Rate Case Process Workshop

In November 2018, the Staff of the Commission asked the Commission to open a workshop titled: “In the Matter of a Workshop Docket to Explore the Ratemaking Process,” and filed a draft rule for discussion that would significantly shorten the time taken to process a rate increase request.  A workshop was held shortly after that filing and consumer representatives and utilities filed comments in the workshop docket in January 2019, but no further action has taken place and the future course of the workshop is unclear. 

Electric Vehicle Workshop

This workshop is intended to help the Commission find the best solutions for developing Missouri’s EV charging network as quickly as practicable. A workshop was held in March and a number of interested entities filed supplemental comments in April.  The issue addressed in this workshop is one that the Commission as a whole is very interested in, and it appears likely that the Commission will use this workshop as a vehicle to continue to gather information and develop policies. 

Electric Utilities Capital Plan Filings

One of the provisions of Senate Bill 564 (passed in 2018), now codified as Section 393.1400.4, requires electric utilities that take advantage of the provisions of that legislation to annually file a capital investment plan. Utilities are required to file detailed information for the first year of the plan, and more general information covering five years. Ameren Missouri, Kansas City Power & Light Company, and KCP&L Greater Missouri Operations Company all filed capital plans in February 2019.  The legislation does not provide for much opportunity for stakeholders to comment on the plans, and gives the Commission no authority to approve (or disapprove) the plans. Nonetheless, the filings do provide a little bit of increased transparency, which is always helpful.


The 2018-2019 legislative session ended with just one significant change to public utility laws.  House Bill 220 changes the way that wind farms are taxed, so that more of the tax benefit accrues to the county in which the wind farm is located instead of being allocated among all the counties where the utility has facilities.  HB 220 does not change the overall amount of taxes paid, so there will not be an impact on utility rates.

In addition to the wind farm taxation bill, several pieces of significant utility legislation were considered, and although none passed, it is worth discussing one that is likely to reappear in future sessions.  One piece of legislation that is likely to be reintroduced next year is the one that changes the Infrastructure System Replacement Surcharge (ISRS) for water utilities.  The legislation would change the acronym ISRS to IRRA, for Infrastructure Resilience Rate Adjustment, and would expand its use in a number of ways.  First, it would geographically expand its availability to the entire state; its use is currently limited to St. Louis County. Second, it would expand its availability to all water and sewer utilities. Third, it would increase the amount of money a utility could collect under the surcharge mechanism to fifteen percent of the utility's base revenue requirement from the current ten percent limit. The ISRS (or IRRA) is a single-issue surcharge; that is, it is a mechanism that allows utilities to raise rates when one specific cost goes up, even if other costs are going down.  As such, it is almost by definition detrimental to consumers.

Related Practices