ML19208C308

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Testimony in Response to Tx Utils Generating Co & Houston Lighting & Power First Set of Interrogatories
ML19208C308
Person / Time
Site: South Texas, Comanche Peak  Luminant icon.png
Issue date: 09/17/1976
From: Springs D
GEORGIA POWER CO.
To:
Shared Package
ML19208C305 List:
References
E-9521, NUDOCS 7909260018
Download: ML19208C308 (6)
v • d • e


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GE'ORGIA PO'JER COMPANY t

6 FPC DOCKET NO. E-9521 PREPARED TESTIMONY OF DAVID A. SPRINGS

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1 Q PLEASE STATE YOUR NAME AND PLACE OF RESIDENCE.

2 3 A David A. Springs, 4514 North Peachtree Road, Chambice, Georgia ,

4 5 Q WOULD YOU STATE YOUR EDUCATIONAL BACF4ROUND?

6 7 A I was graduated frem Georgia Institute of Technology in 1948 with a 8 Bachelor of Electrical Engineering Degree, and again in 1949, with 9 a Degree of Master of Science in Electrical Engineering.

10 11 Q WOULD YOU STATE BRIEFLY YOUR EXPERIENCE?

12 13 A During graduate work at Georgia Tech, I worked 15 months as Assistant 14 Operator of the Georgia Tech AC Network Calculator. At that time, the 15 calculatar was the most advanced tool for studying the overall opera- .

16 tions of power systems. This experience gave me a very early under-17 standing of load flow and stability problems on large utility systems.

18 19 After graduation, I worked for Southern Engineering Company of Georgia in 20 Atlanta, Georgia, for approximately three years, doing distribution design 21 work, transmission system design, and long range power supply planning.

22 23 From 1952 to 1963, I was with the South Carolina Public Service Authority, 24 first as supervisor in charge of wholesale billing and then for a perfod t 25 of six years as their planning engineer. One of my responsibilities with 26 the South Carolina Public Service Authority was to rework and update the 27 " rule curve" of the Pinopolis Hydroelectric Plant Reservoir as steam 28 generation was added to the system.

29 30 Since returning to Southern Engineering Company of Georgia in 1963, I 31 have been in charge of the power supply planning and power system plan-32 ning section. I have been involved as a principal engineer in power 33 system planning or power supply planning for existing or potential sys-34 tems in the following states: Maine, Vermont, Virginia, North Carolina, 35 South Carolina, Georgia, Florida, Alaba=a, Mississippi, Oklahoma, Kansas, 36 Illinois, Kentucky and Ohio. I am a Vice President of Southern Engineer-37 ing Company of Georgia.

38 39 Q HAVE YOU EVER TESTIFIED BEFORE ANY REGUIATORY COMMISSIONS? -

40 41 A Yes, I have testified before this Commission in Carolina Power and Light 42 Company, Docket No. E-7564; Georgia Power Co=pany, Docket No. E-7548; 43 Florida Power Corporation, Docket No. E-7679; Duke Power Company, Docket 44 No. E-7720; and Central Vermont Public Service Company, Docket No. E-7685.

45 I have testified before the Atomic Energy Cor=ission (now the Nuclear 46 Regulatory Commission) in Alaba=a Power Company, Joseph M. Faricy Nuc1 car 47 Plant, Units 1 and 2, Docket Nos. 50-348A and 50-364A. I have also testi-48 ficd before the Public Service Board of the State of Vermont on two 49 occasions.

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J 1Q ARE YOU A REGISTERED PROFESSIONAL ENGINEER 7 2

3 A Yes, I am registered in the States of Georgia and Ransas.

4 5 Q TO WHAT SCHOLASTIC AND PROFESSIONAL SOCIETIES DO YOU BELONG 7 6

7 A I am a member of IEEE and the Georgia Society of Professional Engi-C 8 neers. I am also a member of Tau Beta Pi (Scholastic Engineering) 9 and of Eta Kappa Nu (Scholastic Electrical),

10 11 Q WHAT WERE YOUR ASSIGNMENTS IN THIS PROCEEDING?

12 13 A My assign =ent was in one area only, and that is the method used by 14 Georgia Power Company in assigning capacity responsibility to the 15 wholesale customer under the PR-1 rate schedule. I was asked to 16 review the Company's filing itself and also to review the discussions 17 and negotiations between Company representatives and Oglethorpe Electric 18 Membership Corporation (OEMC) representatives during the development of 19 the rationale upon which the PR-1 was based, and to review similar dis-20 cussions and negotiations since that time which developed modifications 21 applied in the PR-2 filing by the Company and further to review discussions 22 in anticipation of a " Georgia Pool" agreement and determine if the method 23 used by Georgia Power Company in assigning capacity responsibility to 24 whoicsale customers under the PR-1 rate schedule is proper.

