ML19269C961
| ML19269C961 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/31/1979 |
| From: | Poirier M SPIEGEL & MCDIARMID |
| To: | |
| Shared Package | |
| ML19269C960 | List: |
| References | |
| NUDOCS 7902220131 | |
| Download: ML19269C961 (24) | |
Text
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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION In the Matter of Houston Lighting & Power Company )
The City of San Antonio )
The City of Austin ) Docket Nos. 50-49 Central Power & Light Company ) and 50-49 (South Texas Project, Units )
No. 1 & No. 2) )
INITIAL INTERROGATORIES TO AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS BY THE CITY OF AUSTIN, TEXAS FROM THE PUBLIC UTILITIES BOARD OF THE CITY OF BROWNSVILLE, TEXAS Pursuant to Sections 2.740, 2.740(b) and 2.741 of the Nuclear Regulatory Commission's Rules of Practice under the Atomic Energy Act, the Public Utilities Board of the City of Brownsville, Texas ("Brownsville") hereby files initial interrogatories to and requests the production of documents by the City of Austin, Texas (" Austin").
I. GENERAL INSTRUCTIONS
- 1. Each interrogatory should be answered separately and fully in writing under oath or affirmation by the person (or persons) making it.
- 2. Each document produced in response to this request should be referenced with the number (s) of the relevant request and subsection, if any. Should any of the docriments requested pursuant to this set of interrogatories and requests for document production have already been made available for Brownsville's inspection, it will be suf-ficient to note this fact and to provide the following information: (1) document production number, if any; (2) 730222o(3l
date, author, addressee (if any), persons receiving distribu-tion of such document or copies thereof; (3) a description of the nature of the document; and (4) the particular request and item number in response to which the document has pre-viously been produced.
- 3. Responses to interrogatories and requests for the production of documents shall be served upon the following persons:
Robert C. McDiarmid, Esquire Robert A. Jablon, Esquire Marc R. Poirier, Esquire Spiegel & McDiarmid 2600 Virginia Avenue, N. W.
Washington, D. C. 20037
- 4. Documents should be provided by Austin as they become available, but in any event no later than 30 days after the date of this request.
- 5. These interrogatories and requests for documents are of a continuing nature and require supplemental answers should Austin generate or obtain further pertinent infor-mation or documents between the time its answers are filed and its documents produced and tne time of the evidentiary hearing.
II. DEFINITIONS A. " Documents" mean all writings and records of every type in the actual or constructive possession, control, or custody of Austin, its directors, officers, employees, con-sultants, or agents, including but not limited to contracts, memoranda, correspondence, reports, surveys, tabulations,
charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, diaries, log sheets, ledgers, transcripts, microfilm, computer printouts, vouchers, accounting state-ments, telegrams and telegraphic communications, engineering diagrams (including "one-line diagrams"), mechanical and electrical recordings, records of telephone communications, speeches and all other records, written, electrical, mecha-nical, or otherwise.
" Documents" shall also mean copies of cocuments, even though the originals thereof are not in the possession, custcdy, or control of Austin, and every copy of a document which contains handwritten or other notations, or which in any other manner does not duplicate the original, or any other copy furnished pursuant to this request.
B. " Communications" shall include, without limiting the generality of its meaning, all conversations be cween two or more persons either in person or by telephone, all state-ments, speeches, declarations and comments, and shall includ<e documents as defined in II.A. Coove.
C. " Person" shall mean any natural person, company, association, firm, corporation, cooperative, rural electric cooperative, municipality, joint stock association, or any political sco.livision, agency or instrumentality of the federal, state, or municipal governments, or a lawful asso-ciation of any of the foregoing, or any entity that produces, generates, transmits, distributes, purchases, sells, or fur-nishes electricity.
4
D. " Identify," when used with respect to documents, means that the type, author, recipient (s) of the original, recipient (s) of copies, date, and subject of the document should be specified.
" Identify," when used with respect to communications, means that the type of communication, maker of the com-munication, persons communicated to, persons for whom the communication was intended, date and subject of the com-munication should be specified.
" Identify," when used with reference to any cor-poration, association, cooperative, or other legal entity, means to state the name and current address of said organiza-tion or entity; if the current address is unknown, provide the last known address.
