ML19347A611

Responds to ASLB Info Request Re Inputs to Heins & Keeley Testimony & Exhibit Related Studies, & Open Matters Requiring ASLB Decision.Related Correspondence

ML19347A611
Person / Time
Site:	Midland
Issue date:	01/27/1977
From:	Rosso D ISHAM, LINCOLN & BEALE
To:	Coufal F, Leeds J, Luebke E Atomic Safety and Licensing Board Panel
References
NUDOCS 8007291070
Download: ML19347A611 (12)

Text

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THIS DOCUMBIT CONTAlilS-

, , POOR QUAUTY PAGES

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• meAfetH A C Gai4H3 Daveo *t SpCCfota N[TNaLDOf'C4Ovtm DAdeO M SfaML PAut F MAPat ten as ANa es vtRSMDO CHRaSflNC tec M MCHMCytm POO C R T H *MECLER DONALO O HILLIm CfD Roe 4ALO G 2A*8 ARIPs January 27, 1977 Frederic J. Coufal, Esq. Dr. Emmeth A. Luebke, Esq.

Chairman .

Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory Comm.

U.S. Nuclear Regu3atory Comm. Washington, D.C. 20555-Washington, D.C. 20555 m d v Dr. J. Venn Leeds, Eng. j 10807 Atwell

'W4 Houston, Texas 77096 l

\

Dll'e Re: Midland Suspension Hearing 3 p$ ,

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Gentlemen:

.I am responding to the Doard's request for infor- e mation with regard to the following three points:

1. To give the Board an idea of the nunter of persons involved in providing inputs to Mr. Heins, which he uti.lized in his own studies, the results'of which are related in his testimony'and exhibits.

2.. To'give the Board'our views on the best procedure for-informing the Board more fully as to the under-lying methods and assumptions which resulted in the

. inputs utilized by Mr. Heins and Mr. Keeley in.the studies which are related in their testimony and 3.

exhibits 80 0 To list those open matt rb which 72 91C 8 ,0 re ulrc a decision

-byLthe Board, wg //y g_ 'n ~'

3-Messrs. Coufai Luobke and Leeds

January 27, 1977 Page 2 mm en 0 5 oo Su k .m Eefore proceeding with a discussion of points 1 and 2,

.however,-there are a few points which I would like to make.

Cases such as the one before.this Board are somewhat unique in that they.do not present questi~ons solely of "who did what to v.hom" where the critical factual question may be what a witness saw or"did himself and what he_knows_"of his own knowledge" or what is simply hearsay. The. questions in this case with regard to Mr. Ucins, for example, relate to whether a corporation's

planning for the future is reasonable and realistic; whether its analyses and projections of future generating requirements and energy' sales are reasonable, given the current state of the art for the making of such projections and the currently avail-able facts;-and whether contingencies planned for, and assumptions made as to the future, are reasonable. Not that such assumptions and projections are exact, for no one can hope to be exact about the future, but that they are reasonnble projections of what is likely to happen.

In order to make such far-rcaching studios, which l include projections of what the state of the economy is likely to be during the next ten years, how life-styles are likely to change, population growth estimates, etc., a.corperation must employ a variety of persons who keep track of historical and recent trc ds with regard to specific indicators and have the-knowledge and experience to evaluate those trends and what they portend for the future. Inputs for such projections-can include, for example, governmental studies regarding such matters as eco-nomic and population grouth.

Clearly, such studies must comprise a corporate

-effort: no one man can do it all,uno one_ man can be familiar

.with all.of the inputs, no one man can carry all of the details with-regard to such studies!around in his head. Each person J

involved must. rely pn .the . expertise of many other pe rsons uithin-the Company. They consult with each other, cach providing theTother.with inputs );cessary to allow'the other to perform hisifunctions. . Naturally, when one is asked whether he, "of his own knowledge," can_ state that a person he has consulted with used the proper inputs'in performing-an analysis, the-

_.personiasked will renpond'that ycu will have to ask the persen L

who did'that particular. analysis.

In presenting its suspension _ case, Licensec put forth as

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its witness-the man who did the final analysis, who synthesized.

the;workLof.all the others.and made the ultimate studies and judgments as.to plaaning' Licensee's. system for the next ten years. ?Furthermoru, Licensec offered to provide as a witness to respond to-questions any' person within its employ or that of 11ts agentsrand consultants whoLhad an input-to thc_ final study. .

