By Bridgot Gysbers, Senior Fiscal Consultant

Completing a conventional water rate case with the Wisconsin Public Service Commission (PSC) can be a complex and lengthy process. There are ways, however, that utilities can plan strategically to reduce delays and streamline the process.  Read on to explore Best Practices to help you file efficiently and keep your review on track.

File at the Right Time

Submit an application during the appropriate test year window. Filing at the right time ensures your rate aligns with PSC requirements and reduces the risk of revisions. For example, 2026 test year applications are being accepted through July 31, 2026, while filing using the 2027 test year will begin August 1, 2026.

In addition, many utilities will wait to file applications close to the July 31^st deadline, creating a large case load for PSC staff. Filing the application well in advance of July 31^st can reduce wait time before a PSC auditor begins reviewing your application.

Organize Data Early

Start collecting financial, operational, and capital investment data months in advance. Accurate and well-organized records, covering revenues, expenses, depreciation, and rate base, facilitate faster reviews by PSC staff if prepared at the time of application. Having this data well organized and submitted as part of the rate application also reduces needless data requests trying to clarify supporting data.

Conduct Supporting Cash Flow Analysis

It is often necessary to have detailed supporting analysis such as a long-range cash flow to help explain how alternative revenues such as tax incremental financing, impact fees or other revenues interact with the finances of the water utility. Analysis like this is also essential if the utility plans to request a lower rate of return as part of the rate application.

Ensure Accuracy of PSC Annual Reports

The bulk of questions from PSC staff during a rate case are based upon information reported in past year’s PSC annual reports. It is extremely helpful when information included is accurate and well-articulated. If you notice a discrepancy in a previous annual report, it is important to correct that prior to filing the rate application as it will reduce the number of data requests during the application process. Further, providing basic descriptions to operating or plant in service cost changes such as “costs went up” is not helpful and most certainly will warrant follow up questions from PSC staff. Providing well thought out descriptions to cost variations can reduce questions from PSC staff, and provide utility staff with better information on anomalies in data from past years.

Ensure Construction Approvals

Verify that any planned capital projects have the necessary PSC construction approvals before including them in your filing. Approved projects are easier to justify and support in your rate case.

Utilize Simplified Rate Cases (SRC)

Avoiding the conventional rate case process altogether is the most efficient method for increasing user rates. If eligible, the PSC’s SRC process can dramatically shorten the review time while providing an inflationary increase to user rates. Evaluate whether your filing qualifies for SRC to reduce the administrative burden while still achieving your rate objectives.

Address Data Request Promptly

PSC will most certainly request clarification and/or additional documentation after your initial filing. Responding quickly and thoroughly to these requests keeps your case moving and prevents unnecessary delays.

Engage with PSC Staff Early

Early communication with the PSC staff can clarify expectations, identify potential issues, and ensure your application meets current requirements. Proactive engagement can help avoid common pitfalls and streamline review. This is especially true if you have a unique circumstance as part of your rate application. Discussing the situation up front provides PSC staff with an early alert of an upcoming request or situation and allows for them to dialogue with the utility on additional data they will need to review the request or circumstance.

Leverage Industry Knowledge

Tap into lessons learned from previous filings across the water industry. Utilizing benchmarking against peers can help anticipate PSC questions and improve the quality and completeness of your filing.

Careful planning, early preparation, and proactive engagement are the keys to a smoother rate filing. By following these best practices you can minimize delays, improve efficiency, and support timely approval of your rates.

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