Opinion
Opinion By: Jack Conway,Attorney General;Amye L. Bensenhaver,Assistant Attorney General
Open Records Decision
On behalf of Earthjustice and the Sierra Club, Shannon Fisk appeals the Owensboro Municipal Utilities Commission's (the "Commission's") partial denial of his July 18, 2014 multi-part request 4 for a copy of OMU's 2013 Integrated Resource Plan (the "IRP"), related supporting documents. The Commission responded to Mr. Fisk's request on July 25, 2014 by releasing nine records deemed responsive. The Commission denied him access to the 2013 IRP and the majority of the "related documents" based on KRS 61.878(1)(i) and (j). The Commission characterized the IRP as "a draft document that contains opinions and preliminary recommendations, " explaining that the Commission "is the public agency that governs and controls the utility" and that the Commission "has not taken final action on the draft . . . ." Because the IRP is non-final, the Commission asserted, "related documents" used in formulating the IRP are necessarily non-final. At various points throughout its response the Commission stated that "no action was required or taken by the Utility Commission regarding the IRP or the [PowerPoint] presentation" conducted by OMU for the instruction of Owensboro officials on August 1, 2013. The Commission relied on KRS 61.878(1)(c)1., in addition to KRS 61.878(1)(i) and (j), in denying Mr. Fisk's request for "[a]ny projection of future coal prices and supplies," explaining that it received these projections "from a consultant under a pledge of confidentiality." It denied several other requests based on the nonexistence of responsive records.
In his letter of appeal, Mr. Fisk explained that an IRP is "a plan developed by the utility for meeting forecasted energy needs." In it, he advised, "a utility will typically evaluate several options to meeting future energy needs with the goal of selecting and implementing a 'least cost' plan as the utility's 'preferred resource plan.'" In August 2013 OMU summarized the results of the 2013 IRP to Owensboro officials. 5 In that presentation, Mr. Fisk stated, OMU:
explained that its resource assessment led to a 'Five Year Plan' that includes continuing to operate the Elmer Smith Unit 2 power plant 'indefinitely,' and beginning 'pre-retirement planning' for Elmer Smith Unit 1, with a target retirement date of October 2025 [and provided a] bullet point summary of the economic modeling that went into developing the plan, the key issues that were considered, and the evaluation of potential new electric generating sources.
In July 2014, Mr. Fisk submitted his request and received the Commission's partial denial.
On appeal, Mr. Fisk argues that the IRP is not a preliminary draft, note, recommendation, or memorandum in which opinions are expressed or policies formulated but that it is, instead, "a final, completed fully conceptualized plan in itself." Noting that in the course of the IRP process OMU considered eight supply side options and determined that "[the Elmer Smith Station] is the lowest cost power supply option for OMU's customer-owners," he asserted that OMU "adopted as its 'preferred resource plan' the indefinite operation of Elmer Smith Station Unit 2 and the continued operation of Elmer Smith Station 1 until approximately 2025." Mr. Fisk identified as other evidence that the IRP was adopted:
. a November 2013 prepared statement by OMU General Manager/CEO Terry Naulty to the Owensboro Board of Commissioners in which he referred to the 2013 IRP as "OMU's recently completed Integrated Resource Plan";
. the adoption of a budget allocating more than $ 28 million in capital projects at the Elmer Smith Station Units for fiscal year 2014 and confirming "major investment commitments" in the units based on the 2013 IRP;
. the Commission's admission, in its July 2014 response to Mr. Fisk's request, that there are no "analyses, reports, or documents that update, supplement, or revise the 2013 IRP" and therefore no formal and final written product forthcoming to which the IRP is "preliminary."
Mr. Fisk focused on the statement, appearing throughout the Commission's response to his request, that "no action was required or taken" by the Commission on the IRP or the PowerPoint presentation relating to it. It was his position that Commission action is unnecessary because OMU is itself a public agency whose records are governed by the Open Records Act. To find otherwise, Mr. Fisk concluded, promotes circumvention of the Act by permitting the Commission to thwart public access to "preliminary" records by indefinitely postponing final action on those records.
