Office of the Public Advocate v. Public Utilities Commission

2024 ME 11
CourtSupreme Judicial Court of Maine
DecidedJanuary 30, 2024
DocketPUC-23-101
StatusPublished
Cited by1 cases

This text of 2024 ME 11 (Office of the Public Advocate v. Public Utilities Commission) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Office of the Public Advocate v. Public Utilities Commission, 2024 ME 11 (Me. 2024).

Opinion

MAINE SUPREME JUDICIAL COURT Reporter of Decisions Decision: 2024 ME 11 Docket: PUC-23-101 Argued: December 5, 2023 Decided: January 30, 2024

Panel: STANFILL, C.J., and MEAD, JABAR, CONNORS, and DOUGLAS, JJ.

OFFICE OF THE PUBLIC ADVOCATE

v.

PUBLIC UTILITIES COMMISSION

CONNORS, J.

[¶1] The Office of the Public Advocate (OPA) appeals an order of the

Public Utilities Commission extending a waiver of the standard depreciation

rate for the Maine Water Company - Millinocket Division (MWC). The OPA

asserts three claims: (1) the Commission legally erred when it applied Chapter

110 of its rules to waive the depreciation rate set forth in Chapter 68 because

Chapter 68 contains its own waiver provision; (2) the Commission abused its

discretion and set unjust and unreasonable rates by approving an arbitrarily

low depreciation expense; and (3) the Commission relied on information not

included in the evidentiary record. We disagree with the OPA as to its first two

arguments, conclude that the third argument is waived, and affirm the

Commission’s order. 2

I. BACKGROUND

[¶2] The following background is drawn from the Commission’s

February 2, 2023, order, other Commission decisions, and filings made in those

proceedings.1

[¶3] The standard depreciation rates for water utilities are set forth in

Chapter 68 of the Commission’s rules. 65-407 C.M.R. ch. 68 (effective

May 4, 1996). Beginning in February 2003, the Commission granted MWC

waivers of the standard rates set forth in that Chapter based on declining

consumption, due in part to the bankruptcy of a major customer, the Great

Northern Paper Company.2

1 The OPA submitted a supplement of legal authorities consisting of previous Commission

decisions relating to the MWC rates dating from 1997 to 2020. See M.R. App. P. 8(n). In addition to the Commission’s decisions themselves, we may take judicial notice of the existence and content of the filings made in these regulatory proceedings. See Town of Mount Vernon v. Landherr, 2018 ME 105, ¶ 14, 190 A.3d 249 (stating that the Court may take judicial notice of an administrative body’s decisions and noting that a “court may take judicial notice of a document filed in another court not for the truth of the matters asserted in the other litigation, but rather to establish the fact of such litigation and related filings”(citation and quotation marks omitted)).

2 The first waiver lasted through 2005 and allowed MWC to cap its recorded depreciation expense

at $100,000 instead of the $180,000 calculated using the Chapter 68 (at times referred to by the Commission as 680) method. Consumers Me. Water Co. - Millinocket Div., Request for Waiver of Chapter 680 Depreciation Rates, No. 2003-00044, Order Approving Waiver (Me. P.U.C. Feb. 25, 2003). The OPA intervened in the proceeding but did not object to the proposed waiver. Id. In March 2005, MWC requested an extension of the February 2003 waiver. Consumers Me. Water Co. - Millinocket Div., Request for Waiver of Chapter 680 Depreciation Rates, No. 2003-00044, Order Extending Waiver (Me. P.U.C. May 18, 2005). The OPA did not object, and the Commission granted the waiver through 2007. Id. During MWC’s subsequent rate proceeding in 2006, the Commission approved a stipulation between MWC and the OPA for a two-step return to full Chapter 68 depreciation rates. Aqua Me., Inc. – Millinocket, To Increase Revenue in the Millinocket Division by a Step One Increase of $105,809 OR 9.58% and a Step Two Increase of $37,874 OR 3.43%, Order Approving Stipulation (Me. P.U.C. June 1, 2006). This return to standard Chapter 68 rates did not last. MWC requested 3