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( 26 Q 27 HAVE YOU BEEN INVOLVED THROUGHOUT THESE DISCUSSIONS AND NEGOT.IATIONS?

28 A Yes, though there were some meetings at which this subject was dis-29 cussed that I was unable to attend. I have been involved in the 30 early development of the rationale upon which the PR-1 rate schedule-31 was based, and I have been involved to a considerable extent in the 32 discussions and negotiations which have brought about modifications 33 in the PR-1 methodology which in part has shown up in the PR-1 filing 34 and which will also be apparent in the anticipated " Georgia Pool" 35 agreement.

36 37 Q ARE YOU SAYING TIL\T THE METHODOLOGY EMPLOYED IN THE PR-1 RATE SCHEDULE 38 IS NOT A FIXED METHODOLOGY, REFLECTING AGREEMENT BETWEEN THE PARTIES?

39 40 A That is true, the PR-1 rate schedule is in effect a first effort on the 41 part of Georgia Power Company in filing a partial requirements rate I:2 schedule in accordance with rationale generally agreed to between 43 Georgia Power Company and OEMC. In fact, OEMC representatives did not 44 see the proposed filing until just before it was filed. Since the 45 PR-1 filing, both OEMC and Georgia Power Company have been continually 46 testing the correctness of the methodology employed and discussing im-47 provements. Neither OEMC representatives nor Georgia Power Company 48 representatives will claim that the PR-l. methodology represents final 49 agreement between the parties. It is a very good first effort, but it 50 ic certainly not perfect in all respects, h c r, "o "r 1013 089 aFL  : ;!21-

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( WHAT ARE SOME OF THE MODIFICATIONS THAT HAVE BEEN DISCUSSED SINCE 1 Q 2 THE FILING OF THE PR-1 RATE SCIIEDULE?

3 4 A Two major modifications have been discussed. First, the determination 5 of monthly energy entitlement and energy cost responsibility is ex-6 pected to go from an average cost basis by category to an hourly account-7 ing. The average cost basis is used in both PR-1 and PR-2. An hourly 8 accounting is expected to be applied in the PR-3, " Georgia Fool", filing.

9 The second major modification is in the assignment of capacity responsi-10 bility to wholesale customers under the partial requirements rate schedule.

11 This modification is reficcted in the Company's PR-2 filing and is the 12 subject of my assignment in this proceeding. There are other adjustments 13 which have taken place and will take place in the future which reficct 14 refinements in the basic methodology most of which, however, will have 15 very minor impact.

16 17 Q WHAT IS THE DIFFERENCE BETWEEN Tile CAPACITY RESPONSIBILITY OF THE WHOLE-18 SALE PARTIAL REQUIREMENTS PURCHASER UNDER THE PR-1 SCHEDULE AND THE 19 MODIFIED METHODOLOGY EMPLOYED IN THE PR-2 FILING BY THE COMPANY?

20 21 A The PR-1 rate schedule as filed by Georgia Power Company assigns a capa-22 city responsibility to each wholesale customer under the PR-1 rate schedule 23 based upon the wholesale customer's separate maximum annual coincidental 24 peak demand including a percent reserve assignment determined on the basis 25 of the combined territorial generating resources compared to the combined

( territorial coincidental peak load. In the PR-2 filing, on the other hand, 26 27 the Company has based both the capa' city responsibility of the wholesale 28 customer and such wholesale customer's reserve responsibility on such 29 customer's demand contribution to the territorial peak demand (that is the 30 wholesale customer's demand at the same hour of the territorial peak de-31 mand for the year) .

32 33 Q IN YOUR OPINION WHICH IS THE CORRECT METHODOLOGY?

34 35 A The method applied by Georgia Pouer Company in the PR-2 filing.

36 37 Q WOULD YOU EXPLAIN YOUR REASONS WHY?

38 39 A During the early discussions between representatives of Georgia Power 40 Company and representatives of OEMC, out of which the rationale and meth-41 odology of the partial requirements rate filings have evolved, OEMC has 42 expressed a willingness, in fact a desire, to carry its full burden in 43 the resource pooling arrangements being developed with Georgia Power Com-44 pany. This has been expressed by me personally as a desire to move away 45 from a company-customer relationship and to a system-to-system relation-46 ship as soon as practicable. In this same sense I have a number of times 47 expressed the opinion that OEMC's capacity responsibility in the State of 48 Georgia in relation to the Georgia Power Company should be equivalent to 49 the Georgia Power Company's capacity responsibility in relation to the 50 other members of the Southern Company pool. This is still my opinion as