And: Licensee continuosito be prepared to provide any such wit-n'e s s . . Itis=then^up:to the. Board and.the other. parties to the

.- ;preceedinghtoldete'rmine.the degree of detail which they wish to

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, se==i . . wuiu.c ueuse anu weeus .

]

. / January :27, K15.' -

.Page:3 ^ '

, inquire into. . .Once questions ~of detail'beyond the personal knowledge of.thc. wit' ness are: asked, Licensec_must'be given the fopportunity:to respond to such' questions'with an appropriate witness. It i's_after;all,:the knowledge and-planning of the

corporation;which in the question here,'not that of_a particular

. _ witness.= Itjis in the naturc of'these proceedings that no onc l' witness canfrespond to all1 detailed questions regarding: computer.

i. programs, inputs'and: outputs.of_ studies'and ovaluations uhich, were:provided to'him_by other corporate 1 experts and that, when

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such questions-are: raised, the appropriateLcxpert will be. called.-

It:is simply notipermissibic to allow a party-to raise such questions.onLeross-exemination of a. witness'and then to object to the' production of the appropriate'witnesu to answer the ques-tions. -It'is not permissible _for that: party _to argue' that he doesn't.want~to hear the answer now, that the mere fact'that-the first witness.didn't know;the answer proves that the cor-'

porate; study is deficient. That is not the way to arrive at a '

fair evaluation of the merit of the corporate study. Licensee 3 must be permitted to respond to questions raised-by putting-e

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forth theLtestimony of the appropriate expert.

The~. question was raised.at the hearing of_whether all such. potential witnesses-should be available on-call in Chicago-or whether some other more practical arrangement should be made, which w'uld'o allow-then toiremain in Jackson, Michigan ~doing their usualt tasks, andLrcqttire them to come to Chicago, if

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andiwhen necded to tcstify. This is why.the Board asked the fir'stsquestion: lunt many people arc involved. The following is..an: attenipt to advisc- the Board on this- point.

1. Input:withircgard to Cost ofL roduction P and Loss of1 Load Probability Assessment Portions of Mr. Heins' '

testimony.

' Including Mr~ Ucins, atileast 19 persons provided:

: inputs'to'the_ analyses ~with regardito Loss of Load and Produc-tion 1 Costing' presented in-Mr._Heins'. testimony ~and_ exhibits.

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These inputs: included the following matters:

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!= li Data with regard.-to existingfand expected. generating i capability ~and reserve availability of ECAR, Ontario  ?

1 ~. Hydro,iDetroit.rdisoniand other! interconnected com- ',1 Lpanies...

o

.2'. Prices {offexternalipower.- '

d j 3.: : Plant normal maximum operating levels.

Ei 2

4. iMaintenancejexpectations..

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-5..LHeat; rate datai l

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• ,, J 6l. 1Nuclearffue1Icosts-LE z^. t, by . m a & . .- L -- - - - - ~" - ~- i

c.

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. Messrs..Coufa' Luchke and Locds ,

January 27, 1. 7 Page 4 *

7. Fossil' fuel costs

8. IIistorical load data (which is .then input to the load analysis and. load model, the output of which is then input to both production cost data and reliabil-ity data).

j 9. Projected ~ availability, random outage rate and sched-i uled maintenance.

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10. Ilistorical availability, random outage rate and sched-uled maintenance (this is input only to the reliability l program).

11. Projected loads and generating requirements (generation l-models are used with regard to both production costing and reliability programs).

l- 12. Factors affecting current and future operating levels l

t of steam generator plants (including Palisades).

l 13. In-service dates and capacities for future. units. _

14. Environmental deratings and the like

15. Unit net demonstrated capabilitics.

16. Capability of. internal and external trancm'ssion.

i-1 Outputs for the production costing program include: l

1. Economic dispatch 2.._ Feel Costs a.- Unit-by-unit  !

b. Total i

I 1

! 3. Unit-by-Unit capacity factor L _

4. Luddington pumped st orage plant operation

5. Emergency purchase in-t-icgawatts, Meggawatt-hours and  !

dollars.

'6. Detroit Edicon' ,nonreplaccment-energy j 7.- Detroit, Edison - economy energy.

