ML19289C154
| ML19289C154 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/22/1978 |
| From: | Harris J JUSTICE, DEPT. OF |
| To: | |
| References | |
| NUDOCS 7812140280 | |
| Download: ML19289C154 (24) | |
Text
'NRC PUBLIC DOCUMENT R002 mfm Yfp#,
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UNITED STATES OF AMERICA
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i A-ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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Docket Nos. 50-498A HOUSTON LIGHTING AND POWER
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50-499A CO, et al.
)
)
(South Texas Project, Units
)
1 and 2)
)
)
FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS FROM DEPARTMENT OF JUSTICE TO HOUSTON LIGHTING
& POWER AND TEXAS UTILITIES COMPANIES Preface The Department of Justice
(" Department") hereby requests, pursuant to Sections 2.740b and 2.741 of the Commission's Rules of Practice, that Applicant Houston Lighting and Power Company ("HL&P") and party Texas Utilities Generating Company ("TU"), including its subsid-iaries (Dallas Power & Light, Texas Power and Light, and TESCO), answer in writing the following interrogatories and produce the pertinent documents.
Each interrogatory should be answered separately and fully in writing under oath or affirmation by the person (or persons) making it.
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A. Definitions 1.
" Company" means the applicant, Houston Lighting and Power Co., and Texas Utilities Generating Company, and their parents, subsidiaries and affiliates and all prede-cessor companies, including, but not limited to, Houston Industries, Texas Utilities Company, Dallas Power & Light Company, Texas Electric Service Company, and Texas Power &
Light Company.
2.
" Documents" means all writings and records of every type in the possession, control or custody of the company, its directors, officers, attorneys, employees or agents, including, but not limited to, memoranda, correspond-ence, reports, Jurveys, evaluations, charts, books, minutes, notes, agendas, diaries, transcripts, microfilm, accounting statements, telephone and telegraphic communica-tion, speeches, and all other records, written, electrical, mechanical or otherwise, but excluding documents relating to the design, construction or routine operation of electrical facilities.
Where engineering feasibility studies or reports are furnished, the underlying detailed data need not be supplied.
" Documents" shall also mean copies of documents, even though the originals thereof are not in the possession, custody or control of the company, and every copy of a document which contains handwritten or other notations or which otherwise does nct duplicate the original or any other copy.
3.
" 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 herein with respect to any person means that the person's name, current (or past if retired) business address, job title and employer should be specified.
" Identify" when used herein with reference to any corporation, association, cooperative, or other legal entity, means to state the name and current address of said organization or entity and if the current address is unknown, provide the last known address.
4.
" Electric Utility" shall mean a private or public corporation, cooperative, rural electric cooperative, municipality, joint stock association, or any political subdivision, agency or instruraentality of the federal, state, or municipal government, or a lawful association of any of the foregoing which owns, controls, or operates, or proposes to own, control, or operate facilities for the generation, transmission or distribution of electricity.
5.
" Coordination" shall refer to firm power sales, (including partial requirements sales to supplement other power supply resources), reserve sharing, spinning reserve sharing,economicdispatchoreconomyinterchan'he, stagger-ed additions of generating or transmission facilities, emergency and maintenance powr:r interchange, joint mainte-nance scheduling, transmission service, connections or
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interconnections, short term power interchange, diversity interchange, pooling, or sales, purchases or exchange of any form of wholesale power among utilities. " Coordination" and " coordinating" shall also include joint ventures in the sharing of,-or participation in, the ownership, operation, or output of generating f acilities and the sharing of ownership, construction, or use of transmission facilities.
6.
"FERC" shall mean the Federal Energy Regulatory Commission or any predecessor agency and the Department of Energy (DOE).
7.
"FPC" shall mean the Federal Power Commission and any successor agency including FERC and DOE.
8.
" Relating to" means relating to in any way and includes documents which are the subject of the request.
(e.g. " relating to a contract" includes the contract -
itself).
Requests concerning a subject or item should be understood to include possible or contemplated actions as to such subject or item.
