ML19338E951
| ML19338E951 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 09/29/1980 |
| From: | Fabrikant R, Favretto R, Kaplan D JUSTICE, DEPT. OF |
| To: | FEDERAL ENERGY REGULATORY COMMISSION |
| Shared Package | |
| ML19338E942 | List: |
| References | |
| ISSUANCES-A, NUDOCS 8010060353 | |
| Download: ML19338E951 (15) | |
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UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION CENTRAL POWER AND LIGHT COMPANY,)
PUBLIC SERVICE COMPANY OF )
OKLAHOMA, SOUTHWESTERN ELECTRIC ) Docket No. EL-79-8 ,
POWER COMPANY, AND WEST TEXAS ) l UTILITIES COMPANY ) j l
COMMENTS OF THE DEPARTMENT OF JUSTICE l CONTESTING THE OFFER OF SETTLEMENT !
i Pursuant to Section 1.18(e)(2) of the Rules of Practice and Procedures of the Federal Energy Regulatory Commission, as amended by Order No. 32, 1/the Department of Justice ("De-partment") hereby respectTully files with the Presiding Adminis-trative Law Judge Comments contesting the " Offer of Settlement" in the above-captioned proceeding filed on July 28, 1980, by Central Power and Light Company ("CPGL"), Public Service Company 1
of Oklahoma ("PS0"), Southwestern Electric Power Com
("SWEPC0") and West Texas Utilities Company ("WTU") pany (collec-tively referred to as "CSW"), and Dallas Power 6 Light Company
("DPGL"), Texas Electric Service Company ("TESC0"), Texas Power 6 Lignt Company ("TP6L") (collectively referred to as "TUCS")
and Houston Lighting 6 Power Company ("HLGP").
I. Background l A significant portion of the electricity consumed in the State of Texas is produced, transmitted and sold by electric utilities which do not operate in interstate commerce. These exclusively intrastate utilities include TUCS and HLGP. TUCS, HLGP and other utilities operating solely within Texas are mem-bers of the Electric Reliability Council of Texas ("ERCOT").
Applicants CPGL, PSO, SWEPC0 and WTU are all operating subsidi-aries of Central and Southwest Company, a public utility holding company. CPGL operates tirely within Texas and is a member of ERCOT. WTU is a bifurca. system: its Northern Division has -
historically operated in 3.n.erstate commerce, whereas its South-ern Division has operated solely in Texas and is a member of ERCOT. PS0 and SWEPC0 operate in interstate commerce. Both are members of the Southwest Power Pool ("SWPP"), an interstate co-ordinated and interconnected group of utilities in Oklahoma, Louisiana and a small portion of Texas, bordering ERCOT's terri-tory.
1/ Procedure for Submission of Settlement Agreements, Docket Ro. RM78-16 (Issued June 13, 1979).
i 8 010060 SN
Beginning in 1974 CSW sought the cooperation of TUCS and HLGP in establishing interconnections that would electrically integrate CSW's SWPP subsidiaries and its ERCOT subsidiaries.
After TUCS and HLGP declined to accede to CSW's proposal, WTU, on May 4, 1976, energized certain radial ties and began trans-mitting power from Texas to PS0 for resale to customers in Okla-homa. Immediately upon being informed of the interstate inter- )
connection, TUCS and HLGP, in order to avoid FERC jurisdiction, ;
disconnected from CPGL, WTU, each other and other utilities in Texas. While TUCS and HLGP reconnected to one another within a matter of days, these utilities did not reconnect with other l utilities in ERCOT until issuance of an order by the Texas Pub-lic Utility Commission ("TPUC") nearly a year after the original disconnection. 2/ In add 4 tion, the TPUC Order of May 1977 precluded CPGL and WTU from operating in interstate commerce and required any utility operating solely in Texas to obtain prior TPUC or Federal Power Commission approval for future operation in interstate commerce. 3/
In 1978 the Public Utility Regulatory Policies Act ("PURPA")
was enacted. Under PURPA, the FERC is authorized, inter alia, to establish interconnections between SWPP utilities and ERCOT utilities without the latter coming under FERC jurisdiction for l l
2/ Public Utility Commission of Texas, Docket No. 14, Final Urder (May, 1977) and Amended Final Order (July 11, 1977). TUCS and HLGP could have reconnected prior to the TPUC orders without subjecting themselves to the jurisdiction of the Federal Energy Regulatory Commission ("FERC"). See Order Rejecting In Part and Accepting In Part Application For Action Pursuant to Section 202, FERC Docket No. E-9558 (Issued July 21, 1976). As a result of Commission action in Docket No. E-9558, CPGL and WTU's South-ern Division are now interstate utilities regulated by the FERC under Section 201 of the Federal Power Act. Even though both TU and HLGP are interconnected, directly or indirectly, with CPGL.
