Public Service Commission of the State of Missouri Missouri Cases

Liberty, an electric utility, appealed from a Public Service Commission order that approved securitization of costs in a lesser amount than requested for the retirement of its Asbury coal plant and for extraordinary costs incurred during Winter Storm Uri. Liberty argued the Commission's calculations for energy transition costs, fuel and power costs, and carrying charges violated the securitization statute, lacked substantial evidence, and were unreasonable. The appellate court affirmed the Commission's Amended Report and Order, finding its determinations lawful and reasonable and supported by the record.

Spire Missouri, Inc., an investor-owned public utility, appealed an Amended Report and Order from the Public Service Commission (PSC) regarding its proposed rate increases. The PSC disallowed a portion of Spire's rate case expenses, included some proceeds from a facility sale in rate-setting, and determined a lower value for Spire East's prepaid pension asset. The Missouri Supreme Court affirmed the PSC's decisions on rate case expenses and the facility sale, but reversed and remanded the PSC's determination regarding a portion of Spire East's pension asset, finding it unsupported by competent and substantial evidence.

Eastern Missouri Landowners Alliance and Joseph and Rose Kroner appealed the Public Service Commission's order approving the sale of Grain Belt Express Clean Line LLC to Invenergy Transmission LLC. Appellants contended the Commission lacked statutory authority because Grain Belt was not an "electrical corporation" and the sale did not transfer "necessary or useful" assets. The appellate court affirmed the Commission's order, finding the "electrical corporation" issue was barred by collateral estoppel and that Grain Belt's assets qualified as "electric plant" under the statute.