City Utilities of Springfield, Missouri v. FERC

Summary

The D.C. Circuit denied consolidated petitions for review challenging FERC's approval of Southwest Power Pool's Section 205 proposal to prospectively reclassify four Sunflower Zone Byway transmission facilities in Kansas as Highway facilities, shifting their remaining costs from the local zone to the SPP region. The court held FERC adequately explained its approval despite favorable zone-wide RCAR benefit-to-cost ratios, reasonably declined to require zone-by-zone benefit quantification under the approximate cost-causation principle, permissibly approved the adjustment notwithstanding Order No. 1000's ex ante cost-allocation requirement, and reasonably relied on SPP's capacity, flow, and benefit studies as substantial evidence. Review was highly deferential because ratemaking involves technical judgments within FERC's expertise. No separate opinions were filed.