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Vt. Stat. Ann. tit. 30, § 226 (2026)

✓ current as of May 2026
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Subchapter 001 : GENERAL POWERS

(Cite as: 30 V.S.A. § 226)
Notes of Decisions
Cited in 20 cases, 1973–1996 · leading case: In Re Consol. Rate Appeals of Green Mountain Power Corp., 455 A.2d 823 (Vt. 1983).
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In Re Consol. Rate Appeals of Green Mountain Power Corp., 455 A.2d 823 (Vt. 1983). · cites it 5× “Furthermore, the internal logic of 30 V.S.A. § 226, especially taken in connection with the overall regulatory purposes put in place by the legislature, is inconsistent with a narrow construction of the temporary rate increase authority given to the Board.”
Petition of Cent. Vt. Pub. Serv. Corp., 449 A.2d 904 (Vt. 1982). · cites it 4× “The Board suspended this increase under 30 V.S.A. § 226(a). The Board scheduled a hearing on *287 the petition on August 14, 1980.”
In Re New England Tel. & Tel. Co., 382 A.2d 826 (Vt. 1977). · cites it 4× “The Board suspended those rates pursuant to 30 V.S.A. § 226(a); however, the utility began collecting the rates under bond on September 11, 1974, pursuant to a statutory procedure that permits the action pending determination of a rate increase petition.”
In Re New England Tel. & Tel. Co., 305 A.2d 598 (Vt. 1973). · cites it 6× “Such proceedings by the board may also come about by petition from persons adversely affected by the change, all as provided by 30 V.S.A. § 226(a). Once such proceedings have been determined upon, the board has three options available: (1) the new rates may be allowed to take…”
Petition of Green Mountain Power Corp., 385 A.2d 1110 (Vt. 1978). · cites it 5× “It is the second argument of the Attorney General that this rather pragmatic decision to allow the utility to retain the additional money collected under temporary rate increases to cover established revenue deficiencies is actually recoup *175 ment.”
In Re Petition of Burlington Elec. Light Dept., 373 A.2d 514 (Vt. 1977). · cites it 2× “Thus, when the Board gave temporary rate relief on November 25, 1974, in an amount equal to that stipulated to in the order of November 30,1973, it was prohibited *118 from granting any recoupment in its final order on the matter.”
In Re Cent. Vermont Pub. Serv. Corp., 473 A.2d 1155 (Vt. 1984). “30 V.S.A. § 226(b) previously allowed recoupment at the end of a rate case so that a utility could re *56 cover revenues it would have received if the rates finally approved had gone into effect on the date originally requested; however, this statute was repealed on May 6, 1982,…”
Petition of Green Mountain Power Corp., 305 A.2d 571 (Vt. 1973). “On December 21, 1971, the proposed rate schedule was put into effect by Green Mountain, as permitted by 30 V.S.A. § 226, and pursuant to a bond approved by the Board subject to refund within thirty days of the Board’s final determination of this case.”
Petition of Quechee Serv. Co., Inc., 690 A.2d 354 (Vt. 1996). · cites it 2× “§ 226(a), the Board may be somewhat generous to a utility when it sets temporary rates without a full understanding of the circumstances.”
Pub. Serv. Comm'n v. Diamond State Tel. Co., 468 A.2d 1285 (Del. 1983). “Under Vermont cases, authority to recoup is based on express statutory authority (30 V.S.A. § 226(b)) and fairness or “inherent equities” in requiring there be a remedy for a successful appeal from an erroneous commission rate order.”
Petition of Allied Power & Light Co., 321 A.2d 7 (Vt. 1974). “Although the Board may forego, in its own behalf, beginning an investigation, it cannot cut off the statutory right of affected persons to apply to the Board by petition for an investigation.”
In Re Vill. of Stowe Elec. Dep't, 367 A.2d 1056 (Vt. 1976). “30 V.S.A. § 226 (b) provides as follows: If the board orders that the changed rate shall not go into effect until final determination of the proceedings, and if, upon final disposition of the issues involved in such proceeding, the rates as finally determined are in-excess of…”
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— Vt. Stat. Ann. tit. 30, § 226(a) — 7 cases
In Re Consol. Rate Appeals of Green Mountain Power Corp., 455 A.2d 823 (Vt. 1983). “Furthermore, the internal logic of 30 V.S.A. § 226, especially taken in connection with the overall regulatory purposes put in place by the legislature, is inconsistent with a narrow construction of the temporary rate increase authority given to the Board.”
In Re New England Tel. & Tel. Co., 305 A.2d 598 (Vt. 1973). “Such proceedings by the board may also come about by petition from persons adversely affected by the change, all as provided by 30 V.S.A. § 226(a). Once such proceedings have been determined upon, the board has three options available: (1) the new rates may be allowed to take…”
Petition of Cent. Vt. Pub. Serv. Corp., 449 A.2d 904 (Vt. 1982). “The Board suspended this increase under 30 V.S.A. § 226(a). The Board scheduled a hearing on *287 the petition on August 14, 1980.”
Petition of Quechee Serv. Co., Inc., 690 A.2d 354 (Vt. 1996). “§ 226(a), the Board may be somewhat generous to a utility when it sets temporary rates without a full understanding of the circumstances.”
In Re New England Tel. & Tel. Co., 382 A.2d 826 (Vt. 1977). “The Board suspended those rates pursuant to 30 V.S.A. § 226(a); however, the utility began collecting the rates under bond on September 11, 1974, pursuant to a statutory procedure that permits the action pending determination of a rate increase petition.”
— Vt. Stat. Ann. tit. 30, § 226(b) — 11 cases
In Re New England Tel. & Tel. Co., 382 A.2d 826 (Vt. 1977). “The Board suspended those rates pursuant to 30 V.S.A. § 226(a); however, the utility began collecting the rates under bond on September 11, 1974, pursuant to a statutory procedure that permits the action pending determination of a rate increase petition.”
Petition of Cent. Vt. Pub. Serv. Corp., 449 A.2d 904 (Vt. 1982). “The Board suspended this increase under 30 V.S.A. § 226(a). The Board scheduled a hearing on *287 the petition on August 14, 1980.”
In Re Cent. Vermont Pub. Serv. Corp., 473 A.2d 1155 (Vt. 1984). “30 V.S.A. § 226(b) previously allowed recoupment at the end of a rate case so that a utility could re *56 cover revenues it would have received if the rates finally approved had gone into effect on the date originally requested; however, this statute was repealed on May 6, 1982,…”
In Re Consol. Rate Appeals of Green Mountain Power Corp., 455 A.2d 823 (Vt. 1983). “Furthermore, the internal logic of 30 V.S.A. § 226, especially taken in connection with the overall regulatory purposes put in place by the legislature, is inconsistent with a narrow construction of the temporary rate increase authority given to the Board.”
Pub. Serv. Comm'n v. Diamond State Tel. Co., 468 A.2d 1285 (Del. 1983). “Under Vermont cases, authority to recoup is based on express statutory authority (30 V.S.A. § 226(b)) and fairness or “inherent equities” in requiring there be a remedy for a successful appeal from an erroneous commission rate order.”
— Vt. Stat. Ann. tit. 30, § 226(c) — 1 case
Petition of Green Mountain Power Corp., 519 A.2d 595 (Vt. 1986).
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