Missouri Public Service Commission Missouri Cases

Missouri-American Water Company appealed a Public Service Commission order approving a change to its infrastructure system replacement surcharge (ISRS). The company challenged the Commission's exclusion of estimated net operating loss (NOL) from the ISRS calculation, arguing it violated statutory requirements and IRS regulations. The appellate court affirmed the Commission's order, finding no error in its decision to exclude the estimated NOL.

Orange Lake Country Club, Inc. and Silverleaf Resorts, Inc. appealed a Missouri Public Service Commission (PSC) order approving water and sewer utility rate increases for Liberty Utilities (Missouri Water) LLC. Orange Lake challenged the lawfulness of the PSC's Small Utility Rate Case Procedure (SURP), Liberty's qualification as a small utility, and the PSC's evidentiary rulings regarding expert testimony. The appellate court affirmed the PSC's order, finding the SURP lawful, the PSC's interpretation of "customer" reasonable, and no abuse of discretion in the evidentiary rulings.

The Missouri Public Service Commission granted Staff's motion for summary determination, finding Union Electric Co. (Ameren) violated a Commission rule by failing to use updated 2014 data to calculate its "net shared benefits" under an energy-efficiency plan. Ameren appealed, arguing the Commission misinterpreted the term "methodology" in Rule 20.093(1)(F) and that its approved Plan did not require such updates. The Missouri Supreme Court reversed, holding that "methodology" refers only to the formula, not the values of variables, and that the Plan unambiguously did not require updating avoided costs estimates.