" Identify," when used with respect to any person, means that the person's name, current business address (or current mailing address for persons now retired), current job title, and employer, should be specified. If the current address is unknown, please provide the last known address.
Where more than one request in this series asks for identification of a document, communication, legal entity, or person, in response to the second and subsequent requests, please provide the name of a corporation, legal entity or person, or the date and author or maker of a document or communication, along with a reference to the response in which a full identification was provided.
E. " Representative" shall be understood to include ,
without limiting the generality of its meaning, any director, officer, employee, contractor, or consultant, of any person as defined in II.C., who at a particular formal or informal meeting, or in a particular document or communication, appe.ars to pucticipate in the meeting, or in the making of or the receipt of the dccument or communication, on behalf of or as agent for, said person. Whether or not a representative has actual authority us an agent of the r son is irrelevant to his or her status as a representative.
F. " Relating to" or " relate" means consisting of, referring to, reflecting, or being in any way legally, logically or factually connected with. Requests " relating to" a sub-ject or item should be understood to include possible or con-templated actions as to such subject or item. For example, a request for documents relating to interconnection plans would include documents rclating to interconnection arrangements that have been considered but rejected.
G. " Electric utility" means a private corporation, cooperative, rural electric cooperative, municipality; joint stock association, er any political subdivision, agency or instrumentality of federal, state, or municipal governments, or a lawful association of any of the feregoing that owns, controls, or operates, or proposes or is stadying the possi-bility of owning, controlling, or operating, facilities for 9
the generation, transmission and/or distribution ot electricity.
H. " Transmission services" shall mean the undertaking by a utility to transmit power and/or energy for any other electric utility, whether the power and/or energy is generated by the first utility or by any other electric util-ity. " Transmission services" shall also include the sa.le by a utility of transmission capacity without energy.
" Transmission services" include wheeling.
I. " Interconnection" shall mean the physical junction of the electric traramission systems of two or core electric utilities so that electricity may flow over the junction according to location of points of power generation and power usage, in the same manner as electricity flows over the lines of an individual elt 'tric system. A junction nor-mally maintained in an open position is considered an inter-connection. A junction by wh).ch a lower voltage system is joined to a transmission line through a transformer is con-sidered an interconnection.
" Interconnected operation" between two or more electric utilities shall mean a method of operation in which electri-eity flows over interconnections between the electric transmission and/or subtransmission systems of the electric utilities in the same nanner as electricity flows along the lines of an individual electric system, whether or not such flow of electricity occurs pursuant to the terms of an inter-connection agreement. " Interconnected operation" includes all forms of interchange, including sales, purchases or exchange of energy or capacity, reserves sharing, firm power, emergency, maintenance, seasonal, economy exchange, spinning
reserves and any similar transactions.
" Interconnection agreement" shall mean an agreement governing the rates, metering, and other terms and conditions under which interconnected operation occurs.
J. " City of Austin, Texas" or " Austin" means the City of Austin, Texas, including its electric utility department, and any other agency, creature, division, or part of the governing structure of the City of Austin ha7ing any relation to, contact with, or participation in matters affecting or relating to the sale, purchase, transmission, or exchange of electrical power or energy.
K. " Central Power & Light Company" or "CP&L" shall be understood to include its parent, direct er indirect sub-sidiary, af filiated, or predecessor companies and any en ti-ties providing electric ser'eice at wholesale or retail, the properties or assets of which have been acquired by CP&L.
L. " Houston Lighting & Power Company" or "HL&P" shall be understood to include its parent, direct or indirect sub-sidiary, affiliated, or predecessor companies and any enti-ties providing electric service at wholesale or retail, the properties or assets of which have been acquired by HL&P.
M. " Texas Power & Light Company" or "TP&L" shall be understood to include its parent, direct or indirect sub-sidiary, affiliated, or predecessor companies and any enti-ties providing eletric service at wholesale or retail, the properties or assets of which have len acquired by TP&L.
N. " Dallas Power & Light Company" or "DP&L" shall be understood to include its parent, direct or indirect subsidiary
affiliated, or predecessor companies and any entities pro-viding electric service at wholesale or retail, the proper-ties e. assets of which have been acquired by DP&L.
O. " Texas Electric Service Company" or "TESCO" shall be understood to include its parent, direct or indirect sub-sidiary, affiliated, or predecessor complaies and -v enti-ties providing electric service at wholesale c. retail, the properties or assets of which have been acquired by TESCO.