and WTU, the Commission in Docket No. E-9558 held that TU and HLGP were not interstate utilities. The Commission's order in Docket No. E-9558 was remanded by the Court of Appeals in Cen-tral Power G Light Co. v. FERC, 575 F.2d 937 (D.C. Cir. 1978) and currently is under reconsideration by the Commission.
3/ The FERC has participated in a challenge to the TPUC Order in the United States District Court for the Western District of Texas, Civil Action No. A-77-CA-86.
. ratemaking purposes. On February 9, 1979, CSW filed an applica-tion 4/ in the instant proceeding for approval of four al-ternating current (synchronous) interconnections ("AC Intercon-nection" or "AC grid") between ERCOT and SWPP under Sections 202-204 of PURPA. 16 U.S.C. 55 824i, 824j, 824k (1978). TUCS and HLGP opposed CSW's Application.
On June 27, 1980, in an attempt to settle, inter alia, the instant FERC proceeding and a related proceeding before the Nuclear Regulatory Commission ("NRC"), S/ CPGL filed an amended j application 6/ seeking approval under PURPA of two direct ]
current (asynchronous) interconnections ("DC Interconnec-tions") between ERCOT and SWPP. The Offer of Settlement, which j was signed by CSW, HLGP and TUCS, effectuating the proposal set l forth in the Amended Application, was filed on July 28, 1960 ;
(" Offer of Settlement").
In addition to the Offer of Settlement, CSW, TUCS, HLGP, the FERC Staff and the NRC Staff recently have entered into a sup-plemental letter of understanding (" Letter Agreement") with re-gard to conditions to be attached to the proposal contained in the Offer of Settlement. The conditions include rate methodolo-gies for wheeling to, from and over the DC interconnections, reservation of capacity for firm power wheeling, and the oppor-tunity for participation by other utilities in the ownership of incremental capacity increases in the DC interconnections.
l 4/ Application of Central Power and Light Company and Others l Tor Exemption from State Commission Orders Preventing Voluntary Coordination Pursuant to Section 205 of the Public Utility Regu-latory Policies Act of 1978, and Interconnection of Facilities, Provision of Transmission Services and Related Relief Pursuant to Sections 202, 210, 211 and 212 of the Federal Power Act ("Ap-plication").
l 5/ Houston Lighting and Power Co., (South Texas Project, Units '
1 and 2), Docket Nos. 50-498A, 50-499A; Texas Utilities l Generating Company (Comanche Peak Steam Electric Station, Units l 1 and 2), Docket Nos. 50-445A, 50-446A. The NRC proceeding in-volved the issue of whether the intrastate-only operations of certain ERCOT utilities would create or maintain a situation in-consistent with the antitrust laws or the policies underlying those laws under section 105c of the Atomic Energy Act of 1954.
Applicants for the nuclear licenses in that proceeding, includ-ing TUCS and HLGP, have reached a settlement agreement with the governmental parties therein which was tendered to the NRC Licensing Board on September 15, 1980.
6/ Amendment to Application of Central Power and Light Com-pany and Others for Interconnection of Facilities, Provision of Transmission and Related Relief Pursuant to Sections 210, 211 and 212 of the Federal Power Act (" Amended Application").
II. Description of the Offer of Settlement The proposal contained in the Offer of Settlement would re-quire CSW to construct a direct current asynchronous intercon-nection of 200 mw capacity between PS0 near Lawton, Oklahoma and WTU near Oklaunion, Texas (" North Interconnection"). CSW and HL6P would be required to construct a 500 mw direct current asynchronous interconnection between SWEPCO near Walker County, Texas and the South Texas Nuclear Project (" South Interconnec-tion"). The Offer of Settlement includes terms and conditions for ownersh.p participation by other entities and rates for wheeling power over the DC interconnections.
I The Letter Agreement of September 11, 1980, supplements and, in some instances, supplants terms in the Offer of Settlement.
