Utah Department of Business Regulation v. Public Service Commission

720 P.2d 420, 34 Utah Adv. Rep. 35, 1986 Utah LEXIS 807
CourtUtah Supreme Court
DecidedMay 22, 1986
Docket19361, 19362
StatusPublished
Cited by15 cases

This text of 720 P.2d 420 (Utah Department of Business Regulation v. Public Service Commission) is published on Counsel Stack Legal Research, covering Utah Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Utah Department of Business Regulation v. Public Service Commission, 720 P.2d 420, 34 Utah Adv. Rep. 35, 1986 Utah LEXIS 807 (Utah 1986).

Opinions

ZIMMERMAN, Justice:

The Department of Business Regulation' asks this Court to reverse two orders issued by the Utah Public Service Commission (“PSC”) which allowed Utah Power & Light (“UP & L”) to transfer $6 million from an energy balancing account (“EBA”) to UP & L’s general revenue account. The Department of Business Regulation argues that the PSC’s actions amounted to retroactive rate making. We agree and reverse.

Some background discussion concerning utility rate making is necessary to a consideration of the issues presented. Following lengthy hearings, utility rates are fixed prospectively by the PSC. U.C.A., 1953, § 54-4-4(1), and § 54-7-12(l)-(2) (Repl.Vol. 6A, 1974, Supp.1985). In determining an appropriate rate, the PSC considers the utility's historical income and cost data, as well as predictions of future costs and revenues, and arrives at a rate which is projected as being adequate to cover costs and give the utility’s shareholders a fair return on equity. Utah Department of Business Regulation v. Public Service Commission, Utah, 614 P.2d 1242, 1248 (1980). To provide utilities with some incentive to operate efficiently, they are generally not permitted to adjust their rates retroactively to compensate for unanticipated costs or unrealized revenues. See U.C.A., 1953, § 54-4-4 (Repl.Vol. 6A, 1974, Supp.1985); see also Southern California Edison Co. v. Public Utilities Commission, 20 Cal.3d 813, 144 Cal.Rptr. 905, 905-06, 576 P.2d 945, 945-46 (1978). This process places both the utility and the consumers at risk that the rate-making procedures have not accurately predicted costs and revenues. If the utility underestimates its costs or overestimates revenues, the utility makes less money. By the same token, if a [421]*421utility’s revenues exceed expectations or if costs are below predictions, the utility keeps the excess. Overestimates and underestimates are then taken into account at the next general rate proceeding in an attempt to arrive at a just and reasonable future rate. .

Fuel costs comprise a substantial portion of a utility’s operating expenses. Historically, these costs did not fluctuate wildly. However, in the early 1970’s, rapid and unanticipated escalation of fuel costs had devastating effects on utility earnings. Because of statutory limitations that prohibit utilities from recovering for past underestimates of costs, and the length of time required to obtain a rate increase to adjust for future cost increases, these fuel costs posed a substantial enough threat to the utilities’ financial health to prompt a request for legislative relief.

In 1975, the legislature modified the utility regulation statutes to permit the PSC to deal with the problem of escalating fuel costs outside of general rate-making proceedings. 1975 Utah Laws, ch. 166, § 2. Under this legislation, the PSC was authorized to permit utilities to pass increased fuel costs through to ratepayers without the requirement of lengthy hearings. Tentative orders permitting increased rates adjusted for fuel costs could be entered before detailed hearings on the need for the rate increase were held. Provision was also made for accelerated hearings to determine the need for the increase. In such hearings, the PSC was required to consider only whether there was a need to increase that component of the rate attributable to energy or fuel costs, rather than the overall reasonableness of the rates proposed, as is normally required in general rate proceedings. The legislature was careful to limit such accelerated pass-through procedures to use in connection with increased fuel or energy costs. All other utility costs were to be considered only in general rate-making proceedings.1

Subsequent to and independent of the pass-through legislation, the PSC undertook to design a rather unique device for handling not only the utilities’ unstable fuel costs, but also other cost and revenue items which the PSC felt were subject to rapid and unpredictable fluctuation. This device was the energy balancing account, or “EBA,” that was created in 1979 by order of the PSC. Report & Order, Case No. 78-035-21, 79-035-03, pp. 14-17, paras. 31-34 (July 20, 1979).

The EBA was meant to monitor costs incurred and revenues derived from a number of unstable items. The PSC had found that not only were fuel costs subject to rapid fluctuation, but also revenues from nontariff and surplus energy sales, and the cost of the utilities’ own energy purchases varied widely from year to year. The PSC’s order therefore allows utilities to set up separate energy balancing accounts to keep track of these items of cost and revenue. These items of cost and revenue are apparently not included in fixing the general rates; however, the utilities were authorized to seek the establishment of a separate EBA rate to take into account fore[422]*422casts of these unpredictable cost and revenue items in accelerated rate-making proceedings to be held every six months. The EBA nets the revenues anticipated from nontariff sources and surplus energy sales and the expenses expected to be incurred as a result of purchased energy and fuel costs. The “EBA rate” then is added to the base rate in calculating total charges to a utility’s customers.

Revenues derived from the EBA component of a consumer’s utility bill are segregated and held in the energy balancing account. If the EBA rate has been set too low and the energy balancing account shows a deficit, at the next EBA rate proceeding the utility will seek an increase in the rate. On the other hand, if the EBA shows a surplus, the EBA rate will be adjusted downward at the next proceeding. Report & Order at 16, para. 33. Ideally, over the long term the account is zeroed out, i.e., the revenues flowing into the account will equal the expenditures charged to it. Thus, the EBA accomplishes the purpose of the pass-through legislation to allow expeditious rate response to those elements of cost which are subject to frequent fluctuation, and it does so without bypassing the more formal requirements of general rate making. See U.C.A., 1953, § 54-7-12 (Repl.Vol. 6A, 1974, Supp.1985).

With this background in mind, we consider the instant case. The Department of Business Regulation challenges the PSC’s orders allowing UP & L to divert money accumulated in its EBA into its coffers to make up for an unexpected shortfall in general revenues. The facts leading up to the transfer are as follows: In 1982, UP & L’s tariff sales revenues were $40 million short of projections because of decreases in general consumer demand for energy. This slack in demand meant that UP & L had idle generating capacity, the fixed costs of which were borne by the company’s shareholders. To minimize the resulting loss, UP & L aggressively sought non-tariff customers for energy that could be generated from these idle facilities, and it managed to make sales totaling $18 million. This $18 million was placed in the utility’s energy balancing account, rather than its general revenue account, because it was revenue produced from nontariff sales.

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Bluebook (online)
720 P.2d 420, 34 Utah Adv. Rep. 35, 1986 Utah LEXIS 807, Counsel Stack Legal Research, https://law.counselstack.com/opinion/utah-department-of-business-regulation-v-public-service-commission-utah-1986.