United Illuminating Co. v. Public Utilities Regulatory Authority
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The plaintiff, an electric distribution company, appealed from the trial court's dismissal of its consolidated administrative appeals from two final decisions by the Public Utilities Regulatory Authority (PURA). PURA had found the plaintiff violated statutory obligations related to emergency planning and storm recovery during an August 2020 tropical storm, intending to reduce the plaintiff's authorized return on equity (ROE) by fifteen basis points. Additionally, PURA imposed over $1.2 million in fines for violating storm performance standards and $61,000 in civil penalties for late reporting of minor accidents.
The trial court dismissed the plaintiff's appeals, upholding PURA's decisions. The plaintiff then appealed to the higher court, challenging the ROE reduction, the fines for storm performance violations, and the penalties for late accident reporting. During the appeal, PURA decided not to implement the ROE reduction, rendering the issue moot. The court determined that neither the voluntary cessation nor the collateral consequences exceptions to the mootness doctrine applied. The court directed the vacatur of the portion of PURA's order authorizing the ROE reduction and the corresponding part of the trial court's judgment.
Regarding the fines for late reporting of minor accidents, the court concluded that the failure to report a minor accident did not qualify as a "continued violation" under the statute. Instead, each monthly failure to report constituted a single, distinct violation. The case was remanded to the trial court to order PURA to recalculate the penalties accordingly.
The court found sufficient evidence to support PURA's findings that the plaintiff violated storm performance standards by failing to provide a dedicated make safe crew for Bridgeport and inadequately communicating with city officials. The court affirmed the trial court's judgments in all other respects.
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