[¶4] Starting in 2014, the Commission also granted a request for an

infrastructure surcharge from MWC for various projects to replace

infrastructure.3 Me. Water Co. - Millinocket Div., Request for Approval of Water

Infrastructure Surcharge, No. 2014-00307, Order (Me. P.U.C. Oct. 21, 2014).4

[¶5] In February 2022, MWC applied to the Commission to increase its

rates by 14.47% in its Millinocket division. MWC used the previously granted

depreciation waiver in its proposed rate model, which the Commission

another waiver, which the Commission granted without objection from the OPA in January 2009. Aqua Me., Inc. - Millinocket Div., Request for Waiver of Chapter 680 Depreciation Rates, No. 2008-00513, Order Approving Waiver (Me. P.U.C. Jan. 13, 2009). MWC requested extensions of that waiver, which the Commission granted in 2011 and 2014 with either a stipulation or no objection from the OPA. Aqua Me., Inc. - Millinocket Div., Proposed Rate Change to Increase Revenue by $99,026 or 8.74%, No. 2011-00108, Order Approving Stipulation (Me. P.U.C. Aug. 12, 2011); The Me. Water Co. - Millinocket Div., Proposed Rate Change to Increase Revenue by $99,026 or 8.74%, No. 2011-00108, Order Approving Extension of Waiver (Me. P.U.C. Apr. 29, 2014). The 2014 waiver extended the $100,000 depreciation cap until MWC’s next rate case. The Me. Water Co. - Millinocket Div., Proposed Rate Change to Increase Revenue by $99,026 or 8.74%, No. 2011-00108, Order Approving Extension of Waiver (Me. P.U.C. Apr. 29, 2014).

3 An infrastructure surcharge is a mechanism for incorporating into the utility’s rate base between

rate cases the costs of construction of infrastructure projects necessary to the transmission, distribution, and treatment of water. See 65-407 C.M.R. ch. 675, §§ 5(A), 6 (effective June 21, 2013); The Me. Water Co. - Millinocket Div., Request for Approval of Water Infrastructure Surcharge, No. 2020-00325, Order (Me. P.U.C. Dec 15, 2020).

4 The Commission granted five more infrastructure surcharges in 2015, 2016, 2018, March 2020,

and December 2020. Me. Water Co. - Millinocket Div., Request for Approval of Water Infrastructure Charge, No. 2015-00330, Order (Me. P.U.C. Nov. 18, 2015); Me. Water Co. - Millinocket Div., Request for Approval of Water Infrastructure Charge, No. 2016-00262, Order (Me. P.U.C. Nov. 30, 2016); Me. Water Co. - Millinocket Div., Request for Approval of Water Infrastructure Charge, No. 2017-00322, Order (Me. P.U.C. Jan. 12, 2018); Me. Water Co. - Millinocket Div., Request for Approval of Water Infrastructure Charge, No. 2020-00023, Order (Me. P.U.C. Mar. 2, 2020); Me. Water Co. - Millinocket Div., Request for Approval of Water Infrastructure Charge, No. 2020-00325, Order (Me. P.U.C. Dec. 15, 2020). 4

interpreted as a request for an extension of the waiver and asked MWC to file

that request in a separate docket.

[¶6] In October 2022, MWC complied with the Commission’s request and

filed separately for an extension of the waiver. The OPA petitioned to intervene,

filed comments opposing the extension, and served data requests on MWC. The

OPA did not request further processes, such as prefiled testimony or an

evidentiary hearing.

[¶7] In their report, the hearing examiners recommended that the

Commission grant the waiver extension with a direction to MWC to submit a

plan detailing its return to full Chapter 68 depreciation rates with its next rate

case, or by January 2026 if MWC had not initiated a rate case by then. In making

their recommendation, the examiners referenced MWC’s filings and responses

to the OPA’s comments and data requests. They noted that not granting the

waiver capping depreciation expense at $100,000 would add almost $200,000

of additional depreciation expense to consumers’ rates and concluded that it

was reasonable to provide MWC with an opportunity to consider a phased

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2024 ME 11, Counsel Stack Legal Research, https://law.counselstack.com/opinion/office-of-the-public-advocate-v-public-utilities-commission-me-2024.