For example, requests for documents relating to interconnection plans would include documents relating to interconnection arrangements that have been considered but rejected.
9.
"ERCOT" means the Electric Reliability Council of Texas.
- 10. " TIS" means the Texas Interconnected System and its predecessor organizations, the South Texas Interconnected System and the North Texas Interconnected System.
B. Documents No Longer in Company's Possession, Custody or Control If any document described in this section was, on or after December 19, 1970 (date of enactment of P.L.91-560), but is no longer in Company's posession, or subject to Company's control, or in existence, state whether it (a) is missing or lost, (b) has been destroyed, (c) has been transferred to others, or (d) has been otherwise disposed of.
In each instance, explain the circumstances surrounding such disposition and identify the person (s) directing or authorizing same, and the date(s) of such direction or authorization.
Identify each such document by listing its author and addressee, type (e.g.,
letter, memorandum, telegram, chart, photograph, etc.), date, subject matter, whether the documents (or copies) are still in existence and, if so, their present location (s) and custodian (s).
C. Period Covered and Privilege Unless otherwise indicated, the documents which the Department requests be furnished shall include all docu-ments from the files and records of Applicant or TU dated January 1, 1965, to the present.
It is requested that any documents withheld by the Applicant by reason of any assertion of privileg.,
be identified individually by listing the person (s) preparing, sending, or receiving the same, the subject and date thereof, and a brief statement on the basis for asserting privilege as to each document.
All documents for which privilege is claimed shall be submitted to the Licensing Board under seal no later than the last day for this document production.
D.
Documents Available at the Federal Power Commission (FPC) or Fede?al Energy Regulatory Commission (FERC)
In the event that any of the documents or material requested are available on FPC forms 1 or 12 or in any other public filing made with the Federal Power Commission.
or its successor agency, FERC, such documents and materials need not be supplied.
However, each such document should be individually and specifically identified including the.
FPC or FERC file number and the specific location of the requested information on any standardized FPC or FERC form.
E. General Instructions 1.
In any situation where a document is supplied in response to a request, such document should be referenced and identified as to the interrogatory (including subpart) to which it responds.
Should any of the documents requested pursuant to this set of interrogatories and requests for document production have already been made available for the Department's inspection, it will be sufficient that this be so noted along with the following information: (1) production number, if any; (2) date, author, addressee (if any),
persons receiving distribution of such document or copies thereof; and (3) a description of the nature of the document.
All pertinent documents and/or identifying information shall be submitted along with the response to this set of interroga-tories.
- 2. Pursuant to the directive of the Board, issued at the prehearing conference on June 21, 1978, these interrog-atories and requests for documents are of a continuing nature and require supplemental answers should the recipi-ent applicant HL&P or party TU obtain further pertinent information or documents between the time its answers are filed and its documents produced and the time of the evidentiary hearing.
F.
Interrogatories & Document Production
- 1. Providing the identity of the requestor, the date
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of the request (s), the individual contacted and the nature of response (s), describe each occasion upon which an Electrical Utility engaged in interstate commerce, or interconnected with a Electrical Utility engaged in inter-state commerce, contacted HL&P and/or TU, regarding: (a) a request to purchase, sell, or exchange electrical power or energy, including but not limited to wholesair transactions; (b) requests for the use of transmission services; (c) requests for membership in the Texas Interconnected System (TIS); (d) requests for membership in the Electric Reliabil-ity Council of Texas (ERCOT); and (e) provide all documents which relate to (a)-(d) above.
- 2. Identify each contract, agreement, or understand-ing among any Companies or between or among any Company and any third Electric Utility, since 1935 relating to:
(a) the installation, maintenance and inspection of mechanical devices designed to prevent either the flow of power from interstate commerce into the lines of each Company, or the flow of power from each Company into interstate commerce; (b) procedures whereby should any Company desire to engage in interstate commerce, it would notify the other within a specified time; (c) any contract, understanding, agreement or plan whereby either or both s.