It requires each owner of the DC lines to file a single wheeling tariff with the Commission, to, from, and over the DC intercon-nections which, inter alia, incorporates each relevant system's DC transmission costs in the overall transmission costs of that system; provides for a reservation of capacity in the lines for certain firm power wheeling for a minimum of five years after each DC facility goes into commercial operation; and provides for planning and participation by other entities in the owner-ship of incremental capacity in the DC lines. 1/
III. CONTESTED ISSUES The Department contests the DC interconnection proposal as set forth in the Offer of Settlement as proposed to be modified by the Letter Agreement, on the grounds that, it is not clear that the proposal will meet the requirements of PURPA. It is undisputed by the Offer of Settlement that interconnections be-tween ERCOT and SWPP are necessary and are in the public inter-est. The Department believes that AC interconnections between ERCOT and SWPP may have procompetitive features which DC inter-connections would not possess. Moreover, the Department be-lieves that DC interconnections exhibit anticompetitive charac-teristics not associated witn AC interconnections, and that con-ditions cannot be imposed upon the DC interconnections that would render those interconnections the competitive equivalent of AC interconnections. Further, there are no apparent cost or system reliability reasons which would warrant the construction of the proposed DC interconnections rather than AC interconnec-tions as the initial mode of interconnection between ERCOT and SWPP.
1/ In addition, the Letter Agreement obligates TUCS to file a single tariff for wheeling power to and from the DC intercon-nections.
A. The Legal Standard To grant an application for an interconnection under PURPA, the Commission must find that the interconnection (1) is in the public interest, (2) would (a) encourage overall conservation of energy or capi-tal, t
(b) optimize the efficiency of use of facilities and resources, or (c) improve the reliability of any electric utility system or Federal power marketing agency to which j the order applies, and 2
(3) meets the requirements of Section 824k of this title.
36 U.S.C. 5 824i(c). 8/
In determining whether an interconnaction application under PURPA meets the first criteria, that it be in the "public inter-est," the FERC must consider the impact of the interconnection on competition. The Supreme Court has held that in implementing the public interest standard under the ' :deral Power Act, FERC must give due consideration to competi an. 9/ FERC's obli-gation to consider competition under tl PURPA amendmer ts to the Federal Power Act ("FPA") is no less ci apelling than it is under the unamended FPA. Accordingly, the Fb i cannot deteriine that a contested interconnection is in the "public interest within
, the meaning of PURPA if there is evidence in the recorl that an alternate mode of interconnection would not provide su'stan-i tially similar benefits while posing fewer competitive risks.
In this proceeding, FERC must consider whether an At grid would achieve substantially the same benefits as the proposed DC interconnections without creating the same anticompetitivi ef-fects. FERC can make this determination by comparing the 7ro-posed DC interconnection in the Offer of Settlement as proposed to be modified by the Letter Agreement, with the AC interconnec-tion CSW initially proposed. Should the record demonstrate 8/ Section 824k adds Section 212 to the Federal Power Act.
Section 212 requires the Commission to make additional findings before ordering wheeling or interconnections.
9/ Gulf States Utilities v. FPC, 411 U.S. 747 (1973); FPC v.
Conway Cor p. , 426 U.S. 271 (1976).
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'. that, for example, the original CSW AC proposal exhibits fewer anticompetitive characteristics than the DC proposal and pro-vides comparable overall conservation of energy or capital, ef- l ficiency in the use of facilities or resources, or improvement I in the reliability of the electric systems to be interconnected i then FERC cannot at the same time fini that the instant DC in- )
terconnection proposal meets the "public interest" standard of i PURPA. The Commission has already ruled in Order No. 32 that the proponents of an Offer of Settlement continue to bear the burden of proof that their proposal satisfies the statutory cri-teria.
B. Benefits of AC Interconnections l AC interconnections are the normal mode of interconnection l in the electric power industry throughout the United States. DC 1 interconnections have been utilized, to date, primarily for providing stability in special circumstances or for high voltage long distance transmission of large blocks of power from distant ger.eration sources to an AC grid. 10/ Such is not the case with .
the DC interconnections contained In the proposed Offer of f Settlement. _1_1/ l Since the enactment of the FPA in 1935, the major electric '
utilities in Texas have refused to engage in interstate electrical l transactions with the remainder of the nation. As a result, ERCOT l is today electrically isolated from the SWPP and any other neigh- '
boring utilities. The effect of the isolation has been to pre-clude opportunities for competitive power transactions in the southwestern United States. Utilities and other generators and l customers outside this isolated area are foreclosed from buying or selling power, and other entities inside ERCOT are foreclosed from buying or selling electricity outside ERCOT. The construction of AC interconnections between ERCOT and SWPP would create opportuni-ties for such transactions to a significantly greater degree than would the construction of the proposed DC lines. AC lines could be constructed at a lower cost per unit of megawatt capacity than DC lines, and~would furnish substantially greater capacity for in-terstate transactions than would DC lines. Thus, AC lines would I I
enable utilities throughout the southwest United States to opti-mize the potential benefits of interstate interconnections.