-8.- Fuel ose: coal'- tons oil - barrels

. gas : - - Mcf

• W

l Messrs.:Coufe Luebke and Leeds

• T January 27, lu/7 Page 5 Outputs for the reliability program include:

1. Days-required to purchase

-2.- Magnitude of required interconnection support

3. Frequency distribution of required support 4.- Cumulative distribution of required support

5. System average random outage rate

6. Hogawatt outage distribution.

7. Effect of second system.

8. Optimum maintenance schedule.

9. Positive to negative (P/N) days ratio.

2. Long-Term Load Forecast At least 18 persons contributed inputs to the long-term load forecast portions of Mr. Heins' testimony. The key assumptions utilized.in the forecast are listed at pages 1.1-36 to 1.1-19 of the Environmental Report Supplement filed by Licensee on October 26, 1976~, as anended by T.RS Arendn.ent No.'1, filed November 19,1976- (i.h'.sc pages arc attached to this letter for ease of reference). Fages 1.1-1.to 1.1-16 of the ERS, as. amended, '

discuss such related-matters as energy conservation, effect of price elasticity'and rate structure, which were considered.

Similarly, many persons provided input.on a variety of other matters covered in the tectimony, such as cccts due to a delay caused by~ suspension and costs of abandonment of

. Midland and proceeding:with an alternative.

Licensee is prepared to-provide witnesses to respond to questions.regarding alloof these1 matters when and if they are required ~at-the hearings. There is'no way of determining who is required, on what; point, or who,n they should appear until a question is: raised on cross-examination vhich relates to the

.' work of any given.cxpert. Licencoe~ believes-that it can_ generally-provide such witnessen on shcrt notice.cxcept in unusual circum-stances.. It would.cuggcst operating, as a general rulo,cn1 24-hours notice,;except in such circumstances when.a witness.is:

unavailable-due to~illncss, travel or the.like.. Licensee is prepared to attempt to; accommodate-the schedules of the1Doard

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=and the:other~partics;' including.the schedule of.Intervenors' s

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. -. ,. . ~ .- --. -

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dandkh2bh ~T PagcE6 -

consultant, Richard Timm. . If Intervenors will: advise Licensce l Lofxthe' specific' inputs'onLwhich'they wish to cross-examine, Licensee will> attempt-to make the appropriate witnesses.on such inputs-available on-mutually-convenient dates. It: can make witnesses available on the questions which the Board would like

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to, hear ~ addressed f,urther on'datos when Mr. Timm cannotLbe pre- '

'sent,7orrif Intervenors prefer, on dates when he is present._

.Licensectis also prepared, in light of the questions raisedfat the.last'hcaring by Intervenors and by the Board (see

.raquest of.Dr. Leeds at'Tr. 2040) _to' provide wi tnesses who will explain: . the nature of a load forecast and.how it is done, the

, . inputs'to it.and its outputs, the probability encoding analysis. -

and the. analysis done by Mr. Bikel in his confirmatory study.

-t It.isLprepared to; tender witnessen who can explain.the nature of a loss of load probability study and production costing runs,

- the methodology and inputs and outputt fer'such-rnalyses. It'is t also prepared to_ tender' witnesses who can provide similar infor-

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mation with regard to the developecnt of the costs of a delay due to suspension and;the costs of abandonnent of Midland and

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proceeding with an alternative.- Witnesses are available to

' testify with regardito the availability of' funds to finance j the Midland. project and the probability of Palisades operating in the future at its current megawatt rating,'qucetions which arose.at the-last hearing and which the Eoard indicated-it wished .;

- -to hear further on. .

P LLicensee pripared and submitted testimony.which it believes _ supports its' case that a suspension is not warranted.

As questions'are raised with regard to assumptions, analyses,

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' inputs, etc.',-~which went:into the preparation of the prepared

, testimony, nit must be. permitted to augment'its caso, just as-it wouldLbe permitted.to do.at a trial. The Board must remember

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.thatiatia" trial, a party' puts on one witncss at a time who.is'

= then. cross-examined and .that ac party is then free to submit'-

additional.witnessesEto' cover questions which arose on cross-examinationhoflany prior uitness.. Licenece cannot be foreclosed s '

Tfrom thatiright f herci simply" because it' provided Lthe testimony' of;therwitnenses itEoriginally intended to_ submit in written .