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( to the proper relationship between OEMC and Georgia Power Company at 1

2 such time when OEMC and Georgia Power Company have developed a full 3 " Pooling" relationship, contractually recognizing both the benefits 4

and the burdens of full " pool" membership and further recognizing the 5

absolute necessity that OEMC be allowed to continue to purchase its 6 " deficit" capacity in each category out of the average imbeded capa-7 city of the Georgia Power Company in each category (which OEMC member 8 cooperatives have helped to pay for over the past 30 years as full 9 requirements wholesale customers) until OEMC first becomes generally lo scif-sufficient in generating resources. After self-sufficiency is 11 reached OEMC should stand. toe-to-toe with all other Pool members as 12 to generating resource responsibility.

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14 Under PR-1 (and PR-2), as filed by Georgia Power Company, OEMC is a 15.

whoicsale customer of Georgia Power Company. The " Pooling" relation-16 ship is not established as yet. As a customer of Georgia Power Company, 17 OEMC and any other PR-1 customer should be assigned a cost responsi-18 bility out of the Company's system costs on the same basis as that 19 assigned to any and all other classes of Georgia Power's customers.

20 That cost responsibility would be based upon the customer class' contri-21 bution to the Company's peak load. This is because the comoanv's 22 peak load (including all classes of customers' contributions thereto) 23 is the critical point of facility availability and ultimately deter-24 mines what facilitics must be provided and what capital costs must be 25 incurred by the Company. To assign capacity responsibility to whole-(

26 sale customers under the partial rcquirements rate schedule as proposed 27 in the Company's PR-1 filing is to put such customers under a cost 28 disadvantage compared to other customers of Georgia Power Company 29 because the costs allocations to such other customers are based upon 30 those customers contribution to the Georgia Power Company peak load.

31 This is true whether such customer classes are retail or full require-32 ments wholesale. As long as cost allecations to customers of Georgia 33 Pcwer Company are based upon their contribution to the Company's peak, 34 which they are (See FPC Docket Nos. E-9091 and ER 76-536 ), the PR-1 35 method of allocating to partial recairemeres customers based upon the 36 customer's peak non-coincidental wi th the Company's peak yields to an 37 absolute certainty an overcharge as to that partial requirements customer 38 unicss that peak happens to occur it; the same hour as the Company's peak.

39 This is because the partial requirements customer's peak will always 40 be larger than its contribution to the Company's peak unless they 41 happen to occur in the same hour. I, therefore, must agree that the 42 capacity responsibility methodology employed by Georgia Power Company 43 in its PR-2 filing is correct and the methodology employed in the 44 PR-1 filing is incorrect.

45 46- Q HAVE YOU PREPARED AN EXHIBIT WHICH REFLECTS THIS CHANGE?

47 43 A Yes, I have. Pages 1 through 5 of Exhibit (DAS-1) reflect a revised 49 sample billing for capacity to OEMC for the month of August, 1975 incor-50 p rating a capacity responsibility for OEMC based upon the OEMC

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d k- 1 contribution to the territorial peak demand similar to that proposed 2 under the PR-2 as filed by Georgia Power Company. Comparing the 3 monthly capacity charge indicated on line 16 of Page 5 of 7, Exhibit (

4 (DAS-1), to the conthly capacity charge as billed to OEMC during 5 the 1975-76 contract year (line 16, Page 7 of 7, Exhibit _(DAS -1))

6 indicates a decrease in capacity charges under the PR-2 type calcula-7 tion of $203,502 for the conth of August, 1975. This difference would 8 apply to each conth of the 1975-76 contract year. Exhibit 9 (DAS-1), Page 2 of 7 is a recomputation of Page 2 of the PR-1 billing (

10 to OEMC subtitled " Annual Maximum Decand and Reserves - Integrated 11 Peak" reflecting an adjustment to include the .OEMC Hatch Nuclear Plant 12 ownership in the load being reserved. This is a minor adjustment al-13 ready made by Georgia Power Company which is to be compared to Page 12 14 of 22 of Exhibit (HGB-5). t 15 16 17 18 19 2C 21 22 23 24 25

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UNITED STATES FEDERAL POWER CO.t!ISSION DOCKET NO. E-9521 GEORGIA POWER COMPANY STATE OF GEORGLi )

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COUhTY OF FULTON )

d I certify that the attached testimony and exhibits in this docket were prepared by me or under my supervision and that the answers contained in such testimony and exhibits are true and correct to the best of my knowledge and belief.

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( DavidA, Spring / f Subscribed and sworn to before me this 17th day of September, 1976 s

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@otary Public tiotary Pub 0c. Georgia, State at targe My Commission Expires Mar.19,1980 EII .I {

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