SearchRegulatory Affairs & Rates

Regulatory Precedent Search

Regulatory precedent search for utilities: ask how commissions ruled, and get every decision cited to the page, with the direction of travel

Every filing position backed by how regulators actually ruled, cited and trended.

See the demo Book a demo

See one case, screen by screen ↓

demo$14.2Mof crew cost a peer commission disallowed for invoices without time sheets — found before Lumina files its own $61.3M of mutual-assistance cost

estimated$2.4M a yearof allowed earnings in every 10 basis points of return on equity, on Lumina's $2.4B electric equity base

demo31citationsin one storm-cost answer, each read back against the order's page and paragraph — 0 removed

demo38sto a cited answer across 170,420 documents from 31 commissions

The problem

Why “how did the commission rule last time?” takes days to answer

Regulatory Precedent Search answers precedent questions for a utility's regulatory team. Before a rate case or a storm cost recovery filing, counsel and analysts need to know how commissions have ruled on the same issue — their own commission first, then the peers — and what the consumer advocate, staff and industrials argued. That answer sits in thousands of docket PDFs on dozens of commission websites, each with its own search, and it is rebuilt by hand for every case: an analyst reads 30 to 60 orders for one issue, and counsel re-reads the page before quoting it.

What goes wrong is expensive. A peer order gets quoted that a later order modified. The commission's own earlier reasoning is missed, and staff use it on cross. An intervenor argument that won in another jurisdiction is not anticipated. A mechanism regulators are moving away from — a full-return carrying charge on a storm balance — is asked for anyway. On return on equity, every 10 basis points of allowed return matters.

typical$1.3Maverage legal and expert cost of a Massachusetts rate case since 2010 — $4.9M in one case — and regulators may disallow it

typical86decisionselectric ROE authorisations by US commissions in 2025, averaging 9.84% — the peer decisions a cost of capital witness is asked about

Where one issue's precedent research goes, in hoursestimated

By hand28 days

With the solution3.2 days

Finding the dockets on each commission's portal6 → 0.1 d
Reading 30–60 orders for the decision and the reasoning8 → 0.2 d
Building the peer comparison table4 → 0.1 d
Checking later orders and re-reading the page before quoting3 → 0.5 d
Mapping what intervenors and staff argued, and what won3 → 0.3 d
Drafting the position and getting it signed4 → 2 d

Estimated split for one contested issue in a filing (2–4 working days by hand), in hours, by hand and with the solution. The hours that remain are counsel's and the VP's review.

How it works

How a question is answered

Six agents read every docket, build the comparison table and the trend; counsel keeps it and the VP signs.

What comes in

Dockets in31 commissions · orders, testimony, briefs, settlements

Agents at work

Docket readerdecision + page

Then

Precedent agentone row per decision

Position mapper

Then

Trend analyst

Citation checker

Then

Docket watchnightly

A person decides

Regulatory counselkeeps the answer; VP signs the position

What comes out

Comparison table, every row cited

Direction of travel

Signed filing position

One case, step by step

One storm cost filing, from the question to a signed position

On 7–9 February 2026 the ice storm Ilse put 412,000 Lumina Utilities customers out; restoration cost $412.6M, of which $61.3M was mutual-assistance crews. Lumina must file for recovery with the Westmark Public Service Commission in Docket 26-0417-EL by 14 November 2026. Here is the morning of 13 October, screen by screen, in the working solution.