' form in, advance 1of the hearing.- 1 Licensee must be' (Tiven a full.

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4 3 opportunity toirespond..torsuch' questions:as.are raised ddring- -'

E 'the/ proceedings,7particularly Lin ' light of cthe 'naturez of these proceedings: ' the ccmplexity of the. matters presentcd ana-che

', fact that:no:one1 witness can belexpected t'o carry all of this, information'aroundiin his head. Intervenors cannot~be heard-g stolaskLaLqu'estion of-one witness,:have.the'_ witness _tell them 2

lthattithevinformation ;isoavailable from:.someone .else whom Licen-Tseelis ;willing;to produce--es 'aL witness,:;and then argue that they

.are'nothinte'ectedcin1 r hearing the_ response 7frcmTthe? additional ~

witnessf,fthat.;the? fact'thatLtheJfirst witne'ss could not:ansve

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a. t .-  ? .. , , [ a .3 4 sEE' , , , . . , . .r. c-.

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Mossrc. Coufal. Luebhc and Locdn '

January 27, 1 7 Page 7 is conclusive as to the lack of knowledge of the corporation ar a whole, that Licensee should be foreclosed from responding and that its construction permits should be suspended. Such a pro-cedure would be a clear denial of due process.

The consequences of a suspension in this case would be extraordinarily severe. The costs of such a delay, stated in Mr. Keeley's testimony, are astroncmical. The' Board has heard from Dow as to the potentia'l cffect of a suspension on that company. And it is aware of the need for the plant and the serious effects on Licensee if the, plant is delayed by a suspension. The Board cannot do as Intervenors request: sus-pend the construction permits without allowing Licensee to respond to questionc raiced on crocc-examination.

Finally, Licensee lists tl' ore matters which are before the Board for resolution at this time:

1. Licensec's motion to establish a firm schedule and procedures por its Motion and Memorandum of Decem-ber 13, 1976 and its letter of January 17, 1977.

2. Licensee's motion regarding the issues in these procedures por its Motion and Memorandum of January 13, 1977.

3. The propriety of the preparation of Mr. Temple's testimony.

4. Objections by Licensee and Staff to Interrogatories submitted by Intervenors.

5. Licensce's Motion to Certify the Board's ruling regarding privilege on ccrtain documents covered by the Briefs of December 30, 1976.

6. Other claims of Licensee regarding privilege relating to documents which the Ecard has reviewed (Licensee has not received a list of the Board's initial rulino on privilege, and the Board will recall that Licenscc requested an opportunity for argunent as to privilecc on these documents) .

7. Dow's motion to withdraw as a party.

8. Various Motions to Strike which the Board reserved ruling on in the transcript.

Respec ully st mitted, LuvAu v.

$6 dif0 EvSso One of the , torneys for Cons acrs Power Company

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SERVICE LIST '

Frederic J. Coufal, Esquire, Chairman Atomic Safety and Licensing Doard Panel 0" U.S. Nuclear Regulatory Commission Washington, D.C. 20555 f

' ,,f$

y T.- 1 Dr. Emmoth A. Luebke 4 Atomic Safety and Licensing Board Panel -

$ yh\ g/" -(

U.S. Nuclear Regulatory Commission )t2h .pe Washington, D.C. 20555 4 #

ty Dr. J. Venn Leeds, Jr., Esquire -o 10807 Atwell '

Houston, Texas 77096 Atomic Safety and Licensing Board Pancl U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 3r . C . R. Stephens /

Chief, Docketing and 9ervice Section Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Lawrence Brenner, Esquire Counsel for NRC Staff U.S. Nuclear Regulatory Coamission Washington, D.C. 20555 L. F. Nute, Esquire Legal Department Dow Chemical U.S.A.

Michigan Division Midland, Michigan 48640 Myron M. Cherry,. Esquire Suite 4501

.One IBM Plaza

Chicago, Illinois 60611

q $ $' ,

. , 49 == connESPO.NDMCE 4

< w of Michigan', vill in all likelihood cause it to take a cautious and moderate ap-proach toward such changes. Consequently, Concuc.crs Power believes that consump-tion patterns are very unlikely to deviate substantially from those currently pro-

jected and reflected in its forecasts for the period through the early 1980s.