Companies would disconnect from any third Electric Utility with which they were interconnected should that third Electric Utility commence to transmit or receive electrical power or energy in interstate commerce; and (d) provide all documents which relate to (a)-(c) above.
3.
(a) Describe in detail the reasons, factors or policies which were considered by HL&P and/or YESCO in determining to disconnect on May 4, 1976, from other Electric Utilities with which they had been interconnected.
(b) Provide all documents which relate to the response to this interrogatory.
4.
In order of their relative importance, describe the underlying policies or bases upon which HL&P and TU justify their refusal to engage in the interstate transmis-sion or reception of electrical power or energy or to be interconnected with any other Electric Utility engaged in interstate commerce; provide any documents which state or describe these policies or bases.
- 5. With respect to the South Texas Project, identify and describe: (a) all requirements which had to be satisfied before any Electrical Utility would be allowed to partici-pate in the project; (b) all provisions of the South Texas participation agreement, if any, which limit participation to Elect'rical Utilities engaged only in intrastate commerce; (c) whether there is any method whereby it is technically
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feasible to operate the South Texas Project in a situation where one of the participants is engaged in both intrastate and interstate commerce, while all the other participants are engaged exclusively in intrastate commerce; (d) if there is a technically feasible method to allow this manner of cperation, state how much it would cost to implement this method, specifying all assumptions, methods of calculation, and techniques employed in making that estimate; and (e) provide all documents which relate to (a)-(d) above.
- 6. State in current dollar amounts what cost, if any, would be borne by HL&P and TU if ERCOT were interconnected with the Southwest Power Pool.
Had these costs, if any, been calculated prior to the opening of any intercon-nections ca or about May 4, 1976?
State all assumptions underlying these calculations, who made such assumptions, the basis for such assumptions, when the calculations were made, and whether these calculations were undertaken for any purpose other than to use in this or related litigation.
Provide all studies, drafts, working papers, etc. relating to the calculations of any such cos 5.
7.
(a) Identify every occasion upon which TESCO either threatened to open or in fact did open any or all of its interconnections with West Texas Utilities Co. '
(b) With respect to each such occasion identified in response to (a), describe and/or identify all individuals involved in either threatening to open or in actually opening interconnections, the surrounding circumstances, the substance of any such threats, the recipient (s) of any threats, and the response (s) of all involved individuals or entities to any threatened or actual disconnections.
(c) In addition, identify and describe each reason, jus-tification, or policy which led TESCO either to threaten disconnection or actually to disconnect from WTU.
(d)
Provide all documents which relate to the response to this interrogatory.
8.
(a) State every occasion since 1965, if any, on which HL&P or TU communicated with or considered communi-cating with any other Electrical Utility to dissuade that utility from commencing to operate, or to discontinue its then current operation, in interstate commerce. (b) With respect to each such occasion identified in response to (a), describe and/or identify all individuals involved in any such communications or contemplated communications, the surrounding circumstances, the substance of any such communications, the individuals (and the entities for which they worked) to whom such communications were made, and the response (s) of those individuals or entities.
(c) Provide all documents which relate to the response to this interrogatory.
9.
(a) Identify each and every occasion, if any, upon which HL&P and/or TU communicated with West Texas Utilities Company or Central Power & Light Company the subject of possible interstate operation by WTU or CP&L, giving the date(s) of any such communication (s), the surrounding circumstances, the individual (s) so communicating, the recipients of any such communication (s) and the response (s),
if any, of those recipients.
(b) Provide all documents which relate to the response to this interrogatory.
- 10. (a) State whether HL&P and/or TU through any of its management or executive employees has ever promulgated, published, circulated, or in any way communicated through-out the Company or to its shareholders, or to any external person or entity, that it maintained a policy or practice of operating exclusively in intrastate commerce.
