Springfield Utility Board v. Emerald People's Utility District

At issue in this declaratory judgment action is whether a city possesses authority to exclude a people’s utility district (PUD) from providing electrical services in an area newly annexed to the city when the Public Utility Commission of Oregon (PUC)1 previously had allocated that area to the PUD as part of the PUD’s exclusive service territory. For the reasons that follow, we conclude that a city does not possess such authority.

Springfield Utility Board (the board), acting on behalf of the City of Springfield (the city), adopted an ordinance that purported to exclude Emerald People’s Utility…