Harrisburg Steel Corp. v. Pennsylvania Public Utility Commission

109 A.2d 719, 176 Pa. Super. 550, 7 P.U.R.3d 609, 1954 Pa. Super. LEXIS 490
CourtSuperior Court of Pennsylvania
DecidedAugust 30, 1954
DocketAppeals, 9 and 80
StatusPublished
Cited by18 cases

This text of 109 A.2d 719 (Harrisburg Steel Corp. v. Pennsylvania Public Utility Commission) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harrisburg Steel Corp. v. Pennsylvania Public Utility Commission, 109 A.2d 719, 176 Pa. Super. 550, 7 P.U.R.3d 609, 1954 Pa. Super. LEXIS 490 (Pa. Ct. App. 1954).

Opinions

Opinion

by Hirt, J.,

On September 12; 1951, Pennsylvania Power and Light Company (hereinafter referred to as the Company) filed supplements to its existing tariffs with Pennsylvania Public Utility Commission. The various supplements contemplated increases in tariffs applicable to 2,435 large .commercial, industrial and re[553]*553sale customers, only. More than 500,000 other customers of the Company were not affected. Complaints were filed by the present appellants and by many others, which were consolidated for hearing with an investigation, instituted by the Commission of its own motion to determine whether the proposed new rates were fair, just and not unreasonably discriminatory. Pending disposition of the consolidated proceeding, the operation of the proposed tariffs was suspended by successive orders, to August 12, 1952. In its decision and order dated July 30, 1952, the Commission allowed a return of not more than 5.82% on $310,000,000 which it found to be the fair value of the Company’s property for rate making purposes as of October 31, 1951. These determinations as well as specific amounts allowed as operating expense are not involved in the present appeals.

Three questions are raised: (1) May the Company recoup from the rate payers by a process of amortization an amount in excess of $25,000,000 paid by the company, on the purchase of various utility companies, over and above the total of their depreciated original cost? (2) Having failed, over a period of years, to make an adequate allowance for annual depreciation, may the Company recover a resulting deficiency in its depreciation reserve, by means of additional annual charges to operation expense? (3) Are the large commercial and industrial customers of the Company in Lancaster entitled to a continuation of an advantage in rates over other customers of the same class located elsewhere?

Pennsylvania Power and Light Company was formed by the merger of eight utility companies and was incorporated on June 4, 1920 under the laws of this State. During the following ten years the Company acquired by purchase many other utility com[554]*554panies which, were merged into its system for the supply of electric energy throughout the eastern section of central Pennsylvania. The problem which gave rise to the first question here involved, had its origin in the promulgation of a uniform accounting system for public utilities by the Federal Power Commission in 1936. A like system of accounting was adopted by Pennsylvania Public Service Commission which, on January 1, 1937, directed all electric utilities to maintain their books on an original cost basis in accord with the uniform accounting provisions. We are concerned primarily with account 100.5 in the uniform system entitled Electric Plant Acquisition Clause. In this account the Company was required to include “the difference between (a) the cost to the accounting utility of electric plant acquired as an operating unit or system by purchase, merger, consolidation, liquidation, or otherwise, and (b) the original cost, estimated if not known, of such property, less the amount or amounts which may be credited to the depreciation and amortization reserves of the accounting utility at the time of acquisition Avith respect to such property.” In this case the account was intended to disclose the amount in excess of depreciated original cost which was paid by the Company for the utilities purchased by it. On December 19, 1944 the Commission in an accounting proceeding initiated by it found that $25,-930,121.01 was classifiable in account 100.5 under Electric Plant Acquisition Adjustments. The Federal Power Commission had previously classified the same amount in the same fashion. And both Commissions ordered that the amount be written off the books of the Company by amortization over a 15-year period at the rate of $1,746,150 per year. There was a vital difference, however, in the two orders: The Federal Power Commission directed that the amount be written off [555]*555by charges to “Miscellaneous Amortization” as a disposition of income; the Pennsylvania Commission directed the amortization by charges as operation expense. And in the instant proceeding the Commission made final its tentative order of December 19, 1944 and thus put the burden on the present rate payers of providing $1,746,150 annually over a fifteen-year period in addition to a return of a maximum of 5.82% on fair value of $310,000,000 in accordance with the findings of the Commission. We are agreed that there is palpable error in the order in this respect.

The question is of first impression not only in Pennsylvania but in other jurisdictions generally. It is a question of far-reaching importance. We may well believe that the amounts in the Acquisition Adjustment Accounts of other utility companies resulting from similar purchases may amount to hundreds of millions of dollars. And in the present case if the Company, more than 20 years after the purchases were made, may collect from the present rate payers the excess costs appearing in its account 100.5, there is no apparent obstacle to the similar recoupment by other utilities of like payments. Fundamentally, the error in this phase of the appeals arises from the fact that the Company with the aid of the Commission has transformed an administrative procedure, which it was bound to observe, into substantive law (albeit foreign to the processes of rate making) imposing new burdens on the rate payers. This conclusion is clearly indicated by the present record. In referring to the classification of the excess amounts paid for utilities over their original cost, and their amortization by charges to operating expense by our Commission and by charges to gross income by the Federal Power Commission, the 1944 order recites that “both this order and the Federal Power Commission order are for ae-[556]*556counting purposes only.” And although the Commission elsewhere stated that the classification of the amount in account 100.5 was “not a controlling factor in rate adjudication” yet in the present case the Commission treated its amortization as an expense for rate purposes to be borne by the rate payers in addition to a fair return on the rate base. In so doing it is clear that the Commission has projected its accounting determination into the field of rate regulation and it should be noted that the burden imposed on the rate payers by the present order is much greater than the annual amortization payment itself. The payment is not deductible for tax purposes and it is probable that in order to produce a net of $1,746,000 after taxes, the rate payers would have to pay more than twice that amount annually. This is the equivalent of a further increase in the rate base. In Lindheimer v. Illinois Bell Telephone Co., 292 U. S. 151, 164, 54 S. Ct. 658, it is said: “Charges to operating expenses may be as important as valuations of property. Thus, excessive charges of $1,500,000 to operating expenses would be the equivalent of 6 per cent, on $25,000,000 in a rate base.” In the present case the annual charge involved is much more than $1,500,000.

The amount paid by the Company in acquiring the utilities, even if it be assumed that the transactions were at arms length, cannot be adopted as original cost for rate making purposes. Original cost is such cost “when first devoted to public service” (§502 of the Public Utility Law of May 28, 1937, P. L. 1053, 66 PS §1212) and cannot be construed to mean a larger amount which a new owner is obliged to pay on purchase of the property of a utility. Scranton-Spring Brk. W. Serv. v. Pa. P. U. C., 165 Pa.

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Harrisburg Steel Corp. v. Pennsylvania Public Utility Commission
109 A.2d 719 (Superior Court of Pennsylvania, 1954)

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Bluebook (online)
109 A.2d 719, 176 Pa. Super. 550, 7 P.U.R.3d 609, 1954 Pa. Super. LEXIS 490, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harrisburg-steel-corp-v-pennsylvania-public-utility-commission-pasuperct-1954.