P. " West Texas Utilities" or "WTU" sb.ll be understood to include its parent, direct or indirect subsidiary, affil-iated, or predecessor companies and any entities providing electric service at wholesale or retail, the properties or assets of which have been acquired by WTU.
Q. " Southwestern Electric Power Company" or "SWEPCO" shall be understood to include its parent, direct or indirect subsidiary, affiliated, or predecessor companies and any entities providing electric service at wholesale or retail, the properties or assets of which have been acquired by SWEPCO.
R. "Public Service Company of Oklahoma" or "PSO" shall be understood to include its parant, direct or indirect sub-sidiary, affiliated, or predecessor companies and any enti-ties providing electric service at wholesale or retail, the properties or assets of which have been acquired by Public Service Company of Oklahoma.
S. " Central & South West Corporation" or "CSW" shall be understood to include its parent, direct or indirect subsidiary, affiliated, or predecessor companies and any entities pro-viding electric service at wholesale or retail, the proper-
ties or assets of which have been acquired by CSW.
T. " Texas Utilities" or "TU" shall mean Texas Utilities Generating Ccmpany, its parent, affiliated, direct or indirect subsiliary and all predecessor companies, including, but not limited to, Texas Utilities Company, Dallas Power &
Light Company, Texas Electric Service Company and Texas Power
& Light Company.
U. " South Texas Units" shall be understood to refer to the nuclear generating units for which applicants in the above-captioned proceeding hold construction permits from the Nuclear Regulatory Commission.
III. DOCUMENTS NO LONGER IN AUSTIN'S POSSESSION, CUSTODY, OR CONTROL If any document otherwise responsive to any request was, on or after December 19, 1970 (date of enactment of P. L.91-560), but is no longer in Austin's possession, or subject to Austin's control, or in existence, state whether (1) it is missing or lost, (2) has been destroyed, (3) has been trans-ferred voluntarily to others, or (4) has been otherwise disposed of. In each instance, explain the circumstances surrounding such disposition and identify the person (s) directing or authorizing its destruction or transfer, and the date(s) of such direction or authot'ization. Identify each such document by listing its author and addressee, type (e.g., letter, memorandum, telegram, chart, photograph, etc.), date, subject matter, whether the document (or copies) are still in existence, and if so, their present location (s)
and custodian (s).
IV. SCOPE OF PRCDUCTION Each paragraph below, unless otherwise specified, refers to all communications of which Austin is aware, made or received from January 1, 1965 to date, and to all documents made, sent, dated or received from January 1, 1965 to date, in Austin's possession, custody, or control.
V. DOCUMENTS WITHHELL AS PRIVILEGED If any documents within any description set out below are withheld by reason of any assertion of privilege, iden-tify each such document by date, description, and type, iden-tify all persons preparing and/or receiving each document, and state the privilege asserted, and the reasons that, in Austin's opinion, justify the assertion of privilege as to each document.
VI. INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
- 1. Please respond to the subparts of interrogatery 1 separately for:
(i) Electric Reliability Council of Texas ("ERCOT")
(ii) Texas Interconnected System (" TIS")
(iii) South Texas Interconnected System ("STIS")
(a) Is Austin a member of (i) - (iii)?
(b) Please describe each formal or informal applica-tion or inquiry by Austin relating to membership by Austin in any of (i) - (iii). Include the date of each inquirygar application, and the date, format, and substance of each response by any person to each inquiry or application.
(c) Describe the application procedure at the time Austin was admitted to membership in each of (i) - (iii) above. Describe the application procedures at any earlier time (s) that Austin inquired about or applied for membership in any of (i) -
(iii) above. Describe any difficulties Austin had at any time in becoming a member of any of (i) -
(iii) above.
(d) Has Austin ever attempted to initiate, influence, or change policies, procedures, or actions of any of (i) -
(iii) above of which it was a member? Describe each such attempt, including the date of Austin's action (s) and the substance of each auch action, and the date, format, and substance of each response by any person to each such attempt. Indicate whether each such attempt was successful.
Please produce all documents relating to each such attempt.
