Greenwood v. NH Public Utilities

2007 DNH 088
CourtDistrict Court, D. New Hampshire
DecidedJuly 19, 2007
Docket06-CV-270-SM
StatusPublished

This text of 2007 DNH 088 (Greenwood v. NH Public Utilities) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Greenwood v. NH Public Utilities, 2007 DNH 088 (D.N.H. 2007).

Opinion

Greenwood v. NH Public Utilities 06-CV-270-SM 07/19/07 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Alden T. Greenwood d/b/a Alden Engineering Company, Plaintiff

v. Civil No. 06-CV-270-SM Opinion No. 2007 DNH 088 New Hampshire Public Utilities Commission, Defendant

O R D E R

Alden Greenwood brings this action against the New Hampshire

Public Utilities Commission ("PUC") seeking declaratory and

injunctive relief. See generally 28 U.S.C. § 2201. Greenwood

claims that, in contravention of applicable federal law, the PUC

rescinded the final ten years of a 30-year rate schedule

applicable to three small hydroelectric facilities he owns and

operates. Specifically, he says federal law preempts the field

of rate regulation with respect to his generating facilities and

precludes the PUC from modifying the rates initially set. He

seeks a judicial declaration that the PUC's purported rescission

order was invalid and that his original 30-year rate schedule

remains in full force. He also seeks an injunction preventing

the PUC from taking any action inconsistent with the original

order approving his 30-year rate schedule. The parties appear to agree that there are no genuinely

disputed material facts and that the resolution of their dispute

turns exclusively on questions of law. Pending before the court

are the parties' cross motions for summary judgment. For the

reasons set forth below. Greenwood's motion for summary judgment

is granted and the PUC's motion for summary judgment is denied.

Standard of Review

When ruling on a party's motion for summary judgment, the

court must "view the entire record in the light most hospitable

to the party opposing summary judgment, indulging all reasonable

inferences in that party's favor." Griqqs-Rvan v. Smith. 904

F.2d 112, 115 (1st Cir. 1990). Summary judgment is appropriate

when the record reveals "no genuine issue as to any material fact

and . . . the moving party is entitled to a judgment as a matter

of law." Fed. R. Civ. P. 56(c). In this context, "a fact is

■'material' if it potentially affects the outcome of the suit and

a dispute over it is 'genuine' if the parties' positions on the

issue are supported by conflicting evidence." Int'l Ass'n of

Machinists and Aerospace Workers v. Winship Green Nursing Ctr.,

103 F.3d 196, 199-200 (1st Cir. 1996) (citations omitted).

2 Background

I. Federal Regulatory Scheme.

In 1978, in an effort to encourage the development of

alternate energy sources and to reduce the nation's dependance on

fossil fuels. Congress enacted the Public Utility Regulatory

Policies Act ("PURPA"). Section 210 of PURPA, 16 U.S.C. § 824a-

3, directs the Federal Energy Regulatory Commission ("FERC") to

promulgate rules to encourage the development of small power

production facilities, including regulations requiring public

utilities to purchase electricity from qualifying small power

facilities (known as "qualifying facilities" or "QFs"). Among

other things, PURPA requires that those regulations insure that

the rates at which public utilities purchase electricity from

qualifying facilities "shall be just and reasonable to the

electric consumers of the electric utility and in the public

interest, and shall not discriminate against . . . qualifying

small power producers." 16 U.S.C. § 824a-3(b).

A. Rates of Reimbursement.

The FERC regulations require public utilities to purchase

electricity from qualifying facilities at a rate equal to the

utilities' avoided cost, unless the state regulatory commission

(here, the PUC) determines that a lower rate is in the public

3 interest, does not discriminate against qualifying facilities,

and is sufficient to encourage the construction of small power

producers. 18 C.F.R. § 292.304(b)(2). "Avoided cost" is the

"cost to the electric utility of the electric energy which, but

for the purchase from such cogenerator or small power producer,

such utility would generate or purchase from another source." 16

U.S.C. § 824a-3(d). In short, it is the amount of money it would

have cost the public utility to generate (or purchase from

another source) the electricity produced by the small power

producer.

The regulations promulgated by FERC also provide that the

qualifying facility may elect to have the rate at which it sells

electricity to the public utility based on either: (1) the

utility's actual avoided costs, calculated at the time of

delivery; or (2) the utility's predicted avoided costs at the

time of delivery, but calculated at the time the obligation is

incurred. 18 C.F.R. § 292.304(d)(2). The regulations go on to

provide that if the rates at which a utility must purchase

electricity from a qualifying facility are "based upon estimates

of avoided costs over the specific term of the contract or other

legally enforceable obligation, the rates for such purchases do

not violate this subpart if the rates for such purchases differ

4 from [actual] avoided costs at the time of delivery." 18 C.F.R.

§ 292.304(b)(5).

A plain English translation of those regulations is this:

a qualifying facility has the right to receive the benefit of its

long term rate schedule even if, due to changed circumstances or

even faulty predictions of the utility's future avoided costs,

the price at which the utility is obligated to purchase

electricity at the time of delivery is unfavorable to the utility

(i.e., greater than its actual avoided cost). Moreover, the

regulatory and statutory requirement that the rates of

reimbursement to qualifying facilities be reasonable, non-

discriminatory, and in the public interest, are not violated even

if the estimates of the public utility's future avoided costs

prove wholly inaccurate. Viewed from a slightly different

perspective, neither PURPA nor the FERC regulations provide any

basis to rescind or restructure a qualifying facility's existing

rate structure simply because the public utility's predicted

future avoided costs (which were estimated when the QF obtained

its long-term rate schedule) prove to be less than its actual

avoided costs over the pertinent time period.

5 B. Exemption from Certain State and Federal Utility Regulation.

In a further effort to encourage the development of small

power producers, PURPA directs FERC to implement regulations

exempting qualifying facilities from certain state and federal

laws and regulations governing public utilities, including those

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