0113 Oct · 32 days to file
One question, scoped to the filing
Elena Marsh · Senior Regulatory Counsel
Elena asks in plain words: “How have regulators treated storm cost recovery?” The scope comes from the Storm Ilse filing — major-storm restoration cost, Westmark plus 6 peer commissions, 2017–2026, balances over $40M, final orders and approved settlements only. The agents' run shows step by step beside the answer: 170,420 documents from 31 commissions searched, 2,318 passages on storm cost, 41 final orders and settlements kept, 8 of them in the peer set.
“I know the answer is in a 2019 order somewhere. Finding the page takes me two days.” — Elena Marsh
0238 seconds later
The direction of travel, with the count behind it
Trend analyst
The answer leads with a verdict: regulators are moving towards securitisation. 0 of the 3 decisions before 2021 securitised the cost; 4 of the 5 since did. The chart plots every decision in three lanes — deferral with carrying charge, reserve and rider, securitisation — with dot size by storm cost, $2.81B across 8 decisions in 7 jurisdictions. A switch shows the carrying charge customers pay instead: 7.4% full return in 2017, 4.1% cost of debt in Westmark's 2019 order, bond rates of 2.1–5.1% since 2021.
“The one exception was a $48M balance, too small to be worth the bond costs.” Trend line: never projected forward.
03The table
Eight decisions, one row each, in the commission's words
Precedent agent
Each row gives the year, commission and utility, the storm and its cost, what was decided, the reasoning and the mechanism, with a link to the order at the page and paragraph. Row 6: Port Merritt securitised Delmont Energy's Hurricane Ivo balance over 12 years at 5.1% and disallowed $14.2M of mutual-assistance cost. Row 2 carries a flag: the Calder storm reserve target was later raised to $85M by Case 23-E-0311.
Citation checker: “31 citations · 0 removed · 1 order modified later”
04One click
Row 3 opens Westmark's own 2019 order at ¶ 74
Elena Marsh · Senior Regulatory Counsel
Elena opens Lumina's own Storm Hale order, Docket 19-0233-EL, at page 31 with the deciding paragraphs highlighted. The commission deferred $171M over six years at the cost of long-term debt, 4.1%, and denied the full return of 7.2%. The margin notes repeat the decision and the reasoning; the order shows as in force, and a copy-citation button gives the cite in full.
¶ 75: “Customers should not pay an equity return on a cost the company did not choose to incur.”
05What it means
Three positions for Docket 26-0417-EL, each from a row
Precedent agent
Lead with securitisation under the 2023 Act — the same commission financed Ridgeway Electric's $208M derecho balance this way in 2024, after a prudence audit (row 7). Do not ask for a full return on the interim balance — ask for the cost of debt until the bonds are issued (row 3). Attach time sheets for all $61.3M of mutual-assistance crews (row 6).
From row 3: “Our own 2019 order refused it and allowed the cost of debt, 4.1%. Ask for the cost of debt until the bonds are issued.”
06Before the intervenors file
Who argued what on storm cost, and how often it won
Position mapper
Arguments from 61 filings in 8 storm dockets, grouped by point. The Westmark Ratepayer Advocate's call for a prudence audit before any financing order was adopted 3 of 5 times; staff's point that capital replacement belongs in rate base, not the storm balance, 4 of 4. A full return on any carried balance, argued by utilities, won 1 of 3. Each can be marked “Expect in 26-0417”.
“8 arguments from 61 filings in 8 storm dockets · adopted means the order adopts it in words”
0713 Oct, 09:14
The position memo, cited sentence by sentence
Tomas Reyes · Regulatory Analyst
The memo states four positions: a financing order under the Westmark Storm Recovery Financing Act; the cost of long-term debt until the bonds are issued; all $61.3M of crew cost filed with time sheets (Exhibit EM-2); and $38.9M of replaced poles and transformers moved to rate base, so the financing order asks for $373.7M. Elena drafted it at 08:58, Tomas checked the exhibits at 09:14, and EM-4 — 8 decisions, 2017–2025, 31 citations — sits beside EM-1 to EM-3.
“Exhibit EM-4 added from the answer. The eight-decision comparison table, 31 citations, each to the order, page and paragraph.”
08Sign-off
Grace signs the position that goes into the filing
Grace Okonkwo · VP Regulatory Affairs
Grace opens the sign-off for Westmark PSC Docket 26-0417-EL as VP Regulatory Affairs: a financing order for $373.7M, the cost of debt on the interim balance, and all $61.3M of mutual-assistance cost filed with time sheets. When she signs, her signature is written to the audit trail.
“Every statement in the memo cites an order, page and paragraph.”
09Overnight
The day a peer commission rules again, the team knows
Docket watch
Docket watch runs over each night’s new filings. In the morning it shows a new Halvorsen ERC order securitising Kessler Light & Power's storm balance over 15 years — “added to the peer set, the trend would read 5 of the last 6” — and a Westmark rulemaking on storm reserve levels with comments due 20 Nov 2026, six days after the Storm Ilse filing.
Each match says why it matched. A document the watcher may not open is never shown.

Who it’s for

Built for the regulatory team that carries a rate case.

The same storm cost filing, seen by the five people who work on it — what precedent research looked like before, and what it looks like now.

Elena MarshSenior Regulatory Counsel, Lumina Utilities · writes policy testimony and briefs before the Westmark PSC

Senior Regulatory Counsel

Before: Knows the commission ruled on it before, but finding the page means days in docket PDFs. “I know the answer is in a 2019 order somewhere. Finding the page takes me two days.”
Now: Asks the question in plain words and opens every decision at the page and paragraph, with Westmark's own orders marked “Our commission”. She keeps the answer and drafts the position.