(b)
State whether HL&P and/or TU through any of its management or executive employees has ever promulgated, published, circulated, or in any way communicated throughout the Company or to its shareholders, or to any external person or entity, that it intended in the future to operate exclusively in intrastate commerce. (c) If the answer to either (a) or (b) is in the affirmative, give the date(s) of any such communication (s), the surrounding circumstances, individual (s) so communicating, the recipi-ents of any such communication (s) and the specific responses, if any, of those recipients. (d) Provide all documents which relate to (a)-(c) above.
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- 11. Identify each and every period or occasion during or on which HL&P has been interconnected with Gulf States Utilities, or any other Electrical Utility engaged in interstate commerce, and the occasions upon which HL&P either transmitted electrical power or energy to that company or received clectrical power or energy rom that company.
Specify the total number of kilowatt hours (KWH) either transmitted or received during these periods and the specific circumstances, if any, surrounding the i
interconnections.
- 12. With respect to the FERC's Fort Worth regional office study, " STAFF REPORT ON ELECTRIC RELIABILITY COUNCIL OF TEXAS INTERCONNECTION AMD RELIABILITY EVALUATION," March, 1978, do Houston and TU contend that:
(a) the report is incorrect in assessing the amount of cost necessary to interconnect ERCOT and SWPP as being $31,175,000 (p. 32);
(b) The report is incorrect in asserting: "' Internal' load flows for single contingency loss of the largest generating unit in South Texas (South Texas Project 1,250 MW unit) and single contin-gency loss of the largest generating unit in North Texas (Comanche Peak 1,130 MW unit) were made for ERCOT interconnected with SWPP and the rest of the eastern interconnected systems group for 1982.
No over loads or adverse effects were observed" (p. 28);
t (c) if the answer to (a) or (b) is affirmative, and HL&P or TU does reject that finding of the study, explain the basis for that rejection; (d) provide all documents which relate to (a)-(c)
I above.
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- 13. (a) Do HL&P and TU assert that the costs of regulation under FERC regulatory authority would be greater or less than the costs of regulation under the Texas Public Utility Commission; (b) If HL&P and TU assert that greater costs will result from FERC regulation, state the basis upon which that contention rests; and (c) provide all documents which relate to (a)-(b) above.
- 14. State whether, prior to the May 4, 1976 discon-nection, HL&P and/or TU made, commissioned or reviewed any analysic, study or evaluation as to possible adverse effects upon wholesale, industrial and residential consumers of electrical power throughout Texas which would result from HL&P and TU disconnecting from all other Electrical Utilities with which they were intercon-nected.
If so, state the conclusion of cny such analysis, study or evaluation, and by whom, when and under what circumstances it was made.
Provide all documents relating to such analysis, study or evaluation.
- 15. Do HL&P and TU contend that if they become subject to FERC jurisdictional authority, the Commission could ordet them to implement interconnections, provide transmission services, or take other action, the result of which would be detrimental to their customers?
If so, state the basis of that contention and provide all docu-ments relating to that contention.
- 16. (a) State for every wholesale customer of HL&P and TU: the full name or title of the customer; complete i
address of the customer; and the amount of wholesale power purchased by that customer by year for the period 1950-19 '/ 8.
(b) State all requests received by HL&P and/or TU for wholesale service whether or not such service was ever provided, specifying when the request was received, by whom the request was made, and whether the requesting party was at the time of the request engaged in interstate commerce.
(c) Provide all documents relating to the response to this interrogatory.
- 17. State the purpose for which ERCOT was formed and provide all documents relating to itJ formation.
Do HL&P and TU contend that ERCOT engages in activities different from, or has more power and authority than, other regional reliability councils such as SERC (Southeast Reliability Council)?.
- 18. State the purpose for which the TIS was formed.
Provide all documents relating to its formation.
List every occasion upon which an Electrical Utility has requested membership in TIS and provide all documents relating to such request and the response to that request.
I
- 19. (a) Do HL&P and TU contend that, if, pursuant to the July 21, 1976, FPC order (based on S202(d) of the Federal Power Act) authorizing reconnection without attaching FPC jurisdiction, they had reconnected with the
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Electric Utilities with which they had been interconnected prior to May 4, 1976, that the result would have been either economically debilitating or detrimental from an engineering perspective?
