The Delaware Division of the Public Advocate v. The Delaware Public Service Commission

CourtSuperior Court of Delaware
DecidedDecember 30, 2016
DocketN15A-12-002 AML
StatusPublished

This text of The Delaware Division of the Public Advocate v. The Delaware Public Service Commission (The Delaware Division of the Public Advocate v. The Delaware Public Service Commission) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Delaware Division of the Public Advocate v. The Delaware Public Service Commission, (Del. Ct. App. 2016).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

THE DELAWARE DIVISION OF ) THE PUBLIC ADVOCATE, ) ) Appellant, ) ) C.A. N15A-12-002 AML v. ) ) THE DELAWARE PUBLIC ) SERVICE COMMISSION, ) ) Appellee. )

Submitted: September 13, 2016 Decided: December 30, 2016

MEMORANDUM OPINION

Regina A. Iorii, Deputy Attorney General, STATE OF DELAWARE, DEPARTMENT OF JUSTICE, Wilmington, Delaware; Attorney for the Delaware Division of the Public Advocate.

Brenda R. Mayrack, Deputy Attorney General, STATE OF DELAWARE, DEPARTMENT OF JUSTICE, Dover, Delaware; Attorney for the Delaware Public Service Commission.

LeGROW, J. This is an appeal from a decision of the Delaware Public Service

Commission. The appellant, the Delaware Division of the Public Advocate,

contends the Commission erred in construing a statute that governs the

circumstances under which utility companies may be exempt from a state law

requiring them to purchase a percentage of their electric supply from renewable

resources. That statute grants the Commission explicit authority to promulgate

regulations regarding procedures for how the minimum renewable energy purchase

requirement may be frozen. Despite this explicit statutory grant of rule-making

authority, the Commission concluded it nevertheless lacks the authority to

promulgate the type of regulations the DPA contends the Commission should have

adopted. I conclude the Commission’s interpretation of the statute constituted

legal error and therefore reverse and remand.

BACKGROUND AND PROCEDURAL HISTORY

In 2005, the Delaware General Assembly enacted the Renewable Energy

Portfolio Standards Act, 26 Del. C. §§ 351-364 (“REPSA”), requiring all regulated

Delaware electric utilities to purchase a percentage of their electric supply from

renewable and solar resources. Those purchase requirements are referred to herein

as the “minimum renewable energy purchase requirements.” In 2010, the General

Assembly amended Section 354 of REPSA to permit the Department of Natural

Resources and Environmental Control (“DNREC”) and the Public Service

1 Commission (the “Commission”), “in consultation” with each other, to freeze the

minimum renewable energy purchase requirements for regulated utilities under

certain circumstances, namely when the cost of compliance exceeds certain

thresholds. As amended, Section 354(i) and (j) provides:

(i) [DNREC] in consultation with the Commission, may freeze the minimum cumulative solar photovoltaics requirement for regulated utilities if [DNREC]* determines that the total cost of complying with this requirement during a compliance year exceeds 1% of the total retail cost of electricity for retail electricity suppliers during the same compliance year. In the event of a freeze, the minimum cumulative percentage from solar photovoltaics shall remain at the percentage for the year in which the freeze is instituted. The freeze shall be lifted upon a finding by [DNREC], in consultation with the Commission, that the total cost of compliance can reasonably be expected to be under the 1% threshold. The total cost of compliance shall include the costs associated with any ratepayer funded state solar rebate program, SREC purchases, and solar alternative compliance payments.

(j) [DNREC] in consultation with the Commission, may freeze the minimum cumulative eligible energy resources requirement for regulated utilities if [DNREC] determines that the total cost of complying with this

 The statute refers to the State Energy Coordinator, who is an employee of DNREC, and the Delaware Energy Office, which is or was a part of DNREC. I refer to both the State Energy Coordinator and the Delaware Energy Office as DNREC for clarity. The parties agree that the statutory references to the State Energy Coordinator and the Delaware Energy Office are to DNREC for all practical purposes. See Appellant’s Opening Br. 1 n.2; Appellee’s Resp. Br. 5 n.4. 2 requirement during a compliance year exceeds 3% of the total retail cost of electricity for retail electricity suppliers during the same compliance year. In the event of a freeze, the minimum cumulative percentage from eligible energy resources shall remain at the percentage for the year in which the freeze is instituted. The freeze shall be lifted upon a finding by [DNREC], in consultation with the Commission, that the total cost of compliance can reasonably be expected to be under the 3% threshold. The total cost of compliance shall include the costs associated with any ratepayer funded state renewable energy rebate program, REC purchases, and alternative compliance payments.

Also in 2010, the General Assembly added subsection (b) to Section 362 of

REPSA. That new subsection pertinently provides:

For regulated utilities, the Commission shall further adopt rules and regulations to specify the procedures for freezing the minimum [renewable energy purchase]1 requirement as authorized under § 354(i) and (j) of this title . . . .

Section 362 is the only explicit statutory reference to rule-making authority

relating to freezing the minimum renewable energy purchase requirements.

In May 2011, the Commission issued regulations purporting to implement

Section 354(i) and (j) in accordance with the Commission’s authority under

Section 362(b) (the “Commission’s Regulations”). These regulations state:

1 The statute refers only to the “cumulative solar photovoltaic” requirement in Section 354(i), but the parties agree that Section 362(b) includes both the solar photovoltaic requirement and the eligible energy resources requirement. 3 3.2.21 The minimum percentages from Eligible Energy Resources and Solar Photovoltaic Energy Resources as shown in Section 3.2.1 and Schedule 1 may be frozen for CRECs as authorized by, and pursuant to, 26 Del.[]C. § 354(i)-(j). For a freeze to occur, [DNREC] must determine[] that the cost of complying with the requirements of this Regulation exceeds 1% for Solar Photovoltaic Energy Resources and 3% for Eligible Energy Resources of the total retail cost of electricity for Retail Electricity Suppliers during the same Compliance Year. The total cost of compliance shall include the costs associated with any ratepayer funded state renewable energy rebate program, REC and SREC purchases, and ACPs and SACPs alternative compliance payments.

3.2.21.1 Once frozen, the minimum cumulative requirements shall remain at the percentage for the Compliance Year in which the freeze was instituted.

3.2.21.2 The freeze may be lifted only upon a finding by [DNREC], in consultation with the Commission, that the total cost of compliance can reasonably be expected to be under the 1% or 3% threshold, as applicable.

On October 2, 2015, the Delaware Public Advocate (the “DPA”) filed a

petition with the Commission to re-open the rule-making docket and promulgate

additional regulations. Specifically, the DPA sought to amend the Commission’s

Regulations to specify when a freeze of the minimum renewable energy purchase

requirements may be declared under Section 354 (i) and (j) (the “DPA’s Petition”).

In other words, the DPA sought detailed regulations from the Commission

4 regarding how and when the cost of compliance with the minimum purchase

requirements and the total retail cost of electricity would be calculated.

The Caesar Rodney Institute (“CRI”) filed a petition supporting the DPA’s

Petition (considered jointly with the DPA’s Petition, the “Petition”). DNREC then

filed a petition to intervene in the docket, and the Commission staff and DNREC

jointly opposed the Petition. The DPA and CRI filed a joint response, and eight

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