Alaska Exchange Carriers Ass'n v. Regulatory Commission, 262 P.3d 204

AECA discovered an error in AECA's 2007 Rate Development Workpapers six weeks after RCA closed the 2007 access charge proceedings.
The error stemmed from a failure to link spreadsheet cells correctly, affecting five rates and altering the dial equipment minutes subsidy.
The net effect was underbilling of $677,503.42 for 2007.
AECA sought correction; RCA approved the corrected rates prospectively but questioned retroactive application.
GCI urged retroactive ratemaking prohibition under Matanuska Electric Association v. Chugach Electric Association; AECA urged retroactive relief.
The superior court upheld the RCA’s prospective-only relief; AECA appealed, arguing procedural mistakes may warrant retrospective correction; the court remands to the RCA to classify the error and determine retroactive applicability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the RCA properly denied retroactive application of the corrected rates.	AECA argues the error is procedural and should be corrected retroactively.	GCI/RCA contend retroactive ratemaking principle bars retroactive relief.	Remanded to RCA to determine the type of error and potential retrospective application.
Whether the error constitutes a procedural/mathematical mistake rather than a second-look adjustment.	AECA characterizes the error as a clerical/mathematical mistake that can be corrected.	GCI argues the process after stipulations makes the error more substantial (not merely ministerial).	Court finds potential procedural/mathematical mistake; remand to classify appropriately.
Whether the RCA has authority to determine the type of mistake and implement corrective rates retroactively if appropriate.	AECA contends RCA has power to correct procedural errors.	RCA previously limited itself by retroactive ratemaking concerns.	RCA has authority to determine the type of mistake and may apply corrections retroactively on remand.
What is the proper effective date for correcting a procedural mistake?	AECA supports earlier dates based on stipulations or notice.	RCA's November 2, 2007 notice should set the correction date.	Court allows correction starting August 21, 2007 (date of notice) unless detrimental reliance shown; remand to RCA for final determination.

Matanuska Elec. Ass'n, Inc. v. Chugach Elec. Ass'n, Inc., 53 P.3d 578 (Alaska 2002) (retroactive ratemaking prohibition in second-look cases; outlines rationale and limits)
Mike Little Gas Co. v. Pub. Serv. Comm'n, 574 S.W.2d 926 (Ky. App. 1978) (procedural/clerical errors may be corrected; not true ratemaking)
Illinois Power Co. v. Illinois Commerce Comm'n, 254 Ill.App.3d 293, 193 Ill. Dec. 403, 626 N.E.2d 713 (Ill. App. 1994) (ministerial vs. policy-based errors; correction allowed for certain mathematical errors)
Indiana Office of Utility Consumer Counselor v. Duke Energy Indiana, Inc., 896 N.E.2d 936 (Ind.App. 2008) (accounting corrections not treated as retroactive ratemaking when correcting balances per guidelines)
General Motors Corp. v. Pub. Serv. Comm'n, 175 Mich.App. 584, 438 N.W.2d 616 (Mich. App. 1988) (substantive change based on changed circumstances deemed not permitable retroactively)
Bldg. Owners and M'grs Ass'n of Metro. Detroit v. Mich. Pub. Serv. Comm'n, 383 N.W.2d 72 (Mich. 1986) (rate order validation not retroactive rate increase when based on procedural flaw)