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

Summary

The court held that the prohibition on retroactive ratemaking applies to retrospective adjustments based on inaccurate projections, but does not categorically bar correction of procedural or clerical mistakes in a rate calculation. Because the RCA had authority and expertise to determine whether the spreadsheet error was procedural and whether retrospective correction was appropriate, the court vacated the superior court's decision and remanded. If correction is warranted, the RCA may generally correct the rate from the date public notice of the mistake was given, subject to detrimental reliance. Justice Winfree would have left the corrective date entirely to the RCA, while Justice Stowers would have treated the error as a non-ratemaking clerical correction and required correction from the original effective date.