10/ The longest such DC line was built after AC synchronous ITnes were already operating interstate on parallel paths.
11/ The proposed Northern Interconnection would consist of two l Eack-to-back terminals, one on each side of the ERCOT-SWPP !
border at Oklaunion, Texas. The proposed Southern Interconnec- )
tion would consi.st of a DC line approximately 153 miles long.
See Testimony ef Jack C. Wells, pp. 4-5, Offer of Settlement.
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The construction of the proposed AC grid, although of lower capital cost than the DC proposal, would provide substantially more transfer capacity. An AC interconnected grid between ERCOT and SWPP, such as that proposed in the Application, provides not only such greater capacity, but also much more flexibility for future power flows and future economic interconnections than does the DC proposal contained in the Offer of Settlement. Once an AC grid is in place, additional small capacity AC lines can be easily constructed in the future to meet new needs at rela-tively low cost; smaller utilities in Texas could own and con-struct such smaller capacity AC lines as their individual needs dictate.
Thus, if an AC grid is constructed, the market for power flows between ERCOT and SWPP would develop in a manner uncon-strained by artificial historical or technical barriers.
C. Detriments of the DC Proposal In contrast to AC interconnections between SWPP and ERCOT, the DC proposal poses a number of significant risks to competi-tion and efficiency in power transactions in the southwest United States. These risks fall into three categories: 1) per-mitting DC interconnections now may prejudice future intercon-ne'ction decisions; 2) DC interconnections could result in greater capital and operating costs to owners and users than AC interconnections; 3) DC interconnections also exhibit other an-ticompetitive , bottleneck characteristics.
- 1. The approval of DC lines as the initial means of inter-connections will likely irrevocably dictate the future character of interconnections in a manner that would not occur if AC lines were chosen as the first type of interconnections between ERCOT and SWPP. Thus, FERC is being called upon to render an opinion that will have an importance which transcends the instant pro-ceeding. Construction of DC interconnections between ERCOT and SWPP will forestall, or possibly preclude for the foreseeable future, the type of AC grid with the procompetitive benefits mentioned above. The instant proceeding has its genesis in CSW's need to interconnect its four operating subsidiaries in order to comply with the Public Utilities Holding Company Act, 15 U.S.C. S 79 et seq. Once FERC permits CSW to interconnect its four operating subsidiaries, it is unlikely that other enti-ties in the ERCOT or SWPP will be willing or able to invest as much capital as will CSW and HLGP in constructing interconnec- i tions between ERCOT and SWPP. Instead, the construction of future interconnections between ERCOT and SWPP will be largely predetermined by the interconnections which will have been decided in this proceeding.
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I If an AC grid were constructed at this time, future intercon-nections between ERCOT and SWPP could be either AC or DC in char-acter. In particular, once an AC grid is in place, relatively low cost and low capacity AC lines can be constructed with only a min-imal amount of coordination. The cost of constructing additional DC lines would be unaffected by whether the initial interconnec- i tions were AC or DC. If, however, CSW and HLGP are permitted new I to construct DC lines, it will not be possible to construct the type of low cost AC lines that could have been constructed had an AC grid, rather than DC lines, been constructed at the out-set. 12/ Moreover, once DC interconnections are in place, the cost oi : 1 stalling the type of AC grid that would have been con-structed if the DC lines had not been built would be substantially greater than the cost of adding incremental capacity to existing DC interconnections.
- 2. Foreclosure of an AC interconnected grid and the result-ing inability to construct additional AC smaller capacity ties will cause, both in the short and the long-term, a misallocation of resources and will impose artificial constraints on the elec-tric utility industry in the southwest United States. Once the DC interconnections are in place, all power exchanged between ERCOT and SWPP will be required to pass over these lines, such that some of the power will have to be wheeled great distances even though the geographic distance between the point of origin and the ulti-mate point of destination of that power is relatively short. Such unnecessary and inefficient wheeling would be obviated by the con-struction of an AC grid, since such a grid would enable utilities to construct AC lines at a greater number of strategic delivery points than that contemplated by the DC proposal. These AC lines would not pose the locational problems created by a smaller number of DC lines.
