City of St. Helena v. Public Utilities Commission

In this writ of review, the City of St. Helena (City or St. Helena) seeks annulment of various decisions of the state Public Utilities Commission (Commission or PUC) conferring public utility status on the Napa Valley Wine Train, Inc. (Wine Train). At issue is whether the City is preempted, by reason of the Wine Train’s public utility status, from exercising its local jurisdiction regarding the placement of a Wine Train station in downtown St. Helena. We find the Wine Train does not qualify as a common carrier providing transportation, and is not subject to regulation as a public utility.

I. BACKGROUND

This case has a long and complicated history that largely defines the issues on review. Initially, in 1988 the City was a party to a complaint filed with the PUC asking the Commission to deem the Wine Train a public utility. The complaint reveals St. Helena and others were concerned with the environmental impact of the Wine Train’s proposed passenger service. The interested parties claimed the Wine Train was subject to the provisions of the California Environmental Quality Act (CEQA) and sought an order asserting the PUC’s jurisdiction over the Wine Train’s proposed…