme

Delmarva is a Delaware public utility2 company regulated by the

Commission. Under the Delaware Public Utilities Act3 (the “Act”), the Delaware

General Assembly delegated to the Commission the exclusive authority to regulate

Delaware public utilities.4 This Court has held that the Delaware legislature

specifically created the Commission for “the purpose of balancing the interests of

the consuming public with those of regulated companies.”5 Delaware public utilities

are prohibited from imposing any “unjust or unreasonable or unduly deferential or

unjustly discriminatory individual or joint rate.”6 These utilities must notify the

2 26 Del. C. § 102(2) (A public utility is defined as every individual, partnership, association, corporation, joint stock company, agency or department of the State or any association of individuals engaged in the prosecution in common of a productive enterprise (commonly called a “cooperative”), their lessees, trustees or receivers appointed by any court whatsoever, that now operates or hereafter may operate for public use within this state, (however, elective cooperatives shall not be permitted directly or through an affiliate to engage in the production, sale or distribution or propane gas or heating oil), any natural gas, electric (excluding electric suppliers as defined in § 1001 of this title), water, wastewater (which shall include sanitary sewer charge), telecommunications, (excluding telephone services provided by cellular technology or by domestic public land mobile radio service) service, system, plant or equipment.) 3 See, e.g., 26 Del. C. §§ 102, 201, 304-305. 4 26 Del. C. § 201. 5 Chesapeake Util. Corp. v. Delaware Pub. Serv. Comm’n, 2017 WL 2480804, at *3 (Del. Super. June 7, 2017) (citing E. Shore Nat. Gas Co. v. Del. Pub. Serv. Comm’n, 635 A.2d 1273, 1277 (Del. Super. Feb. 19, 1993)) (additional citations omitted). 6 Id. at *3 (citing 26 Del. C. § 303).

3 Commission if any rate change is sought.7 The Commission is then statutorily

authorized to conduct hearings.8

B. Legal Principles Governing Rate Cases

The primary purpose of ratemaking is to fix rates sufficient to give the utility

a fair return upon the present value of property dedicated to the public use.9 When

the Commission considers the lawfulness of any rate change, it must review a

utility’s rate base and how that rate base is calculated. “Ratemaking is commonly

considered an art, not a science.”10

1. Rate Base

Rate base is “the dollar value of the utility’s plant employed in providing its

service to the public and upon which the utility and its investors are entitled to earn

a fair return.”11 The rate base is, in effect, the investment upon which the investors’

return is earned.12 The Act outlines the components of a Delaware-regulated utility’s

rate base, which includes:

7 26 Del. C. § 304(a). 8 26 Del. C. § 305. 9 Chesapeake Util. Corp. v. Del. Pub. Serv. Comm’n, 705 A.2d 1059, 1065 (Del. Super. Mar. 31, 1997). 10 Id. 11 Id. at 1066. 12 Id. 4 a. The original cost of all used and useful utility plan

and intangible assets either to the first person who

committed said plant or assets to public use or, at

the option of the Commission, the first recorded

book cost of said plant or assets; less

b. Related accumulated depreciation and

amortization; less

c. The actual amount received and unrefunded as

customer advances or contributions in aid of

construction of utility plant, and less

d. Any accumulated deferred and unamortized

income tax liabilities and investment credits,

adjusted to reflect any accumulated deferred

income tax assets including, but not limited to,

those arising from the payment of alternative

minimum tax, related to plant included in

paragraph a. above, plus

e. Accumulated depreciation of customer advances

and contributions in aid of construction related to

plant included in paragraph a. above, and plus

5 f. Materials and supplies necessary to the conduct of

the business and investor supplied cash working

capital, and plus

g. Any other element of property which, in the

judgment of the Commission, is necessary to the

effective operation of the utility.13

A utility’s rate base, in essence, is determined by adding the utility’s investment in

physical properties to its working capital.

2. Working Capital

Working capital constitutes the operating funds essential to pay for the current

obligations of a utility.14 Stated another way, working capital is the money – fronted

by the utility – necessary to finance the services provided until the utility is

compensated by its customers.15 As expertly outlined by the New Mexico Supreme

Court:

In the context of utility regulation, working capital does not include the total liquid funds with which the business is conducted. It is not the property which the business has; that is, it is not the excess of current assets over current liabilities.

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Delaware Division of the Public Advocate v. Delaware Public Service Commission, Counsel Stack Legal Research, https://law.counselstack.com/opinion/delaware-division-of-the-public-advocate-v-delaware-public-service-delsuperct-2023.