ML19323G602
| ML19323G602 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/20/1980 |
| From: | Spiegel G SPIEGEL & MCDIARMID |
| To: | Chanania F NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8006060361 | |
| Download: ML19323G602 (2) | |
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law opmets cEonot SPIEGEL P.c.
SPIEGEL & MCDLLRMID sONNIE S. SLAIR c4Non$Is"T 2600 VIRGINIA AVENUE. N.W.
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0eERT A JAs WASHINGTON. O.C. 20037 CY eG ALAN J. ROTH TELEPHONE (202) 333-4500 GARY J. NEWELL DAN g oky ggo TELECOPf ER (202) 333-297A gyA A, u e
THOM AS N. MCHUGH. JR.
JOSEPM L VAN EATON DANIEL J. GUTTM AN SETEa < = ATT May 20, 1980 D AVID R. STRAUS g
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5 MAY 2 31980 > 5 f
omteof theSectelNT Fredric Chanania, Esq.
oc t W g & Sa @ls Nuclear Regulatory Commission Bf8
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7735 Old Georgetown Road 4
Room 11217 ca TO Washington, C. C.
20555 Re:
Proposed License Conditica Houston Lighting & Power Comoany,'et al.,
(South Texas Project, Units 1 and 2),
NRC Docket'Nos.'50-498A, 50-499A
Dear Fred:
I have reviewed the one-page document telecopied to us on May 9th dealing with the question of disconnecting facilities in the event of interconnection in interstate consnerce.
I was travelling last week and did not have an earlier opportunity fully to review it.
I am concerned that this may indicate that the NRC Staff is tending towards acceptance of paragraph 8 of the Outline of DC Settlement under which it is proposed that Houston Lighting & Power Company and Texas Utilities would not become "public utilities" sub-ject to FERC jurisdiction under the Federal Power Act.
We have seen no basis yet offered by any party as to how the public interest will be served by bifurcating regulation over the utilities of the Southwest, particularly among the Texas Interconnected Systems.
It seems clear that the public interest will not be served absent an inter-agency agreement between the FERC and the Texas Public Utilities Commission in order to assure, for example, that there will be fully coordinated operation of all systems to best serve the needs of the entire region.
Bifurcated regulation will not provide the clear and comprehensive regulations necessary to realize the substantive
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Fredric Chanania, Esq. May 20, 1980
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potential advantages of coordination and interchange (as estimated in the Stagg Systems study, for example) and to insure wheeling on reasonable rates, tems and conditions so that the many utilities in the area can benefit from interconnected operations.
We urge the Comi',sion Staff not to agree prematurely to any license condition allowing exemption from Federal jurisdiction without thorough, discussion with the small utilities who would most
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f- "_~ i edrge : Spiegel
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.rAttorney-for the ~Public Utilities
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