(b) if the answer to part (a) of this interrogatory is in the affirmative, explain in detail precisely why such action would have been economi-cally debilitating or detrimental from an engineering perspective, specifying each assumption, premise, calcula-tion, or conclusion upon which that response is based; (c) if the response to part (a) of this interrogatory is negative, identify the basis upon which it was determined not to interconnect under authority of the FPC's order.
- 20. In reference to the formation of ERCOT, identify each occasion upon which any employee of HL&P or TU engaged in any communication with any other party, indiv dual or entity, specifying the substance of each such communication, the employee of HL&P or TU who made it, the date, the recipient of the communication, and the recipient's response, if any, relating to:
(a) the advisability of limiting membership in ERCOT to Electric Utilities engaged only in intrastate commerce; (b) concern about possible antitrust implications of so limiting membership to intrastate Electric Utilities only; (c) alternative devices or understandings, either formal or informal, whereby Electric Utilities engaged in interstate commerce could be fore-closed from membership in ERCOT without this being made an explicit requirement for membership; and (d) provide all documents relating to (a)-(c) above.
- 21. In reJerence to the agreement, understanding, or contractual arrangements whereby HL&P and TU reconnected following their disconnection of May 4, 1976, identify and specify in detail:
(a) the occasions, instances, and dates upon which negotiations between HL&P and TU employees re-lating to possible reconnection occurred; (b) the precise agreement, understanding or con-tractual arrangement whereby the reconnection was effected; (c) any conditions that HL&P and/or TU insisted upon, requested or solicited from the other as a re-quirement before reconnection could be effected; (d) any contacts or communications from Electric Utilities other than HL&P and TU pertaining either to reconnection or new interconnections, and the response of HL&P and TU to those communi-cations; (e) any conditions that HL&P or TU insisted upon, requested or solicited from other Electric Utilities as a requirement before either Company would consider reconnection; and (f) provide all documents which relate to (c)-
(e) above.
- 22. In reference to the Comanche Peak Project, identify and explain: (a) any requirements which had to be satisfied before any Electrical Utility would be allowed to participate in the project; (b) all provisions of the Comanche Peak participation agreement, if any, which limit participation to Electrical Utilities engaged only in intrastate commerce; (c) each instance in which an Electri-cal Utility engaged in interstate commerce, or interconnect-ed with an Electrical Utility engaged in interstate commerce, ever requested participation in Comanche Peak and was refused; (d) those Electrical Utilities which requested participation in Comanche Peak and were granted participatory status; (e) for any Electrical Utilities identified in the response to parts (c) or (d) of this interrogatory, explain why that Electric Utility was either denied or granted participatory status; and (f) provide all documents which relate to (a)-(e) above.
- 23. (a) Describing the circumstances and providing the date, persons participating, and facilities inspected, identify each occasion upon which employees of HL&P and/or TU (including attorneys retained by either Company) visited the generating plants, relays, installations, or equipment of the other Company, either alone or accompanied by employees of the Company owning the facility, for the purpose of inspecting any relays, mechanical devices, or other equipment designed to prevent the flow of electri-cal power or energy in interstate commerce; (b) Describing the circumstances and providing the date, persons participating, and facilities inspected, identify each occasion upon which employees of HL&P or TU visited the generating plants, relays, installations, or equipment of any other company, entity or Electrical Utility (i.e., other than HL&P or TU) for the purpose of inspecting any relays, mechancial devices, or other equipment designed to prevent the flow of electrical power or energy in interstate commerce; (c) Identify each occasion, occurrence, or date upon which any employee of HL&P or TU requested, provided or received any pamphlets, printed material, reports, or other written matter, pertaining to the installation or maintenance by any Electrical Utility, of any relays, mechanical devices, or other equipment de-_gned to prevent the flow of electrical power or energy in interstate commerce, specifying the date, requested material, material received or provided, and the individuals involved; (d) estimate how much money has been expended, if
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any, since 1965 by HL&P and TU for the purpose of seeking to inspect relays, mechanical devices, or other equipment of another Electrical Utility or entity to ascertain whether any electrical power or energy was flowing from that equipment into interstate commerce; and (e) provide all documents which relate to (a)-(d) above.