Challenging the Commission's denial of other portions of his request, Mr. Fisk maintained:
. the Commission's denial of his request for "related documents" based on KRS 61.878(1)(i) and (j), fails because the documents formed the basis of the 2013 IRP and were adopted into final action by implementation of the 2013 IRP;
. even if the IRP is a preliminary document, the "related documents" are not necessarily preliminary drafts, notes, or correspondence with private individuals or preliminary recommendations or memoranda in which opinions are expressed or policies formulated within the meaning of KRS 61.878(1)(i) and (j);
. the Commission provides insufficient information to support its claim that the "related documents" are preliminary but instead merely recites the language of the exceptions or restates that the IRP is exempt;
. the Commission's reliance on KRS 61.878(1)(c)1. to support nondisclosure of a consultant's report procured by the Commission for the Commission's use is misplaced since that exemption can only be invoked upon presentation of proof that the information disclosed to the Commission is generally recognized as confidential or proprietary and that the entity confidentially disclosing it to the Commission would be placed at an unfair commercial disadvantage if it were disclosed;
. the Commission uses conditional language in responding to a number of requests ("if the requested records exist, they are preliminary") and the law does not permit conditional responses.
On these bases, Mr. Fisk asked that the Attorney General issue a decision affirming his right of access to the records withheld.
In response, the Commission defended the adequacy of its responses to Mr. Fisk's requests and clarified its role in relation to OMU:
The Utility Commission is a body corporate and politic that is owned by the City of Owensboro, but that is a separate entity whose members are appointed by the Mayor of the City, with the approval of the Board of City Commissioners. The Utility Commission does business as "Owensboro Municipal Utilities," but the Utility Commission is the "public agency" which governs and has absolute control of the utility. KRS 96.530(1). The Utility Commission, as the governing body of Owensboro Municipal Utilities, is the entity which takes "final action, " as that term is contemplated by the Kentucky Open Meetings Act ("OMA") and the ORA.
Turning to its decision to prepare an IRP, the Commission explained:
[T]here is no legal requirement that the Utility Commission adopt an Integrated Resource Plan. While utilities that are governed by the Kentucky Public Service Commission ("PSC") may be required to submit an IRP to the PSC, the Utility Commission is not subject to the jurisdiction of the PSC, nor is it required by law to adopt or implement an IRP. KRS 278.010(3). If the employees or consultants of OMU draft an IRP, and even summarize the draft in a presentation to the Utility Commission, the draft does not lose its preliminary status unless it is adopted through final action by the Utility Commission.
Focusing on the critical issue of final agency action, the Commission confirmed:
No 'final action' has been taken by the Utility Commission on the draft 2013 IRP. A public agency speaks only through its records. [Footnote omitted.] '[T]he rule is that the governing body of a municipal corporation such as a board of education can speak only through its records and can confer authority to make or terminate contracts only by proper proceedings at a meeting regularly called and held when its acts are duly recorded and authenticated.' Lewis v. Board of Education of Johnson County, 348 S.W.2d 921, 923 (Ky. 1961). 'The formal records of such municipal corporation constitute the only legal evidence of all that was done by any such corporation and that nothing more was done.' Id .
The minutes of the Utility Commission do not show that any final action was taken regarding the IRP. As noted by the Appellant, the draft 2013 IRP envisions 'beginning "pre-retirement planning" for Elmer Smith Unit I, with a target retirement date of October 2025.' Appeal, p. 1. However, the Utility Commission has not yet taken any final action on this recommendation, and thus, it has not been determined when, or even if, pre-retirement planning for Unit 1 should begin.
Citing 06-ORD-254 (affirming the preliminary draft status of a report prepared by the Governor's Blue Ribbon Panel "[s]o long as the potential exists that one word will be changed, one correction made, or one sentence added or deleted" and "until such time as it is formally and finally adopted by the Blue Ribbon Panel").
