Office of Public Utility Counsel and Texas Industrial Energy Consumers// Public Utility Commission of Texas v. Public Utility Commission of Texas// Office of Public Utility Counsel and Texas Industrial Energy Consumers

CourtCourt of Appeals of Texas
DecidedJanuary 15, 2010
Docket03-08-00698-CV
StatusPublished

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Office of Public Utility Counsel and Texas Industrial Energy Consumers// Public Utility Commission of Texas v. Public Utility Commission of Texas// Office of Public Utility Counsel and Texas Industrial Energy Consumers, (Tex. Ct. App. 2010).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN




NO. 03-08-00698-CV

Appellants, Office of Public Utility Counsel and Texas Industrial Energy Consumers// Cross-Appellant, Public Utility Commission of Texas



v.



Appellee, Public Utility Commission of Texas// Cross-Appellees, Office of Public Utility Counsel and Texas Industrial Energy Consumers



FROM THE DISTRICT COURT OF TRAVIS COUNTY, 345TH JUDICIAL DISTRICT

NO. D-1-GN-08-000476, HONORABLE JOHN K. DIETZ, JUDGE PRESIDING

O P I N I O N



The Office of Public Utility Counsel ("OPC") and Texas Industrial Energy Consumers ("TIEC") sought judicial review of the decision of the Public Utility Commission ("the Commission") in a generic administrative proceeding instigated for the purpose of determining whether statewide stranded costs exceeded $5 billion and, if necessary, reallocating costs in excess of $5 billion among the various classes of customers. The trial court affirmed the Commission's decision in part, but remanded a single issue related to environmental retrofit costs back to the Commission to allow for the presentation of additional evidence. OPC and TIEC now appeal from the trial court's order to the extent it affirms the Commission's order. The Commission cross-appeals, asserting that the trial court erred in remanding the issue of environmental retrofit costs. We affirm that portion of the trial court's order affirming the Commission's decision. Because we conclude that the trial court erred in remanding the issue regarding environmental retrofit costs back to the Commission, we reverse that portion of the trial court's order and affirm the Commission's decision.



BACKGROUND

Deregulation

In 1999, the legislature initiated the deregulation of the Texas electricity market, providing for the transition from a regulated industry to a competitive deregulated market. See Act of May 27, 1999, 76th Leg., R.S., ch. 405, 1999 Tex. Gen. Laws 2543 (current version at Tex. Util. Code Ann. §§ 39.001-.916 (West 2007 & Supp. 2009)); see generally CenterPoint Energy Houston Elec., LLC v. Gulf Coast Coalition of Cities, 252 S.W.3d 1, 7-12 (Tex. App.--Austin 2008, pet. granted) (describing deregulation). As part of the deregulation process, formerly regulated utilities were allowed to recover their investments made in generation assets, such as nuclear power plants, that would generally not be recoverable in a competitive market. See CenterPoint, 252 S.W.3d at 8; see also Tex. Util. Code Ann. § 39.001(b)(2) (finding that it is in the public interest to "allow utilities with uneconomic generation-related assets . . . to recover the reasonable excess costs over market of those assets"). Utilities were authorized to recover these "stranded costs" by allocating and collecting them from the residential, commercial, and industrial classes of customers according to certain allocation factors created by the legislature. See Tex. Util. Code Ann. §§ 39.252 (right to recover stranded costs), 39.253 (allocation of stranded costs). The administrative proceeding giving rise to this appeal dealt primarily with issues related to the proper allocation of stranded costs among the customer classes for purposes of collection.



Stranded Cost Allocation Methodology

According to the applicable stranded cost allocation methodology, industrial and commercial customers are allocated stranded costs based solely on what the parties refer to as production demand allocation factors ("PDAFs"). (1) See id. § 39.253(d), (e). With respect to residential customers, 50% of stranded costs allocated to this class of customers are allocated on the basis of PDAFs, while the remaining 50% are allocated on the basis of energy consumption. See id. § 39.253(c). Because residential customers typically bear a greater share of costs when allocation is based on PDAFs, and a lesser share of costs when allocation is based on consumption, the effect of section 39.253(c) is that residential customers are allocated less of the stranded cost burden than they would have been if 100% of stranded costs were allocated using PDAFs. However, once "total retail stranded costs" exceed $5 billion on a statewide basis, those stranded costs in excess of $5 billion are to be allocated to residential customers based solely on PDAFs. See id. § 39.253(f). As a result of section 39.253(f), residential customers are allocated a higher share of those statewide retail stranded costs that exceed $5 billion.



Generic Reallocation Proceeding: Docket 32795

In the years after deregulation, the Commission conducted a series of true-up proceedings in order to quantify the stranded costs of each deregulated utility and implement the recovery of stranded costs from the customer classes within each utility's service area. Until all of the true-up proceedings were completed, the Commission could not determine total statewide retail stranded costs and therefore could not determine how much, if any, of the stranded costs should have been allocated using the methodology required by section 39.253(f) for statewide stranded costs in excess of $5 billion. In the interim, the Commission allocated all stranded costs using the methodology described in section 39.253(b)-(d). Upon completion of all true-up proceedings, the Commission's staff filed a petition to initiate a generic proceeding to reallocate stranded costs pursuant to section 39.253(f). This petition resulted in Docket 32795, the administrative proceeding giving rise to this appeal. (2)

The Commission was faced with two primary issues in Docket 32795. First, it had to determine whether total statewide retail stranded costs exceeded $5 billion. Second, to the extent statewide retail stranded costs did exceed $5 billion, the Commission had to reallocate stranded-cost recovery among the customer classes in order to ensure that the allocation complied with section 39.253(f).

Shortly after the initial petition was filed in Docket 32795, the case was referred to the State Office of Administrative Hearings (SOAH). After reviewing the evidence, conducting a hearing, and accepting post-submission briefs, the SOAH administrative law judges issued a proposal for decision. The Commission considered the proposal and then issued an order remanding the case back to SOAH for the resolution of a specific list of questions. The administrative law judges issued a new proposal for decision on remand, which was ultimately adopted by the Commission in its final decision.

In its final order, the Commission determined that statewide retail stranded costs totaled approximately $6.029 billion, necessitating a reallocation of the $1.029 billion in stranded costs that exceeded the $5 billion threshold.

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