Finally, on the basis of evidence currently available, Consumers Power believes that, even should such radical changes in rate design and price levels be insti-tuted, they would have a much less significant effect on customer demand at the time of system peak load than they would have on overaL. consumption levels.

1.1.1 Lead Characteristics 1.1.1.1 Load Analysis Historical peak load data and forecasted peak loads are listed in Table 1.1-1 for the years 1966 through 198h. Projected data over the cceplete life of the fa-cility are not available. Data are shown for Consumers Power alone, combined with Detroit Edison, and for ECAR. Table 1.1-2 lists historical and projected energy requirements for the same period. The projected data for Concusers Power and Detroit Edison are as shovn in the 1976 ECAR response (dated April 1976) to ,

FPC Docket R-362, Order 383-3, with adjustments to reflect : st recent fcrecasts.

Figure 1.1-1 shows Consumers Power's load duration curve for the year 1975 cur-

. rent peak demand and energy forecasts support the extension of this data to 1981 and 1982 conditions without significant modification.

1.1.1.2- Demand Projections

- The projections of peak de=and and energy requirements appearing in Tables 1.1-1 and 1.1-2 are based upon forecasted energy sales to custoners. Table 1.1-3 lists historical and projected sales to ulti= ate custeners for the period 1966 throuCh l 195k. -

Electric Sales Projections ~ 1 i

Consumers Power's electric sales forecasts are developed to cover three periods, each. done by class of-service, but each by a methodology and in a level of ' detail

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dictated by-their ulti= ate use. The budget year projection (developed in September- I of the previous year) is a conthly forecast based upon 'an in-depth analysis of conthly sales and Lincludes -local input frem the Company's geographical regions.

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The first. year beyond the ibudget year is an annual projection that is. developed-based upon the information and insiiht gained frcm the . budget year forecast. And \

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b thelong-tier = projection, beyond the second year cut, is developed based upon 11ong-term trends in the ecenc=y, population and energy use.

Each forecast is reviewed b'y the Cc=pany's. senior Management. It is the icng-te= forecast of sales which is of interest for_ the period'during which Midland is to be in ser--

vice.

Shova below- are the key assu=pticus upon which Concu=ers Pover's long-te sales forecast is based.

The infor=ation is given for each custc=er classifica-tien.'

I. Residential .

A. - The service _ area adult population projection is based on the State of Michigan report " Population Projections for the Counties of Michigan;"

October 197h.

The population is expected to grev at an annual rate-of about 1.6 percent even though zero net =i p atica is assumed.

3.

The ratio of adults per year-end custc=cr (adults per residenti:1 =2:er) .

b is expected to drop from about .179 in 1975 to about 1.70 by 1986 and' about 1,63 by 1990.

This is a =uch less precipitous drop than cecurred during the 1960s and reflects a slovdown in the pcvch of second hc=e3

.and adults living alene.

C.

Residential dc=estic average use is expected to grev at approxi=stely 2 percent per year through 1990 cc= pared with a'cout h percent annual growth during the-1960s.

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"'his reduced grovth rate reflects censervatten, price elasticity and the develop =ent and prc=otion of =cre efficient appliances.

D. ;

It:is assu=ed that the heat ^ pu=p vill be used 'cy about 10 percent of nev L

electrically heated hc=es by 1980 and that this' percentage vill increase -

to 30 jiercent Lby 1990.

The heat pu=p is accu =ed to havr a ceasonal per-femance factor of 1.6 (ie, :it

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, heating)'. is 1.6:ti=es as efficient as resi:tanca  ;

E.

'It is expected; that. shortages ofl alternate fuels vil1~. cause an in- .

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creasing saturation of. residential electric space heating. -

D ?F.? "Basedion- the' aheve -assu=ptiens,. total residential sales 'are expel

,-grov at.an annual rate of approxi=ately 3.2 percent thrcush 19861cc= pare vith'~~anlannualegrowth rate of'shgu f q iperiod.

? for' theil96k through 197k l g.

mELM%w.u.M i - - - - - - -

S

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-II. Commereial

The historicigrowth: rate of Consumers Power's commercial c1cetric sales is 9 percent.- Based on recent trends and subjective' analysis by Business Code, future: commercial l sales are projected to grow at a rate of.5.5 percent to

'6 percent-per year. ' The; reduced growth rate lis expected- because 'of con -

servation:and price elasticity:ard U5 belief that co==ercial lighting and

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,airxconditioning have reached a high saturation level. An offsetting. factor

'is:the potential for greater use of electricity for space heating and water heating asiother fuels become less- readily available.