Tomas ReyesRegulatory Analyst · peer tables for ROE, depreciation and storm cost, data requests and exhibits

Regulatory Analyst

Before: Builds peer tables by hand from commission portals. “Every peer table I build is out of date the week a new order lands.”
Now: Sees precedent by issue — storm cost, ROE, depreciation lives, smart meter cost, allocators, rate case expense — refreshed overnight, and checks the exhibits that go into the filing.

Dr. Hal BrennerExpert witness, outside · cost of capital testimony · public documents only

Expert witness

Before: Writes ROE testimony and must answer cross-examination on what other commissions did. “If I quote a peer order on the stand, it had better say what I say it says.”
Now: Opens the order itself at the cited paragraph, highlighted, with any later order that modifies it flagged. His access covers public documents only.

Grace OkonkwoVP Regulatory Affairs · signs every filing position

VP Regulatory Affairs

Before: Signs positions and the outside-counsel budget. “Show me which way the commission is moving, and our own last order first.”
Now: Gets a position memo where Westmark decisions lead and every sentence cites an order, page and paragraph — then signs it, on the record.

Sam WhitlockPolicy Manager · tracks dockets and rulemakings across peer jurisdictions

Policy Manager

Before: Checks peer commission sites for new orders and rulemakings. “I need to know the day a peer commission changes its mind.”
Now: Gets each morning's new orders, testimony and rulemakings that match his watches, with the reason each matched, and a calendar of pending decisions.

Built on the engine

6 agents. Each with one job, and hard limits.

Six agents read every docket, build the comparison table and the trend; counsel keeps it and the VP signs.

Docket reader

Reads every new order, testimony, brief, intervenor filing and settlement, and records the issue, decision, mechanism, amounts, rates, docket, page and paragraph.

A document without a docket number and page is not indexed
A brief or testimony never decides a row
Privileged counsel memos are labelled counsel-only at reading time

Precedent agent

Turns a question into a scoped search, reads the passages, and builds the comparison table: one row per decision, with the reasoning in the commission's words and the user's own commission first in the memo.

A row without an order passage never reaches the screen
Numbers are quoted, never recalculated
Counsel-only memos are never quoted into a filing
Says so when no order decides the question

Trend analyst

Computes the direction over time from the rows shown — the share of each mechanism before and after, or the path of a number such as the return granted — and states it with its count.

No trend from fewer than 4 decisions — the peer trend is shown faded instead
No forecast beyond the last decision
The count is always shown beside the verdict

Citation checker

Reads every row and memo sentence back against its order passage, and flags any order that a later order modified or reversed.

Never adds a source
Every removal is written to the audit trail

Position mapper

Groups the arguments parties made across testimony and briefs — consumer advocates, staff, industrial customers, utilities — and matches each to whether the order adopted it.

Never marks an argument adopted without the order paragraph

Docket watch

Runs each night over new filings in the watched commissions and tells the owner, in one line, why each one matched and what it changes: a trend count, a deadline, a new position.

Never surfaces a document the watcher may not open

VP Regulatory Affairs

Signs every position that goes into a filing. The agents propose; a named person decides.

Ask in plain words

Ask about any order, docket or position

Ask about any order, docket or position, or say what to add to the filing. Every answer points to the order it came from.

Which way is the Westmark commission moving on storm costs?

Westmark has decided storm recovery twice. In 2019 it deferred Storm Hale over 6 years at the cost of debt, 4.1%, and refused the full return. In 2024 it securitised Ridgeway Electric's derecho under the 2023 Act, after a prudence audit. That is the peer direction too.

Has any order disallowed mutual-assistance crew costs?

Yes, one in the peer set: Port Merritt disallowed $14.2M of Delmont Energy's Hurricane Ivo cost because the crew invoices came without time sheets. Lumina has $61.3M of mutual-assistance cost in Storm Ilse.

Show me peer return on equity decisions since 2024

Eight decisions: granted 9.40% to 9.90%, average 9.70% against 10.43% asked. Both Westmark orders sat below the peer average, 9.55% in 2024 and 9.40% for Lumina's water business in 2026.

