Off. of the People's Counsel for D.C. v. D.C. Public Serv. Comm'n.

CourtDistrict of Columbia Court of Appeals
DecidedNovember 10, 2022
Docket21-AA-684 & 21-AA-869
StatusPublished

This text of Off. of the People's Counsel for D.C. v. D.C. Public Serv. Comm'n. (Off. of the People's Counsel for D.C. v. D.C. Public Serv. Comm'n.) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Off. of the People's Counsel for D.C. v. D.C. Public Serv. Comm'n., (D.C. 2022).

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

Nos. 21-AA-0684, 21-AA-0869

OFFICE OF THE PEOPLE’S COUNSEL FOR THE DISTRICT OF COLUMBIA, PETITIONER,

v.

D.C. PUBLIC SERVICE COMMISSION, RESPONDENT,

and

POTOMAC ELECTRIC POWER COMPANY, INTERVENOR.

On Petition for Review of a Decision of the D.C. Public Service Commission (Formal Case No. 1156)

(Argued September 15, 2022 Decided November 10, 2022)

Scott H. Strauss, with whom Sandra Mattavous-Frye, Karen R. Sistrunk, Laurence C. Daniels, and Amanda C. Drennen were on the brief, for petitioner.

Kimberly Lincoln-Stewart, with whom Christopher G. Lipscombe, Angela L. Lee, Richard S. Herskovitz, Emil Hirsch, Emily Green, Frederick A. Douglas, Curtis A. Boykin, and Nausheen Gaznabi were on the brief, for respondent.

Nicholas S. Penn, with whom Anne Bancroft, Kimberly A. Curry, Andrea H. Harper, Dennis P. Jamouneau, Taylor W. Beckham, and Sherry F. Bellamy were on the brief, for intervenor.

Before EASTERLY, MCLEESE, and HOWARD, Associate Judges. 2

EASTERLY, Associate Judge: The Office of the People’s Counsel for the

District of Columbia (“OPC”) brings this challenge to two orders of the D.C. Public

Service Commission (“the Commission”) in Formal Case No. 1156, in which the

Commission approved a multiyear rate plan for the Potomac Electric Power

Company (“Pepco”)’s electricity distribution services from 2020 to 2022.

Specifically, OPC argues that the Commission should not have permitted Pepco to

recover costs from its distribution customers that it incurred in conducting a remedial

investigation and feasibility study regarding possible environmental damage at or

from its facilities at 3400 Benning Road NE, Washington, D.C. (“the Benning Road

site”). OPC also contests the inclusion of two energy efficiency rebate and loan

programs targeting small businesses in Pepco’s rate plan, which would permit Pepco

to recover the costs of those programs from its customers in a future rate case.

We vacate the Commission’s orders as to both issues and remand for further

proceedings consistent with this opinion. 3

I. OPC’s Challenge to Pepco’s Recovery of Remedial Investigation Costs

A. Facts and Procedural History

Pepco’s Benning Road site is a 77-acre lot bordered by the Anacostia River

on its western side. The site contains a service center used to support its transmission

and distribution operations. The site also contains a power plant that began operating

in or around 1906, consisting of structures including a generating station, cooling

towers, and storage facilities. The generating station shut down in 2012.

In 1999, attempting to step back from its then-active energy production

business, Pepco applied to the Commission in Formal Case No. 945 for

authorization to divest its generating assets according to its proposed plan. The D.C.

Council, however, had “concerns”—the exact nature of which is not clear from the

record—about the proposed sale of two generating stations, including the one at

Benning Road, and thus it requested that the Commission hold the divestiture in

abeyance. In order to move its divestiture application forward, and after engaging

in “comprehensive negotiations,” Pepco agreed to comply with specific conditions

regarding those stations. These conditions were memorialized in Section 1.05 of the

resulting settlement agreement, hereinafter the “FCN 945 Settlement,” which

provided: 4

Nothing in this Settlement Agreement shall be construed as requiring Pepco to include in the sale of the [generating a]ssets, the Company’s generating stations located at Benning Road and Buzzard Point in the District of Columbia; provided, however, that if the Benning Road and Buzzard Point generating stations are not included in the sale of the [generating a]ssets, the Company shall be thereafter barred and estopped from asserting or exercising any legal right that it might otherwise have to recover from customers located in the District of Columbia any stranded costs associated with those generating stations. In connection with any Pepco base rate proceeding in the District of Columbia instituted after June 30, 2000, the Benning Road and Buzzard Point generating stations shall not be included in the cost of service for purposes of determining the Company’s District of Columbia jurisdictional revenue requirement.

The Commission approved this settlement agreement pursuant to its rules and

procedures. See 15 D.C.M.R. § 130.13-.17 (2022).

Ten years later, the United States Environmental Protection Agency (“EPA”)

released a report detailing environmental toxins found on and around the Benning

Road site. The report concluded that chemical contaminants known as PCBs 1 “have

1 “PCBs” refers to polychlorinated biphenyls, a solid waste that persists in the environment without degrading; if a person consumes fish or other organisms that have been contaminated with PCBs from their environment, the PCBs can cause “a variety of adverse health effects, including cancer.” Consent Decree at 2, District of Columbia v. Potomac Elec. Power Co., No. 1:11-cv-00282-BAH (D.D.C. Aug. 17, 2011) [hereinafter “DOEE Consent Decree”], https://benningservicecenter.com/ library/documents/BenningConsentDecree.pdf; https://perma.cc/WC6U-27WW. 5

been released from the site to the Anacostia River,” tracing one release of PCBs to

“the generating station’s cooling tower basins,” which discharge into the river. It

further concluded that “[t]he only potential uncontained potential source [of PCBs]

identified on the site” was a sludge dewatering area previously used in association

with the cooling towers.

In response to the report, the District Department of Energy and Environment

(“DOEE”) 2 notified Pepco that it intended to sue the company for abatement of

hazardous conditions resulting from the Benning Road site. To settle the intended

suit, Pepco entered into a consent decree in 2011 with the DOEE, which in part

bound Pepco to conduct a remedial investigation and feasibility study (“RI/FS”) that

would inform any future remedial actions. 3 As of the time of Pepco’s application in

this case, the company’s work on the RI/FS was ongoing.

In 2018, Pepco entered into a settlement agreement to resolve its 2017 rate

application, Formal Case No. 1150, before the Commission (hereinafter the “FCN

2 At the time, the DOEE was known as the District Department of the Environment. 3 DOEE Consent Decree at 6. 6

1150 Settlement”). OPC was also a party to the settlement. Pepco had

unsuccessfully sought to place its RI/FS costs in a “regulatory asset” in previous rate

cases, but finally secured it in this settlement. 4 In relevant part, the FCN 1150

Settlement provided:

The Parties agree that Pepco will receive regulatory asset treatment in the total amount of $3.3 million in actual costs incurred to conduct a remedial investigation (“RI”) at the Benning facility. Pepco will begin to recover the $3.3 million over a 10-year amortization period, with carrying costs based on the Company’s Commission-authorized rate of return. This recovery relates only to the RI costs that have already been incurred as a result of the [DOEE] Consent Decree . . .

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