It is clear from the testimony of CSW's Senior Vice President for Engineering, Mr. Jack C. Wells, that substantial economic ad-vantages will result from constructing connections between SWPP and ERCOT. Mr. Wells states (at page 9) that over the period 1984-2000, CSW's total revenue requirements with the DC intercon-nections will be approximately $1.6 billion less than if the in-terconnections are not installed. Mr. Wells' testimony does not demonstrate, however, whether CSW's total revenue requirements would be even lower, if an AC gri were constructed. Moreover, ,
the DC proposal contained in the Offer of Settlement minimizes the extent to which the benefits of CSW's interconnections will be shsred with small electric utility systems, and does not compare ;
the benefits which sn.all systems would obtain from the 12/ It is possible that DC interconnections may permit the construction of smaller capacity AC interconnections than would te possible absent any interconnections whatsoever, but only if the AC ties are operated in close coordination with the DC ties.
construction of an AC grid. The proposal, in this regard, doen not e'ncourage overall conservation of energy or capital or ey11 mize the efficiency of use of facilities and resources as required by Section 210 of the FPA. Finally, the D.~. interconnection may place an undue burden on such small electric utilities, qualifying 4
cogenerators and qualifying small power producers, and electric utilities affected by the proposed Offer of Settlement may be un- 1 reasonably impaired in rendering adequate service at a competitive l cost to their customers in contravention of Section 212 of the i Federal Power Act.
- 3. DC lines contain exceedingly restrictive characteristics in addition to those mentioned above which may render such lines
" bottleneck" facilities that would impair, not facilitate, power flows between ERCOT and SWPP. For example, HL6P and CSW will have daily scheduling control over all transactions over the DC lines.
If AC interconnections with their greater capacity and flexibility were constructed in lieu of DC, much less coordination of long-term planning and daily scheduling would be required.
In conclusion, for all the foregoing reasons, the Department formally contests the Offer of Settlement tendered by CSW, TUCS and HLGP and asserts that such Offer of Settlemnt does not contain substantial evidence for the Presiding Administrative Law Judge and the Commission to find that the Offer of Settlement is in the public interest and meets the other requirements of PURPA. PURPA requires a reasoned consideration by the Commission of the effects on competition of approving the proposed Offer of Settlement.
IV. PROPOSED PROCEDURES The Department, in an effort to expedite hearings on a set-tlement in accordance with 18 C.F.R. 5 1.18(b), recommends the following procedure to compile an adequate record on the cor. tested issues:
- 1. That the Presiding Officer issue an order defining the issues and setting down a procedural schedule within 30 days; l
- 2. That the order provide for a phased proceeding, Phase I to require the proponents to show that the Offer of Set-t1ement, as compared to AC interconnections, fulfills the requirements of PURPA. If in the Phase I proceeding it is determined that the Offer of Settlement, as compared to AC interconnections, does not fulfill the requirements of PURPA, a Phase II proceeding shall be held to detet-mine whether the AC proposal as contained in CSW's origi-nal Application complies with PURPA;
- 3. That such an order provide a limited period for necessary discovery;
. 4. That the parties be required to file simultaneous direct testimony within 45 days of the close of discovery; re-buttal testimony to be filed 30 days from the filing of direct testimony;
- 5. That evidentiary hearings for the purpose of cross-examining all persons filing direct and/or rebuttal testimony commence within 30 days of the filing of rebut-tal testimony.
The Department believes that such procedures will allow the compilation of an adequate record, while still expediting the final decision in the case.
V. CONCLUSION On the basis of the foregoing, the Department of Justice re- l spectfully urges the Presiding Officer to issue an order:
- 1. Finding that there are contested issues of material fact, I
and that the record does not currently contain substan- ,
tial evidence, upon which the Commission may reach a rea- l soned decision on the merits of the contested issues;
- 2. Defining the issues to be resolved in the proceeding;
- 3. Setting down a procedural schedule to expeditiously con-clude this proceeding on an adequate record.
