Manufacturers’ advocacy group and environmental advocacy organization sought judicial review of decision of the Public Utilities Commission approving and adopting prudence and performance audits of electric-distribution utilities’ legacy-generation-resource riders.
The Supreme Court held that:
- Commission did not abuse its discretion in excluding testimony of expert witness;
- Commission did not commit reversible error in improperly determining that utilities could not be held accountable for any imprudent decisions regarding commitment strategy utilized for legacy-generation resource for particular year;
- Group failed to show that Commission’s determination as to reasonableness of commitment strategy was against manifest weight of evidence;
- Group failed to show that Commission’s determination as to reasonableness of costs incurred by utilities lacked record support;
- Organization failed to show that Commission’s prudence determination as to commitment strategy violated statute requiring opinion supported by record and setting forth Commission’s rationale;
- Commission’s improper application of presumption of prudence to utilities’ management decisions was not reversible error; and
- Commission was not required to evaluate whether utilities’ actions benefited ratepayers and public interest under a reasonableness standard.