- 2. Please produce all documents relating to any joint actions, actual or contemplated, by three or more operating companies that are members of the Texas Intarc.onnected System, or representatives of three or more operating com-panies that are members of the Texas Ir.terconnected System, including, but not limited to, joint reports or studies, joint planning of generation or transmission expansion, and meetings of any kind. This request excludes agendas and minutes of annual or other regular meetings of TIS or its standing committees.
- 3. Please describe the manner in which agendas and minutes are prepared for TIS meetings and meetings of TIS committees and subcommittees. For TIS and for each TIS com-mittee and subcommittee, please answer the following:
(a) Who is generally responsible for preparation and derarmination of subjects to be considered?
(b) Do prepared agendas and minutes actually reflect the substance of all discussion had during such meetings? If not, describe how actual discussion may deviate from the pre-pared agendas.
The scope of this interrogatory extends to all periods in which meetings of TIS or TIS committees or subcommittees have been held.
- 4. Please respond to this question if Austin is or has ever been a member of ERCOT.
(a) What is the purpose of ERCOT? Describe fully the functions of ERCOT, both formal and informal, with respect to the following areas:
(i) olanning for construction of new generation facili-ties by any member e.'.ectric utilities; (ii) planning for constr;uction of new transmission faci-lities by any member electric utilities; (iii) spinning reserves of any member electric utility; (iv) central dispatch among any or all member electric utilities; (v) fuel acquisition by any or all member eleccric utilities; (vi) interconnected operation by any or all member electric utilities.
(b) Describe fully the way in which Austin is affected by, or takes into account, the activities and/or decisions of ERCOT with respect to each of areas (i) through (vi) listed in (a) above.
(c) Produce all documents relating to (a) or (b) above.
- 5. Please respond to this question if Austin is or ever has been a member of TIS.
(a) What is the purpose of TIS? Describe fully the functions of TIS, both formal and informal, with respect to the following areas:
( i) planning for construction of new generation facili-ties by any member electric utilities; (ii) planning for construction of new transmission facilities by any member electric utilities; (iii) spinning reserves of any member electric utility; (iv) central dispatch among any or all membe.r electric utilities; (v) fuel acquisition by any or all member electric uti-lities; (vi) interconnected operation by any cr all member electric utilities.
(b) Describe fully the way in which Austin is affected by, or takes into account, the activities and/or decisions of TIS with respect to each of areas (i) through (vi) listed in (a) above.
(c) Produce all documents relating to (a) or (b) above.
- 6. Please respond to this question if Austin is or ever has been a member of STIS.
(a) What is the purpose of STIS? Describe fully the functions, both formal and informal, of STIS with respect to
(i) planning for construction of new generation facili-ties by any member electric utilities; (ii) planning for construction of new transmission facilities by any member electric utilities; (iii) spinning reserves of any member electric utilities; (iv) central dispa?.ch among any or all member electric utilities; (v) fuel acquisition by any or all member electric utilities; (vi) interconnected operation by any or all member electric uti.lities.
(b) Describe fully the way in which Austin is af fected by, or takes into account, the activities and/or decisions of STIS with respect to each of areas (i) through (vi) listed in (a) above.
(c) Produce all documents relating to (a) or (b) above.
- 7. Please produce all documents relating to any com-parison of ERCOT and TIS and/or STIS. Please identify any communications of which Austin is aware relating to any such comparison. Please produce all documents relating to each such communication. For a particular communication described in this request if documents produced in response to this request fully identify and describe the substance of the com-munication, no further description is necessary with respect to that particular communication.
- 8. To the extent not produced or previous'y supplied in response to this interrogatory and data request or to pre-vious related interrogatories and data requests, please pro-duce a.1 documents relating to membership by any electric utility in STIS, TIS, or ERCOT.
- 9. Please produce all indexes or other descriptions, either partial or complete, computerized and/or manually created, to discovery documents produced in response to interrogatories and document requests propounded in West Texas Utilities Co. v. Texas Electric Service Co., Case No.
CA3-76-0633F (N. D. Texas, Dallas Div.) or in other related pecceedings as noted in the Licensing Board's Special Prehearing Conference Order in the above-captioned proceeding dated July 13. 1978.
- 10. Please produce all documents relating to purchase and/or sale of bulk power and/or energy by Austin. Exclude billing log data.
11.(a) Describe all offers of participation in the South Texas Units 1 and 2, including all electric utilities to which offers were made, the representative (s) by whom each offer was made, the representative (s) of each utility to which offers were made, the date of each such offer, and the terms of each such offer.
