When a filed rate is challenged in a proceeding made available by statute to challenge the rate, it is possible to allege and even to prevail on a complaint that the filed rate is excessive and should not be charged. There is just no filed rate doctrine in such administrative proceedings, it appears.
Even when the persons challenging the rate as excessive file their own complaint "incorrectly" but they allege enough claims to merit the attention of the agency. See Malott v. Summerland Sanitary Dist., 55 Cal. App. 5th 1102, ___ Cal. Rptr. 3d ___ (Cal. 2d DCA, Div. 6, October 19, 2020).
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