Alaska Exchange Carriers Association, Inc., Appellant v. Regulatory Commission of Alaska, General Communications…

Summary

The court reaffirmed that rates may not be revised retroactively merely because later information shows that an approved projection was inaccurate, but held that this prohibition does not categorically bar correction of procedural, clerical, or mathematical mistakes. Because AECA's spreadsheet error might have been a procedural mistake that did not implicate the reliance and efficiency concerns underlying the rule, the court remanded for the RCA to determine the error's character and whether retrospective correction was appropriate. Justice Winfree would have left the corrective date entirely to the RCA, while Justice Stowers would have treated the correction as non-ratemaking and required correction from the original effective date.