(b) Produce all documents relating to participation, actual oc potential, by any electric utility in the South Texas Units, including the terms and conditions, limitations or restrictions of such participation.
(c) Identify all communications among officers, repre-sentatives or employees of Austin and all communications be-
tween any officer or representative of Austin and any other person, relating to participation in the South Texas Units by any other electric utility. Provide all documents relating to each such communication. If documents provided in rs sponse to (b) above fully identify a particular comraunication, no further response is required as to that particular com-munication.
- 12. Please describe fully each use by Austin of transmission facilities owned jointly by Austin and other persons, and of transmission facilities owned entirely by others. This request includes both actual and potential uses.
(b) Has Austin ever had difficulty in obtaining acc as to transmission services provided by other persons, or to transmission facilities owned in whole er in part by other persons? Please describe fully each such instance of dif-ficulty of access.
(c) Please describe each instance, actual or potential, of construction, by any person other than Austin or a person under the control of Austin, of additional transmission facil-ities, or of increasing the capacity of existing transmission facilities owned in whole or in part by any person other than Austin, for the purpose of providing transmission services to Austin.
(d) Please provide all documents relating to any of (a)-(c) above. Exclude routine back-up engineering docu-ments, accounting documents, unimportant duplicates, and incidental documents that do not relate to policy of any per-son and do not have significance in terms of decisions affecting use of transmission facilities or capacity or construction of transmission facilities.
- 13. To the extent not otherwise provided or supplied in response to this interrogatory and data request, or to pre-vious related interrogatories and data requests, please pro-duce all documents relating to interconnection and/or inter-connected operation of Austin with any other electric utili-ties. Routine documents relating to accounting and opera-tions may be excluded.
- 14. Please produce copies of all interconnection agreements entered into between Austin and any other party.
- 15. Please produce all documents relating to policy for participation, actual, planned or potential, or to establishing terms for any participation, by any electric utility in any generation facility of which Austin is whole or part owner.
- 16. Please produce all documents relating to any attempts, whether actual or contemplated, by any electric utility, to acquire or to lease, either in whole or in part, the electric facilities of Austin or any other municipally or cooperatively owned and/or operated electric utility. The scope of this request is from January 1, 1957 to the present.
(b) Identify any communications of which Austin is aware by any person to any person relating to any acquisition or lease attempt referred to in (a) above. Please produce all documents relating to each such communication. If docu-ments produced fully identify and describe the substance of a particular communication, no further response is required with respect to that particular communication.
- 17. Please produce rates of Austin for all classes of customers at all times since January 1, 1970.
- 18. Has Austin ever received an offer of a special rate or individually designed rate for any form of power and/or energy purchase since January 1, 1957? Please produce all documents relating to each such of fer or rate, or potential offer or rate. Exclude routine billing documents from this request.
- 19. Please produce a copy of the 1994 transmission study referreo to in the August 14, 1972 letter of Emmet C.
Rummel (Austin) to Kermit L. Williams (HL&P) (document num-bers 25130001737) and all documents relating to the study.
- 20. Please state all reasons that Austin has considered for and against operating in interstate commerce. Please produce principal documet ts relating ta each such reason.
21.(a) Please produce all documents relating to any actual or potential purchase by Austin of power and/or energy from the City of Denton, Texas. Identify all communications between officers or representatives of Austin and any other person relating to the purchase of Austin of power and/or energy from the city of Denton, Texas. If documents produced in response to this request fully identify and describe the substance of a particular communication, no additional response is required with respect to that particular com-munication.
(b)(i) Did Austin at any time during 1974 aiscuss, negotiate, or in any way communicate with officers or repre-sentatives of the City of Denton, Texas relating to possible purchase of power and/or energy by Austin from the City of Denton, Texas?
(ii) If the answer to (b)(i) is in the af firmative ,
did Austin and the City of Denton, Texas enter into any contract or agreement relating to the purchase of power and/or energy by Austin from tha City of Denton, Texas?
(iii) If the answr to (b)(ii) is negative, please list every reason for which no agreement or contract between Austin and the City of Denton was reached. Please produce all documents related to each such reason.