Res ectfully submitted, I $ )
Richard J. Fffe etto r Assist %nt Attorney General Dep
./
c/chl / /l w,
/Mnald A. Kap 1'an f' Chief Energy Section
- iobert Fabrikant Assistant Chief Energy Section ,
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Mildred L. Calhoun Dated: September 29, 1980 Attorneys, Energy Section Washington, D.C. Antitrust Division Department of Justice Telephone No. (202) 724-6624 l
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. I CERTIFICATE OF SERVICE l l
l I hereby certify that on this 29th day of September, 1980, I caused to be served by United States mail, postage prepaid, copies of the foregoing Comments of Department of Justice Con-testing tne Offer of Settlement upon the counsel listed below:
6:: ", ' f ~
Nancy H. )(cMillen Attorney l
l
., SERVICE LIST - DOCKET NO. EL 79-8 David M. Stahl, Esq. David J. Rosso, Esq.
Sarah F. Holzsweig, Esq. Peter Thorton, Esq.
Isham, Lincoln G Beale Isham, Lincoln 4 Beal Suite 325 4200 One First National Plaza 1120 Connecticut Ave., N.W. Chicago, Illinois 60603 Washington, D.C. 20036 George B. Pletsch, Esq. Walter C. Greenough, Esq.
Gearold L. Knowles, Esq. Schiff, Hardin G Waite Schiff, Hardin G Waite 7200 Sears Tower 1101 Connecticut Avenue, N.W. 233 South Wacker Drive Washington, D.C. 20036 Chicago, Illinois 60606 J. Mark Davis, Esq. Stephen K. Cuffman, Esq.
Arkansas Public Service Comm. 500 Union Train Station Attorney General's Office Little Rock, Arkansas 72201 Litigation Division Justice Building Tom Diamond, Esq.
State Capitol Grounds City of El Paso, Texas Little Rock, Arkansas 72201 1208 First City National Bank Building Jack A. Swidensky, Esq. El Paso, Texas 79901 Southwestern Power Admin.
P.O. Drawer 1619 Carl W. Ulrich, Esq.
Tulsa, Oklahoma 74101 Chapman, Duff G Paul 1730 Pennsylvania Ave., N.W.
Evern R. Wall, President Washington, D.C. 20006 El Paso Electric Company P.O. Box 982 Lee Cook, Esq.
El Paso, Texas 79960 Oklahoma Corporation Comm.
Jim Thorpe Office Building Michael D. McQueene, Esq. Oklahoma City, Oklahoma 73105 Kemp, Smith, White, Duncan and Hamm David R. Richards. Esq.
P.O. Drawer 28000 Texas AFL-CIO El Paso, Texas 79999 600 West 7th Street Austin, Texas 78701 Stephen Gardner, Esq.
Legal Aid Society of Central Jon C. Wood, Esq.
Texas W. Roger Wilson, Esq.
900 Perry Brooks Building Matthews, Nowlin, MacFarlane Austin, Texas G Barrett 1500 Alamo National Bldg.
W.S. Robson, General Manager San Antonio, Texas 78205 South Texas Elec. Co-op, Inc.
Rt. 6,. Building 102 Morgan Hunter, Esq.
Victoria, Texas McGinnis, Lockridge G Kilgore 5th Floor, Texas State Bank L.E. Gross, General Manager 900 Congress Avenue Medina Electric Co-op, Inc. Austin, Texas 78701 2308 18th Street Hondo, Texas 78861
Mark White, Attorney General Stuart Fryer, Assistant Donald R. Allen, Es Attorney General Ronald G. Greening,q.Es State of Texas 1575 "I" Street, N.W. q.
P.O. Box 12548, Capitol Station Washington, D.C. 20005 Austin, Texas 78711 Carol M. Barger, Esq.
Jerry L. Harris, Esq. Consumers Union of the U.S.,
Richard C. Balough, Esq. Inc.
City of Austin, Texas Southwest Regional Office P.O. Box 1088 .
500 West 13th Street Austin, Texas 78767 Austin, Texas 78701 Cecil L. Johnson, Esq. Richard A. Shannon, President i
Gulf States Utilities Company Texas Environmental Coalition P.O. Box 2951 P.O. Box 2164 Beaumont, Texas 77704 Austin, Texas 78767 Madeline Bass Framson Benny H. Hughes, Esq.
Orgain 4822 Waynesboro Drive Bell 6 Tucker Houston, Texas 77035 Beaumon,t Savings Building Beaumont, Texas 77701 Gary B. Randall, Esq.