Add the comparison table to the Storm Ilse filing as Exhibit EM-4

Done. The eight-decision table is Exhibit EM-4 in the Storm Ilse filing, with 31 citations, each to the order, page and paragraph. It goes to Grace Okonkwo with the position memo for sign-off.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

Regulatory Precedent Search — The answer — **The answer**The question with its scope, the verdict with its count, the direction of travel across eight decisions and the run beside it.

Regulatory Precedent Search — Agents at work — **Agents at work**The run step by step: 170,420 documents searched, deciding documents kept, each order read, the trend found and every citation checked.

Regulatory Precedent Search — The comparison table — **The comparison table**One row per decision — commission, utility, storm and cost, what was decided, the reasoning, the mechanism and the order at the page.

Regulatory Precedent Search — What it means for the docket — **What it means for the docket**Three positions for Docket 26-0417-EL, each tied to the row it comes from, with the follow-up questions to ask next.

Regulatory Precedent Search — The order at the page — **The order at the page**Westmark's 2019 Storm Hale order opened at page 31, the deciding paragraphs highlighted, with margin notes and whether it is in force.

Regulatory Precedent Search — Precedent by issue — **Precedent by issue**Storm cost, return on equity, depreciation lives, smart meter cost, cost allocators and rate case expense, each with its direction.

Regulatory Precedent Search — Who argued what — **Who argued what**Arguments from testimony and briefs grouped by point, who made them, and how often an order adopted them in words.

Regulatory Precedent Search — The position memo — **The position memo**The Storm Ilse position memo with a citation on every sentence, the sign-off, the exhibits and the days to file.

Regulatory Precedent Search — Sign the position — **Sign the position**The VP Regulatory Affairs signs the filing position; the signature is written to the audit trail.

Regulatory Precedent Search — Sources — **Sources**Orders, testimony, briefs, intervenor filings and settlements from 31 commissions, by type, commission and docket.

Regulatory Precedent Search — Watch — **Watch**New orders and dockets that match what the team follows, the reason each matched, and the decisions due this quarter.

Regulatory Precedent Search — Insights — **Insights**Questions answered, median time to an answer, rows carrying a citation, answers kept in filings and where the deciding orders came from.

Regulatory Precedent Search — Your rules — **Your rules**Answer rules, the peer set and who signs.

Governance

Built for the record: cited, checked, signed.

Only orders decideOnly final orders and approved settlements may decide a row. Testimony and briefs appear as positions — who argued what — never as decisions.

Every row cites the page and paragraphEach row and each memo sentence carries the order, page and paragraph, and opens the order there. A sentence without an order passage never reaches the screen.

Read back, and checked for later ordersThe citation checker reads every row back against its passage and searches later orders that cite it. A row whose order was modified or reversed later is flagged on the row.

A trend only with the count behind itThe direction of travel is computed only from the decisions shown, with the count beside the verdict, from at least four decisions, and never projected beyond the last one.

Privileged memos stay with counselOutside-counsel memos are labelled counsel-only when they are read, visible to counsel only and never quoted into a filing draft. An outside expert witness sees public documents only.

Counsel keeps; the VP signsAgents propose; counsel keeps the answer and drafts the position; the VP Regulatory Affairs signs every position that goes into a filing. Every question, answer kept and signature is written to the audit trail.

Configuration

Your answer rules, peers and sign-off

Which documents decide, when a trend is shown, who counts as a peer and who signs are settings, chosen by the regulatory team.

Setting	Default	Choose from
Documents that may decide a row	Orders + settlements	Orders + settlements · Orders only — testimony and briefs are shown as positions, never as decisions
Fewest decisions before a trend is shown	4	3 · 4 · 5 · 6 — below this, the peer trend is shown faded
Flag orders modified or reversed later	On	On · Off — searches every later order that cites the row
Own commission first	On	On · Off — Westmark PSC decisions lead every memo
Peer set	Westmark PSC + 6 peers	Own commission plus the peer commissions you add — Brannock, Calder, Ardenne, Halvorsen, Port Merritt, Tamsin Valley
Who signs filing positions	Grace Okonkwo	VP Regulatory Affairs — positions going into a filing need her signature
Who sees what	By person	Counsel-only memos for Elena Marsh · exhibits for Tomas Reyes · public documents only for an outside expert witness · watches for the policy manager

Connections

Works with the record a rate case is argued on

Commission ordersfinal orders and financing orders — 14,960 in the sample library

Testimony and briefsdirect and rebuttal testimony and briefs — shown as positions, never as decisions

Intervenor filingsconsumer advocate, staff and industrial customer positions

Settlement agreementsstipulations and approved settlements, which may decide a row