- 24. (a) Identify by date each occasion or period upon or during which TU was interconnected with any Electrical Utility transmitting or receiving electrical power or energy in interstate commerce, or was interconnected with any Electrical Utility that was in turn interconnected with an Electrical Utility transmitting or receiving electrical power or energy in interstate commerce; (b) state in detail all detrimental financial consequences or disadvantageous engineering ramifications, if any, that occurred during these periods, occasions or instances of interstate interconnection which were a direct result, and/or were caused or effected by, this interstate inter-connection; and (c) provide all documents relating to (a)-(b) above.
- 25. (a) Describe in detail how the desire, practice, preference, or policy of HL&P and TU to operate exclusively in intrastate commerce has affected, influenced, controlled, or modified the design of physical facilities, plants, transmission facilities,.or any other construction engaged in by the two Companies; (b) state whether or not the maintenance of intrastate status or operation on the part of HL&P and TU had any impact, influence, effect, or consequences upon the cost of the physical facilities, plants, transmission facilities, or other construction costs borne by the two Companies; (c) indicate an approxi-mate figure representing how much additional cost, if any, was borne by HL&P and TU since 1965 in undertaking new construction or maintenance of existing facilities as a result of any policy or desire to remain exclusively in intrastate operation; (d) state in detail what assumptions and calculations were employed to prepare a response to subsection (c) of this interrogatory; and (e) identify every individual, person or employee of HL&P or TU who decided, or participated in deciding, to design, con-struct, or build any facility or modify any existing facility in such a manner that the owner Company would not become engaged in interstate commerce.
Respectfully submitted, 13 N_. fO_
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Judith L.
Harris Ronald H.
Clark Frederick H.
Parmenter Attorneys, Energy Section Antitrust Division U.S. Department of Justice Washington, D.C.
November 22, 1978
UNITED STATES OF AMERICA BEFORE THE ATOMIC ENERGY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
HOUSTON LIGHTING AND POWER
)
Docket Nos. 50-498A CO.,
et al.
)
50-499A
)
(South Texas Project, Units
)
1 and 2)
)
)
CERTIFICATE OF SERVICE I hereby certify that service of the foregoing FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS FROM DEPARTMENT OF JUSTICE TO THE HOUSTON LIGHTING
& POWER AND TEXAS UTILITIES COMPANIES has been made on the following parties listed hereto this 22nd day of November 1978, by depositing copies thereof in the United States mail, first class, postage prepaid, or by hand where an asterisk appears next to the name of the party.
Marshall E.
Miller, Esquire Richard S.
Salzman, Esquire U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.
C.
2C555 Washington, D.
C.
20555 Michael L. Glaser, Esquire Jerome E.
Sharfman, Esquire 1150 17th Street, N.W.
U.S. Nuclear Regulatory Washington, D.
C.
20036 Commission Washington, D.
C.
20555 Sheldon J. Wolfe, Esquire U.S. Nuclear Regulatory Chase R. Stephens, Secretary Commission Docketing and Service Branch Washington, D.
C.
20555 U.S. Nuclear Regulatory Commission Samuel J. Chilk, Secretary Washington, D.
C.
20555 Office of the Secretary of the Commission Jerome Saltzman U.S. Nuclear Regulatory Chief, Antitrust and Commission Indemnity Group Washington, D.
C.
20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.
C.
205S5 Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.
C.
20555
Roff Hardy Michael I.
Miller, Esquire Chairman and Chief Executive Richard E.
Powell, Esquire Officer David M.
Stahl, Esquire Central Power and Light Thomas G.
Ryan, Esquire Company Isham, Lincoln & Beale P.
O.
Box 2121 One First National Plaza Corpus Christi, Texas 78403 Chicago, Illinois 60603 G.
K.