National Rural Electric Co-op, Inc. Wallace F. Tillman, Esq.
National Rural Electric Co-op, Inc.
1800 Massachusetts Ave., N.W.
Washington, D.C. 20036 1800 Massachusetts Ave., N.W.
Washington, D.C. 20036 ,
Frederick H. Ritts, Esq. i William H. Burchette, Esq. J.L. Johns, President Law Offices of Northcutt Ely Northeast Texas Electric Co-op, Inc.
Watergate 600 Building Washington, D.C. 20037 P.O. Box 70 Gilmer, Texas 75644 Carl M. Turner, Exec. Manager New Mexico Rural Cooperative Electrification Alan H. Richardson, Esq.
Association P.O. Box 416 American Public 2600 Virginia PowerN.W.
Avenue, Assoc.
Santa Fe, New Mexico 87501 Washington, D.C. 20037 Michael D. Oldak, Esq. Harold E. Shapiro, Esq.
Office of General Counsel Solicitor U.S. Department of Energy John A. Cameron, Jr., Esq.
6A152 Forrestal Bldg. Robert L. Woods, Esq.
1000 Independence Ave., S.W. Alan Wolf, Esq.
Washington, D.C. 20585 Charles F. Reusch, Esq.
Frederick Klein, Esq.
Robert A. O'Neil Federal Energy Regulatory
. Miller, Balls 6 0'Neil, P C. Commission 776 Executive Building 825 N. Capitol Street, N.E.
1030 Fifteenth Street, N.W. Washington, D.C. 20406 Washingtor, D.C. 20005 Frederick K. Slicker Worsham, Forsythe 6 Sampels Twenty-Five Hundred, 2001 Bryan Tower Dallas, Texas 75201
Douglas F. John, Esq. Harry A. Poth, Jr., Esq.
McDERMOTT, WILL 6 EMERY Floyd L. Norton, IV, Esq.
1850 K Street, N.W. Reid 6 Priest Washington, D. C. 20006 111 19th St., N.W.
plashington, D. C. 20036 William R. Brown, Esq. R. Gordon Gooch, Esq.
Charles G. Thrash, Jr., Esq. Steven R. Hunsicher, Esq.
J. Gregory Copeland, Esq. Baker 6 Botts Baker G Botts 1701 Pennsylvania Avenue, N.W.
3000 One Shell Plaza Washington, D.C. 20006 Houston, Texas 77002 Jack Hopper, Esq. -
Jay M. Galt, Esq. South West Utility Associates Looney, Nichols, Johnson P.O. Box 12952 6 Hayes Austin, Texas 78711 219 Couch Drive Oklahoma City, Oklahoma 73102 John Schwab, Esq.
Association of Louisiana Leland Leatherman, Esq. Electric Co-ops i McMath, Leatherman 6 Woods Cajun Electric Power Co-op l 711 West Third Street P.O. Box 3036 Little Rock, Arkansas 72701 Baton Rouge, Louisiana 70E21 Robert W. Sullivan, Esq. William C. Wise, Esq.
Grand River Dam Authority Robert Weinberg, Esq.
Drawer G Suite 500 Vinita, Oklahoma 74301 1200 18th Street, N.W.
Washington, D.C. 20036 James Moran Scott, Jr.
830.?. Albacore Robert C. McDiarmid, Esq.
Houston, Texas 77074 Robert A. Jablon, Esq.
Marc R. Poirier, Esq. J Carl N. Stover, Esq. Spiegel 6 McDiarmid C.H. Guernsey 6 Company 2600 Virginia Avenue, N.W.
National Foundation, West Bldg. Washington, D.C. 20037 Northwest 58th and Portland Oklahoma City, Oklahoma 73112 Don Hart, Manager Taylor Electric Co-op, Inc.
Charles K. Mallory, Esq. P.O. Box 250 Hunton 6 Williams Merkel, Texas 79536 1919 Pennsylvania Ave., N.W.
Suite 710 Willian D. Meriwether, Jr., Esq.
P.O. Box 19230 P.O. Box 61000 Washington, D.C. 20036 New Orleans, Louisiana 70161 Lawrence S. Smith, Esq. Charles Herring, General Manager Small, Craig 6 Werkenthin Lower Colorado River Authority 2600 Austin National Bank Bldg. P.O. Box 220 Austin, Texas 78701 Austin, Texas 78767 i
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