22.(a) To the extent not produced or previously supplied in response to tnis interrogatory and data request, or to previous related interrogatories and data requests, please produce all documents relating to actual, potential, possible or contemplated competition between Austin and any other electric utility.
(b) Please identify all communications among officers, representatives or employees of Austin, or between any officer or representative of Austin and any other person, relating to competition as described in (a) above. Please produce all documents relating to each such communication.
If documents produced in response to this interrogatory and data request or to' previous related interrogatories and data requests fully identify and describe the substance of a par-ticular communication, no further information is necessary with respect to that particular communication.
- 23. Please furnish a copy of all Austin's responses to interrogatories and document requests submitted to Austin in the instant proceeding by any other party, including all schedules, exhibits, appendices, attachments, and collections or compilations of documents.
- 24. Please update responses to all interrogatories and data requests received by Austin in this proceeding ot- in any related proceeding (listed at pages 6-7 of the Special Prehearing Conference Order of July 13, 1978 in the above-captioned proceeding), the discovery of which has been ordered to be treated as part of the discovery in this proceeding.
- 25. Please identify the persons who prepared or assisted in the preparation of Austin's response to each of the foregoing requests.
Respectfully submitted, d4 arc ciwl, Marc R. Poirier Attorney for the Public Utilities Board of the City of Brownsville, Texas Law Offices of:
Spiegel & McDiarmid 2600 Virginia Avenue, N.W.
Washington, D.C. 20037 (202) 333-4500
UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
Houston Lighting & Power Company ) Docke t No s . 50-498A The City of San Antonio ) and 50-499A The City of Austin )
Central Power & Light Company )
( So uth Texas Proj ect, Unit Nos. )
1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that I have caused a copy of the foregoing INITIAL INTERROGATORIES TO AND FIRST REQUEST FOR PRODUCTION OF DCCUMENTS BY THE CITY OF AUSTIN, TEXAS FROM THE PUBLIC UTII ITIES BOARD OF THE CITY OF BPOWNSVILLE, TEXAS in the above-captioned proceeding to be served on the following by deposit in the United States mail, first class, postage prepaid, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission internal mail system, this 31st day of January, 1979.
Marshall E. Miller, Chairman Joseph J. Saunders, Esquire Atomic Safety & Licensing Board Chief, Public Counsel &
Panel Legislative Section Nuclear Regulatory Commission Department of Justice Was hing ton , D. C. 20555 P. O. Box 14141 Washington, D. C. 20044 Sheldor. J. Wolfe, Esquire Atomic Safety & Licensing Board Joseph Gallo, Esquire Panel Richard D. Cudahy, Esquire Nuclear Regulatory Commission Robert H. Loe f fle r , Esquire Washington, D. C. 20555 Isham, Lincoln & Beale Suite 701 Michael L. Glaser, Esquire 1050 17th Street, N. W.
1150 17th Street, N. W. Wa s h ing ton , D. C. 20036 Was h ing to n , D. C. 20036 John D. Whitler, Esquire Joseph Rutberg, Esquire Ronald Clark, Esquire Ar titrus t Counsel Department of Justice Counsel for NRC Staff P. O. Box 14141 Nuclear Regulatory Commission Washington, D. C. 20044 Wa s hing to n , D. C. 20555 Joseph Knotts, Esquire Chase R. Stephens, Chief Nicholas S. Re ynold s , Esquire Docketing and Service Sec tion Debevoise & Liberman Office of the Secretary 1200 17th Street, N. N.
Nuclear Regulatory Commission Wa sh ing ton , D. C. 20036 Washington, D. C. 20555
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Douglas F. John, Esquire Joseph I. Worsham, Esquire Akin, Gump, Hauer & Feld Merlyn D. Sampels, Esquire 1100 Madison Office Building Worsham, Forsythe & Sampels 1155 15th Street, N. W. 2001 Bryan Tbwer, Suite 2500 Washing ton , D. C. 20024 Dallas , Texas 75201 R. Gordon Gooch, Esquire Spencer C. Relye a , Esquire John P. Mathis , Esquire Worsham, Forsythe & Sampels Baker & Botts 2001 Bryan Tbwer, Suite 2500 1701 Pennsylvania Avenue , N. W. Dallas , Texas 75201 Washington, D. C. 20006 R. L. Hancock, Director Robert Lowens te in , Esquire City of Austin Electric J. A. Bouknight, Jr., Esquire Utility Department Lo wens te in , Ne wman , Re is & P. O. Box 1088 Axelrad Austin, Texas 78767 1025 Connecticut Avenue, N. W.