III. Indu:: trial- 4 A. Sales'to General Motors Estimates of k"In sales to GM~ are based on a regression model using GM vehicle production and time as independent variables. Exhibit A shows this' model and the =odel used -to project sales excluding GM and Dev.

The current forecast .ssumes that GM vehicle production vill grow at a relatively slow rate in the- future and that total industry passenger- .(

car production vill not exceed the 1973 level of 9 7 =illion until-1981. It is assured that vehicle production vill increase at a de-creasing rate in the future, with total industry passenger car-produc-tion reaching approxicately 10.8 million by -1985,12.0 million by 1990,

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and 13.3 mil 1 ion by 1995. ~To reflect continued conservation by.the autc=akers, it'israssumed that fu;ure kWh celes to GM vill grov at the rate projected by the codel frcm a depressed 1976 starting point. This subjective adjustment-for censervation and price elasticity has the ef-

~ fect of reducing. future sales 9. acticn to GM accounts by about 10 per-

-cent below the. values pro'c Ji the codels.

3. : Sales to Dow Chc=ical - E 'a.-

Forecasted sales to Cow are based on dir.cussions between Consu=crs Power

and!Dov representatives.

'C. = Industrial Sales: Excluding GM and - Dow

.~ Sales to industrial custc=ers other tha'n GM and kV are forecast using the-FRB llanufacturing.Index.as the^ independent variable,~vith the results ,.

f - of th~e model te=peredz to reflect the .recent leveling off in the ratio, of. I l

+

sales of. electricity perTunit of FEB 'index. - This ' te=pering: also can be I

& inteB;rukt4 . x_ -

l>y * ~

m 2

4-

+

q. ,

1 D. . Total'-Industrial Sales -

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UsingltheLabove approaches and assumptions and:also analysis of. industrial sa. css-by; Business Code,' industrial sales-excluding Dov are projected to-

-grow at- a long-ters annual rate of approximately- 5 percent in the- future :

' compared with an annual- rate of about 7. percent for the -1960s and. earlyL 1970s.

IV. Other .

Strectlighting sales are projected 'to crov at a long-term rate of 3 percent!

per year. Interdepartmental sales are expected to remain fairly level, while sales to' other utilitics are expected to grov at a rate of about- 5 percent "

per year.

V. Total

!- -The above class-by-class projections result in a total forecasted sales 4

growth rate,for Consumers Power of approximately 5.2 percent per year after 1977 Enerry Recuire=ents and Peak Lead Projections-Consumers Pover's; peak lead: projections are developed from its sales forecuts. '

Sir e the sales forecasts r.easure energy requirencnts at the point of sale-ani energy. losses take place between the generation fr.cilities and the point of cale,

..the sales forecasts must be multiplied by an efficiency factor to determine the

, ' amountL of ' generation' necessary ;to meet the sales forecasts. The efficiency factor is. a' ratio ; o~f J 2te. te_ cenerati:n calculated cr. . .e basis of historical trc:..i.5,

. =odified ~to. reflect known or expected factors ~ that- vill-influence efficiency.

! Application of the'_ efficiency factor' results Lin an .esti ate of the . total cencra-

-tion requirement finikh"n necessary to =cet the annual sales forecast. The expected

~ peak load is calculated by dividing the average de=and (ie, the total generation require =ent divided by;the hours 'in the year) by ,;he esti::sted annual load f r.ctor

~ ~

i for the year. kThi annus1'1 cad factor is a ratio 'of average dc=and to peah iemand-

.iAnnualtlea.d factors are' developed from historical relationships.of load factors based 'on1 sum =er :=axi=uri dc= ands 1 and- vinter =aximu:a de= ands . In projecting future

[ load [ factor $,'conside'rationisgivenLtothezi=pactofsuchthings-as.energycon-

~

, - ,3 -

servation,jpricing offenergy~,f availability of sas Lvith the resultantLefrect on

-- -  ; thefuse o'ffelectricityifer heating,fload:! manage =ent' and generalf economic condi-

.. . .. . ~ .- .

tions b iSince ?sece forithese, factors; tend to :i= prove lead-~ factor and ' otherc Ltend -

.