The Commission refuted, point by point, Mr. Fisk's claims that OMU impliedly adopted the IRP, asserting that:
. OMU has no authority to take final action on the IRP but is, instead, governed by the Commission which alone is vested with final decision making authority;
. OMU's PowerPoint presentation to the Commission was described as a recommendation, and not an accomplished fact, on the first slide;
. public discussion of the IRP did not vitiate the claim of exemption under KRS 61.878(1)(i) and (j) as interpreted in 00-ORD-195 (affirming agency denial of a request for a consultant's report, notwithstanding public discussion of the report, where no final action had been taken on the report);
. 11-ORD-101, upon which Mr. Fisk chiefly relies to support his argument of implied adoption, is inapposite because the final decision maker in that case formally and finally acted upon the proposal in a consultant's report but continued to improperly withhold the report under KRS 61.878(1)(i) and (j) because a contract implementing the proposal had not been executed;
. the Commission's adoption of a budget that included expenditures for planned outages for Elmer Smith Units 1 and 2 was entirely unrelated to the 2013 IRP. 6
Finally, the Commission defended its reliance on KRS 61.878(1)(c)1., as well as KRS 61.878(1)(i) and (j), to support nondisclosure of "[a]ny projection of future coal prices and supplies prepared by or for OMU since 2012 and any analysis, study, or report providing the basis for such projection. " The Commission distinguished those open records decisions declaring that KRS 61.878(1)(c)1. does not extend protection to a consultant's report prepared for the agency at agency expense. It was the Commission's position that its invocation of the exception was aimed at protecting "proprietary information furnished or employed by a consultant or the consultant's models" and not its own "operational and financial records created . . . in the normal course of business."
Although Mr. Fisk presents well researched and well reasoned arguments in support of his position, one irrefutable fact precludes resolution of this appeal in his favor: KRS 96.530(1) vests "absolute control" of OMU in the Owensboro Utilities Commission, and the record is devoid of evidence that the Commission has taken final action on the 2013 IRP. Notwithstanding the passage of well over a year since it was first presented in summary to the Commission, the IRP remains a preliminary draft under KRS 61.878(1)(i), as well as a preliminary recommendation under KRS 61.878(1)(j). 7 It follows that related documents supporting the IRP have not "become a part of the records adopted by the [Commission] as the basis of its final action, " but remain exempt under KRS 61.878(1)(i), KRS 61.878(1)(j), or both. However, the Commission's original denial of Mr. Fisk's extensive open records request vis-a-vis "related documents" was not, in all cases, "detailed enough to permit the [reviewer] to assess its claim and the opposing party challenge it." Kentucky New Era at 82. It is therefore incumbent on the Commission to "provide particular and detailed information" in response to all requests seeking "related documents" for which a "limited and perfunctory response was provided. Edmondson at 858.
KRS 96.530(1) provides, in part:
Any city acquiring or constructing an electric light, heat, and power plant under the provisions of KRS 96.520 shall, by ordinance, appoint a city utility commission consisting of three (3) commissioners to operate, manage, and control the plant, except that a city with a population equal to or greater than twenty thousand (20,000) based upon the most recent federal decennial census shall appoint five (5) commissioners. The utility commission shall have absolute control of the plant in every respect, including its operation and fiscal management and the regulation of rates . . . . The utility commission, when so appointed, shall be a public body politic and corporate, with perpetual succession; and the body may contract and be contracted with, sue and be sued, in and by its corporate name, and have and use a corporate seal. The utility commission shall provide rules for the management of the plant, and it shall fix the number, qualifications, pay, and terms of employment of all employees needed to operate the plant. 8
(Emphasis added.) OMU cannot act on the IRP, except in excess of its delegated authority, until the Commission approves it.