Washington, D. C. 20036 Jerry L. Harris, Esquire City Attorney William J. Franklin, Esquire City of Austin Lo wens te in , Ne wm an , Reis & P. O. Box 1088 Axelrad Austin , Texas 78767 1025 Connecticut Avenue, N. W.
Washing to n , D. C. 20036 Richard C. Balough, Esquire Assistant City Attorney Frederick H. Ritts, Esquire City of Austin Law Of fices of Northcutt Ely P. O. Box 1088 Watergate 600 Building Austin , Texas 78767 Was hing ton , D. C. 20037 Dan H. David son Wheatley & Miller City Manager 1112 Watergate Of fice Building City of Austin 2600 Virginia Avenue , N. W. P. O. Box 1088 Washing to n , D. C. 20037 Austin , Texas 78767 Roff Hardy, Chairman and Chief Do n R. Butler, Esquire Executive Officer Sneed, Vine, Wilkerson, Selman Central Power & Light Company & Perry P. O. Box 2121 P. O. Box 1409 Corpus Christi, Texas 73403 Austin, Texas 78767 G. K. Spruce , General Manger Morgan Hunterg Esquire City Public Service Board McGinnis, Lochridge & Kilgore P. O. Box 1771 900 Congisss Avenue San Antonio , Texas 78203 Austin , Texas 78701 Jon C. Wood, Esquire Kevin B. Pratt, Esquire W. Roger Wilson , Esquire Assistant Attorney General Matthews , Nowlin , Macf arlane P. O. Box 12548
& Barrett Capital Station 1500 Alamo National Building Austin, Texas 78711 San An tonio , Texas 78205 Linda L. Aaker, Esquire Perry G. Brittain, Presiden t Assisrant Attorney General Texas Utilities Generating P. O. Box 12548 Ocmpany Capital Station 2001 3r Dallas , van Toweg/5201 Austin, Texas 78711
' Texas
E. W. Barnett, Esquire John E. Mathews, Jr., Esquire Charles G. Thrash, Jr., Esquire Mathews, Csborne, Ehrlich ,
Baker & Bo tts McNatt, Gobelman & Cobb 3000 One Shell Plaza 1500 American Heritage Life Bldg.
Houston, Texas 7 7002 Jacksonville, Florida 32202 J. Gregory Copeland, Esquire Robert E. Bathen Theodore F. Weiss, Jr., Esquire R. W. Beck & Associates Baker & Botts P. O. Box 6817 3000 One Shell Plaza Orlando, Florida 82803 Houston, Te xas 77002 Somervell County Public Library G. W. Oprea, Jr. P. O. Box 417 Executive Vice President Glen Ro se , Texas 76403 Houston Lighting & Power Company P. O. Box 1700 Maynard Human, General Manager Houston , Texas 77001 Western Farmers Electric Coop.
P. O. Box 4 29 W. S. Pobson , General Manager Anadarko, Oklahoma 73005 South Tbxas Electric Cooperative, Inc. James E. Monahan Route 6, Building 102 Executive Vice President and Victoria Regional Airport General manager Victoria, Texas 77901 Brazos Electric Power Coop. , Inc.
P. O. Box 6296 Michael I. Miller, Esquire Waco, Te xas 76706 Richard E. Powell , Esquire Isham, Lincoln & Beale Judith Harris , Esquire One First National Plaza Department of Justice Chicago, Illinois 60603 P. O. Box 14141 Washing ton , D. C. 20044 David M. Stahl, Esquire Thomas G. Ryan, Esquire
- Jerome Saltzman , Chief Isham, Lincoln & Beale Antitrust & Indemnity Group One First National Plaza Nuclear Regulatory Commission Chicago, Illino is 60603 Washington, D. C. 20555 Knoland J. Plucknett Executive Director Committee on Power for the Southwest, Inc.
5541 Skelly Drive Tulsa, Oklahoma 74135 Jay M. Galt, Es quire Looney, Nichols , Johnson &
Hayes 219 Couch Drive Oklahoma City, Oklahoma 73101 A
Marc . Poirier Attorney for the Public Utilities Board of the City of Brownsville, Texas