Commission e-filing portals31 commissions connected, read nightly; connect another from Sources

Your filings archive and counsel memospast testimony and exhibits; privileged memos kept counsel-only

What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target

100%

of precedent rows and memo sentences cited to the order, page and paragraph

31 of 31 citations
checked on the storm answer

estimated

$2.4M

a year of allowed earnings in every 10 basis points of return on equity

target

< 1min

for one issue's precedent, instead of 2–4 days of docket reading

By hand2–4 days

With agents38 s

“demo” = seen in the working solution, on its sample docket library · “estimated” = our estimate: $2.4M a year = a $2.4B equity base × 0.10%, and the split of one issue's research hours · “typical” = published figures: Boston Globe, 2017 (rate case legal and expert cost, $1.3M Massachusetts average, $4.9M in one case); S&P Global Market Intelligence / RRA (86 US electric ROE authorisations in 2025, average 9.84%). Lumina Utilities, the commissions, utilities, dockets and people named on this page are fictional — characters and sample data in the working solution.

Questions

What regulatory teams ask us.

What is regulatory precedent search software for utilities?

Software that answers precedent questions — how did commissions rule on storm cost, return on equity or depreciation lives — from the orders themselves. Regulatory Precedent Search gives one row per decision with the reasoning and a link to the order at the page and paragraph, and shows which way regulators are moving. Counsel keeps the answer; the VP Regulatory Affairs signs the position that goes into a filing.

How does regulatory precedent search work?

You ask in plain words and set the scope: the issue, your commission and its peers, the years and the document types. The agents search the docket library, keep only final orders and approved settlements, read each order for the decision and the reasoning, compute the trend and read every citation back. In the sample case that took 38 seconds across 170,420 documents.

How is it different from a docket tracker?

A docket tracker finds the docket. This reads the orders and answers the question: what was decided, why, under which mechanism, and where it says so. It also groups what intervenors and staff argued and how often the order adopted it, and watches for new orders that would change the answer.

How does it know a precedent still holds?

The citation checker searches later orders that cite each row and flags any that modified or reversed it. In the sample answer, the 2018 Calder storm reserve decision is flagged: its reserve target was later raised to $85M by Case 23-E-0311.

Can it show which way a commission is moving?

Yes. Above the table, a chart plots every decision over time, with a verdict and the count behind it — for storm cost, 0 of 3 securitised before 2021 and 4 of 5 since. The trend uses only the decisions shown, needs at least four of them, and is never projected forward.

Does it keep privileged counsel memos out of filings?

Yes. Outside-counsel memos are labelled counsel-only when they are read, are visible to counsel only, and are never quoted into a filing draft. An outside expert witness can be limited to public documents.

Do people stay in control of the filing position?

Yes. The agents propose rows, trends and positions, and every sentence carries its citation. Counsel decides what to keep, and only the VP Regulatory Affairs signs a position that goes into a filing; the signature is written to the audit trail.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your commission and peer set, your issue list, a sample of your past orders and filings — and it goes live once every quality gate has passed. We will run it on your own dockets first.

Regulatory Affairs & Rates

More in this division.

All 8 solutions →

Rate Case Data Request Management

Every data request answered on time, with one number for one thing.

1-min demo Regulatory Commitment Tracking

Every directive owned and dated within a day of the order, and closed with its proof.

1-min demo Regulatory Change Management

Each rule change mapped to the processes it touches the morning after it is adopted.

1-min demo

See it on
your dockets.

We'll run Regulatory Precedent Search on your own commission's orders and a question from your next filing.

Book a demo Browse solutions

Regulatory Precedent Search

Why “how did the commission rule last time?” takes days to answer

How a question is answered

One storm cost filing, from the question to a signed position

One question, scoped to the filing

The direction of travel, with the count behind it

Eight decisions, one row each, in the commission's words

Row 3 opens Westmark's own 2019 order at ¶ 74

Three positions for Docket 26-0417-EL, each from a row

Who argued what on storm cost, and how often it won

The position memo, cited sentence by sentence

Grace signs the position that goes into the filing

The day a peer commission rules again, the team knows

Built for the regulatory team that carries a rate case.

6 agents. Each with one job, and hard limits.

Ask about any order, docket or position

The working solution, as it ships.

Built for the record: cited, checked, signed.

Your answer rules, peers and sign-off

Works with the record a rate case is argued on

The difference, in numbers.

What regulatory teams ask us.

More in this division.

See it onyour dockets.

See it on
your dockets.