The parties to this appeal have engaged in a sufficiently detailed and accurate analysis of the authorities construing KRS 61.878(1)(i) and (j) to obviate the necessity of a restatement of the law. Ultimately, we are aware of no legal authority supporting Mr. Fisk's position that final action can be inferred. Finalization and implementation by OMU of the IRP without Commission approval is prohibited by statute and therefore cannot be inferred from PowerPoint presentations, statements made by OMU officials, the adoption of a budget, or responses to his open records request. While it remains unclear to us why the Commission responded to that request by stating that "no action was required or taken by the Utility Commission regarding the IRP or the [PowerPoint] presentation, " the Commission provided adequate proof of the necessity of Commission approval of the IRP in its supplemental response to meet its burden of proof. Moreover, the Commission did not deny Mr. Fisk's requests in toto , but provided him with nine responsive records. Consistent with the position recently taken by the
Kentucky Supreme Court in University of Louisville v. Sharp, 416 S.W.3d 313, 315 (Ky. 2013), we find that "piecemeal disclosure along the path of the decision-making process is not mandatory" and affirm the Commission's partial denial of Mr. Fisk's request. 9
Related preliminary documents supporting a preliminary draft or recommendation cannot be said to have forfeited their preliminary status before final action is taken on the draft or recommendation they support. Any argument to the contrary is a non sequitur . It is only after final action is taken, and the records "are adopted by the [agency] as part of its action, that the preliminary characterization is lost, as is the exempt status." Board of Medical Licensure at 956. "Unless so adopted and made a part of the [agency's] final action, such documents remain excluded under Subsection [(i) and (j)] of the Act." Id . In the absence of evidence of final action by the Commission on the IRP, we must also affirm its denial of Mr. Fisk's request for related documents. Because we affirm the Commission's denial of that request on the basis of KRS 61.878(1)(i) and (j), we are not required to determine whether it also properly invoked KRS 61.878(1)(c)1. to deny his request for "projections of future coal prices and supplies prepared by or for OMU since 2012" and analyses, studies, or reports supporting these projections. The analyses, studies, and reports supporting them are, perforce, preliminary drafts, notes, recommendations or memoranda exempted from disclosure by KRS 61.878(1)(i) and (j) until finally acted upon.
Having so concluded, we are nevertheless obliged to comment on the Commission's failure to provide sufficient detail in its original and supplemental responses to Mr. Fisk's request. While the Commission is not "obliged in all cases to justify nondisclosure on a line-by-line or document-by-document basis . . . . [a]t least with respect to voluminous ORA requests, such as [here], it is enough if the agency identifies the particular kinds of records it holds and explains how the release of each assertedly exempt category would harm the agency in a prospective enforcement action."
City of Ft. Thomas v. Cincinnati Enquirer, 406 S.W.3d 842-851-2 (Ky. 2013). When the agency adopts this generic approach it must still "identify and review its responsive records, release any that are not exempt, and assign the remainder to meaningful categories . . . . [a] category is meaningful if it allows the [reviewer] to trace a rational link between the nature of the document and the [exemption claimed]." Id . (quotation removed). The Commission failed to assign the responsive records to (at a minimum) meaningful categories, in order to allow Mr. Fisk or this office to trace the link between the records and the non-final IRP at issue here. Accordingly, it must do so.
We are mindful that the conclusion we reach, although consistent with the Open Records Law, could, in the wrong hands, promote circumvention of the Act through the subterfuge of nonaction. There is no evidence of subterfuge in this appeal. KRS 61.878(1)(i) and (j) authorize nondisclosure of the 2013 IRP and related documents upon which the Owensboro Municipal Utilities Commission has not acted. We nevertheless remind the Commission that "the General Assembly did not intend to mandate an iron rule of nondisclosure whenever an exemption applies." 10 We suggest that it consider the approach established by law for IRPs developed by entities governed by the Public Service Commission, and found at 807 KAR 5:001 Section 13(2), in the interest of transparency and public accountability.
