Oncor Electric Delivery Company LLC v. Public Utility Commission of Texas

406 S.W.3d 253, 2013 WL 3013899, 2013 Tex. App. LEXIS 7334
CourtCourt of Appeals of Texas
DecidedJune 14, 2013
Docket03-11-00233-CV
StatusPublished
Cited by28 cases

This text of 406 S.W.3d 253 (Oncor Electric Delivery Company LLC v. Public Utility Commission of Texas) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Oncor Electric Delivery Company LLC v. Public Utility Commission of Texas, 406 S.W.3d 253, 2013 WL 3013899, 2013 Tex. App. LEXIS 7334 (Tex. Ct. App. 2013).

Opinion

OPINION

SCOTT K. FIELD, Justice.

Oncor Electric Delivery Company LLC sued for judicial review of a final order issued by the Public Utility Commission denying the recovery of certain rate-case expenses under the Public Utility Regulatory Act (PURA). 1 See Tex. UtihCode §§ 11.001-66.016. The district' court affirmed the Commission’s final order. In its order, the Commission found that On-cor was entitled to recover its reasonable and necessary rate-case expenses incurred directly in connection with the underlying system-wide rate case. 2 The Commission *256 explained that the parties had settled the issues of recoverability and reasonable and necessary amounts of those expenses. As part of the settlement, the parties had also stipulated to the reasonable and necessary amounts of rate-case expenses that were associated with two municipal show-cause proceedings (the “2004 and 2005 expenses”) and a prior rate case that had been initiated by Commission staff and withdrawn in 2008 (the “Docket No. 34040 expenses”), but the parties did not reach agreement on the recoverability of those expenses. The Commission disagreed with the administrative law judge’s proposal for decision recommending that Oncor recover those expenses and instead found that Oncor was not entitled to recover them. In two issues on appeal, Oncor contends that the district court erred by affirming the Commission’s order because the Commission (1) acted arbitrarily, capriciously, and contrary to law when it denied Oncor recovery of its rate-case expenses associated with the prior proceedings and (2) erred by finding it lacked jurisdiction to hear Oncor’s claim for its 2004 and 2005 expenses. We conclude that the Commission (1) had jurisdiction to hear Oncor’s claim for the 2004 and 2005 expenses and (2) acted arbitrarily and capriciously by denying Oncor recovery of its expenses incurred in prior proceedings. Accordingly, we will reverse the district court’s judgment affirming the Commission’s order, reverse the Commission’s order, and remand the cause to the Commission for proceedings consistent with this opinion.

BACKGROUND

We provide a brief overview of the rate-making process to assist in understanding the issues that led to this appeal. PURA establishes a regulatory process for rate-making with a goal of allowing the utility “a reasonable opportunity to earn a reasonable return” after recovering its reasonable and necessary operating expenses. See id. § 86.051. Under PURA, the Commission and individual municipalities share jurisdiction over the regulation of utilities, including the establishment and regulation of rates. 3 To establish a utility’s rates, the appropriate regulatory authority must quantify the utility’s invested capital “used and useful in providing service to the public,” the appropriate rate of return on that invested capital, and the utility’s reasonable and necessary operating expenses. 4 Id. The utility’s reasonable and necessary operating expenses to be included in the utility’s rates may include reasonable rate-case expenses. See id. § 36.061(b)(2) (establishing that “[t]he regulatory authority may allow as a cost or expense ... reasonable costs of participating in a [ratemak-ing] proceeding” in amount that regulatory authority approves).

Oncor is a regulated electric utility company that applied to the Commission for authorization to change its system-wide rates on June 27, 2008 (the “system-wide rate case”). As part of its requested reve *257 nue increase, Oncor initially sought recovery under PURA section 36.061(b)(2) of its reasonable and necessary rate-case expenses totaling $11,477,898.40. After the parties settled the issues related to reasonable and necessary amounts of all expenses and the recoverability of the expenses related to the system-wide rate case, Oncor sought a total of $10,127,047.86 in its own expenses. Of that total, $6,737,009.70 was for Oncor’s expenses incurred directly in connection with the system-wide rate case; $1,540,004.81 was for Oncor’s 2004 and 2005 expenses; and $1,850,053.35 was for Oncor’s Docket No. 34040 expenses.

The 2004 and 2005 expenses stem from two municipal regulatory proceedings. In 2004, 23 cities with exclusive original jurisdiction over Oncor’s rates passed resolutions requiring Oncor to show good cause why its transmission and distribution rates should not be reduced. An additional 87 cities later joined the other cities in the show-cause action. Oncor and the cities reached a settlement in February 2005, which was extended and modified in January 2006. 5 The settlement agreement provided that Oncor would seek recovery of its rate-case expenses from the municipal proceedings in its next system-wide rate case, which it agreed to file by July 1, 2008.

Before Oncor filed a system-wide rate case, Commission staff - filed Docket No. 34040 in August 2007 to review Oncor’s rates. Oncor sought recovery for the 2004 and 2005 expenses and its estimated expenses for Docket No. 34040 as part of its rate-filing package in that proceeding. The parties jointly requested dismissal of the Docket No. 34040 rate case as part of the settlement of another case in which the Commission approved the merger between Oncor’s parent corporation (TXU Corporation) and Texas Energy Future Holdings Limited Partnership. The order of dismissal in Docket No. 34040 did not address Oncor’s requested rate-case expenses. No party requested or obtained recovery of rate-case expenses in the merger case, and the issue of recovery of rate-case expenses was not addressed in the settlement agreement. Like the municipal-cases settlement agreement, the merger-case settlement agreement provided that Oncor would file a system-wide rate case by July 1, 2008.

Oncor filed the agreed-upon system-wide rate case with the Commission on June 27, 2008. As part of its rate-filing package, Oncor again sought recovery for the 2004 and 2005 expenses, and it also sought recovery of its expenses for Docket No. 34040 in addition to its expenses incurred in filing the system-wide rate case. Oncor based its rate-filing package on actual 2007 test-year books and records, adjusted for known and measurable changes. When Oncor filed the system-wide rate case with the Commission, it also filed its application for authorization to change rates and its rate-filing package with each incorporated city in its service area that has original jurisdiction over its rates. After the original-jurisdiction cities passed rate ordinances denying Oncor’s requested increase in rates, Oncor appealed those ordinances to the Commission, and the appeals were consolidated with the system-wide rate case.

*258 In early 2009, the issue of rate-case expenses was severed from the system-wide rate case. As mentioned earlier, the parties entered into a partial settlement of the rate-case expense issues in which they stipulated to the reasonable and necessary amounts and recoverability of the expenses incurred in direct connection with the system-wide rate case.

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Bluebook (online)
406 S.W.3d 253, 2013 WL 3013899, 2013 Tex. App. LEXIS 7334, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oncor-electric-delivery-company-llc-v-public-utility-commission-of-texas-texapp-2013.