Spruce, General Manager Roy P.
Lessey, Esquire City Public Service Board Michael Blume, Esquire P.O.
Box 1771 U.S. Nuclear Regulatory San Antonio, Texas 78203 Commission Washington, D.
C.
20555 Perry G.
Brittain President Jerry L. Harris, Esquire Texas Utilities Generating City Attorney, Company Richard C. Balough, Esquire 2001 Bryan Tower Assistant City Attorney Dallas, Texas 75201 City of Austin P.O. Box 1088 R.L.
Hancock, Director Austin, Texas 78767 City of Austin Electric Utility Department Robert C. McDiarmid, Esquire P.
O.
Box 1088 Spiegel and McDiarmid Austin, Texas 78767 2600 Virginia Avenue, N.W.
Washington, D.
C.
20036 G.
W.
Oprea, Jr.
Executive Vice President Dan H.
Davidson Houston Lighting & Power City Manager Company City of Austin P.
O.
Box 1700 P. O. Box 1088 Houston, Texas 77001 Austin, Texas 78767 Jon C.
Wood, Esquire Don R.
Butler, Esquire W.
Roger Wilson, Esquire 1225 Southwest Tower Matthews, Nowlin, Macfarlane Austin, Texas 78701
& Barrett 1500 Alamo National Building Joseph Irion Worsham, Esquire San Antonio, Texas 78205 Marlyn D.
Sampels, Esquire Spencer C. Relyea, Esquire Joseph Gallo, Esquire Worsham, Forsythe & Sampels Richard D. Cudahy, Esquire 2001 Bryan Tower, Suite 2500 Robert H.
Loeffler, Esquire Dallas, Texas 75201 Isham, Lincoln & Beale Suite 701 Joseph Knotts, Esquire
- 1050 17th Street, N.W.
Nicholas S.
Reynolds, Esquire
- Washington, D.
C.
20036 Debevoise & Liberman 806 15th Street, N.W.
Suite 700 Wasnington, D.
C.
20005
Douglas F. John, Esquire R. Gordon Gooch, Esquire Akin, Gump, Hauer & Feld John P.
Mathis, Esquire 1100 Madison Office Building Baker & Botts 1155 15th Street, N.W.
1701 Pennsylvania Avenue, N.W.
Washington, D.
C.
20024 Washington, D.
C.
20006 Morgan Hunter, Esquire Robert Lowenstein, Esquire
- McGinnis, Lochridge & Kilgore J.
A.
Bouknight, Esquire
- 5th Floor, Texas State Bank William Franklin, Esquire
- Building Lowenstein, Newman, Reis &
900 Congress Avenue Axelrad Austin, Texas 78701 1025 Connecticut Avenue, N.W.
Washington, D.
C.
20036 Jay M. Galt, Esquire Looney, Nichols, Johnson E. W.
Barnett, Esquire
& Hayes Charles G. Thrash, Jr., Esquire 219 Couch Drive J. Gregory Copeland, Esquire Oklahoma City, Oklahoma 73101 Theodore F. Weiss, Jr.,
Esquire Baker & Botts Knoland J.
Plucknett 3000 One Shell Plaza Executive Director Houston, Texas 77002 Committee on Power for the Southwest, Inc.
Linda L.
Aaker, Esquire 5541 East Skelly Drive Kevin B.
Pratt, Esquire Tulsa, Oklahoma 74135 Assistant Attorney General P.O.
Box 12548 John W.
Davidson, Esquire Capital Station Sawtelle, Goode, Davidson Austin, Texas 78711
& Tioilo 1100 San Antonio Savings Frederick H.
Ritts, Esquire Building Northcutt Ely San Antonio, Texas 78205 Watergate 600 Building Washington, D.C.
20037 W.
S.
Robson General Manager South Texas Electric Cooperative, Inc.
Route 6, Building 102 a :M N. COA Victoria Regional Airport Ronald H.
Clark ~, Attorney Victoria, Texas 77901 Energy Section Antitrust Division Department of Justice
.