Either party may appeal this decision by initiating action in the appropriate circuit court pursuant to KRS 61.880(5) and KRS 61.882. Pursuant to KRS 61.880(3), the Attorney General should be notified of any action in circuit court, but should not be named as a party in that action or in any subsequent proceeding.
Distributed to:
Shannon FiskLisa K. PerfettoLaurie WilliamsSonya L. DixonPatrick D. Pace
Footnotes
Footnotes
1 Kentucky State Board of Medical Licensure v. Courier-Journal and Louisville Times Co., 663 S.W.2d 953, 956 (Ky. App. 1983).
2 Kentucky New Era, Inc. v. City of Hopkinsville 415 S.W.3d 76, 82 (Ky. 2013).
3 Edmondson v. Alig, 926 S.W.2d 856, 858 (Ky. App. 1996).
4 The Commission described Mr. Fisk's request as "forty separate requests, including multiple requests within requests."
5 In his letter of appeal, Mr. Fisk states that OMU made this PowerPoint presentation to the Owensboro Board of Commissioners ("Board"). Throughout the correspondence underlying this appeal reference is made to the PowerPoint presentation to the Utility Commission ("Commission"). Our confusion arises from the confusion in the record on appeal but does not preclude resolution of the issues on appeal.
6 The Commission explained:
Earthjustice argues that, because the capital budget adopted by the Utility Commission includes expenditures which are referenced in the draft 2013 IRP, final action has ipso facto been taken on the draft. However, the draft IRP had nothing to do with the fiscal year budget, including the planned outages. These outages are scheduled well in advance and require much more work and funding than is required during years without planned outages. Additionally, the Utility Commission changed its accounting practices in 2012, capitalizing much of the work that had previously been treated as a maintenance expense.
The outage schedule and capital and maintenance expenditures are developed far in advance of planned outages, and the issuance of bonds is required to fund some of this work. Due to this level of complex planning, the outages referenced by Earthjustice were developed before the draft 2013 IRP was even drafted. Furthermore, budgets were developed before, and therefore independently of, any work on the draft IRP. For these reasons, Earthjustice's reliance on "budgetary evidence" is misplaced.
7 Relying on KRS 61.878(1)(i), which authorizes nondisclosure of "[p]reliminary drafts, notes, correspondence with private individuals, other than correspondence which is intended to give notice of final action of a public agency,." the Commission consistently refers to the IRP as a preliminary draft However, the Commission also cites KRS 61.878(1)(j), authorizing nondisclosure of "[p]reliminary recommendations, and preliminary memoranda in which opinions are expressed or policies formulated or recommended." Because it is accurately described as a "recommendation" to the Commission, we believe that the IRP qualifies for exclusion under both exceptions.
8 KRS 96.530 was amended in the 2014 legislative session, and those amendments will take effect on January 1, 2015. They have no impact on our analysis.
9 Were OMU a utility governed by the Public Service Commission ("PSC"), filing of its IRP would be required under 807 KAR 5:058. As "material on file with the commission," a public agency governed by the Open Records Act, an IRP is "available for examination by the public unless the material is confidential." Thus, when filed with the PSC under legal requirements not applicable here, an IRP is presumptively open unless a party requesting a grant of confidential treatment for portions of the IRP meets its burden of proving that the material falls within one of the statutory exceptions found in the Open Records Act. 807 KAR 5:001, Section 13(2). The PSC has, for example, afforded confidential treatment to infrastructure records under KRS 61.878(1)(m)(1), but refused to afford protection to load forecasts under KRS 61.878(1)(c)1. See, e.g., In the Matter of: 2014 Integrated Resource Plan of Big Rivers Electric Corporation, Case No. 2014-00166 (Order Regarding Request for Confidential Treatment entered August 26, 2014).
10 Lawson v. Office of the Attorney General, 415 S.W.3d 59, 68 (Ky. 2013).
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