ML19347E670
| ML19347E670 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/17/1981 |
| From: | Rasmey Robinson, Ryan B BETHLEHEM STEEL CORP., DECHERT, PRICE & RHOADS |
| To: | PENNSYLVANIA, COMMONWEALTH OF |
| Shared Package | |
| ML19347E637 | List:
|
| References | |
| C-80072105, C-80072106, R-80051196, R-80051196-C009, R-80051197, R-80051197-C014, NUDOCS 8105130205 | |
| Download: ML19347E670 (24) | |
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BEFORE THE j
PENNSYLVANIA PUBLIC UTILITY COMMISSION l
PENNSYLVANIA PUBLIC UTILITY COMMISSION and BETHLEHEM STEEL CORPORATION et al Docket Numbers v.
R-80051196 and R-80051196 C009 METROPOLITAN EDISON COMPANY R-80051197 and and PENNSYLVANIA ELECTRIC R-80051197 C014 COMPANY and METROPOLITAN EDISON COMPANY and PENNSYLVANIA ELECTRIC COMPANY v.
C-80072105 C-80072106 PENNSYLVANIA PUBLIC UTILITY COMMISSION BRIEF AND REQUESTS FOR FINDINGS OF FACT AND CONCLUSIONS OF BETHLEHEM STEEL CORPORATION OF COUNSEL:
Bernard A. Ryan, Jr.
l William L. Moyer DECHERT PRICE & RHOADS 800 North Third Street i
Harrisburg, PA 17102 Roger W. Robinson Michael J. Delaney Martin Tower Bethlehem, PA 18016 Attorneys for Bethlehem Steel Corporation 8105130h0S
-.-. A
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INDEX Statement of the Case 1
Questions Presented 3
Summary of the Argument 4
l Preliminary Observations 6
Argument 8
The Cost of Service Standard 8
The Cost of Service Evidence 10 Proposed Adjustments to Company Cost of Service Studies 14 Rate Design 19 Conclusion 22 Requests for Findings and Conclusions Following the Brief O
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Statement Of The Case These proceedings were initiated on July 29, 1960 by the contemporaneous filings by both Metropolitan Edison Company
(" Met Ed") and its sister corporation, Pennsylvania Electric Company ("Penelec"), of (i) requests for additional base rate revenues and (ii) complaints against the existing temporary rates being charged by both companies pursuant to the Order of the Commission dated May 23, 1980 at Docket I-79040308.
In their base rate filings Met Ed requested an increase in allowable revenues of $76.5 million while Penelec requested an increase of S67.4 million.
Met Ed O
simu1taneous1y f11 d a getition for extraordinary rate relief in the amount of $35 million but that petition was denied by the Commission in its Order dated August 28, 1980.
Following prehearing conferences and the filing of 4
memoranda by various parties on questions relating to the possible consolidation of these matters, the Administrative Law Judge on October 16, 1980 ruled that the base rate case and the complaints against tne temporary rates were to be consolidated "for hearing purposes only" for each of the companies.
W1an the hearing pnasc of these proceedings began in October of 1980, separate hearings were held for each company for several weeks, but thereafter joint hear-O ings were held to receive evidence with respect to the l
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issues in the general rate cases and the complaint cases for
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both companies.
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Bethlehem Steel Corporation (" Bethlehem") is an indus-trial customer of Met Ed taking service primarily under rate schedule TP at Bethlehem's Lebanon plant and an industrial customer of Penelec taking service primarily under rate schedule LP at Bethlehem's Johnstown plant.
Bethlehem filed complaints against the proposed base rate increases reques-ted by Met Ed and Penelec.
The Commission ordered an investigation of the Met Ed and Penelec general rate increase filings, and the tariff supplements incorporating those requests wer-automatically suspended under the provisions of the Public Utility Code.
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Bethlehem's complaints against those rate increase requests were tnen consolidated with the Commission's investigation.
Bethlehem was also treated as a party in the temporary rate complaint proceedings with which the general rate increase investigations were consolidated for hearing purposes.
Hearings on all of these matters were held between October of 1980 and January 23, 1981 when the record was closed.
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Ouestions Presented 1.
Should not any base rate increases ultimately granted to Met Ed and Penelec be allocated among'the various customer classes of those companies in accordance with the cost of service evidence of record in these proceedings?
2.
Should not the cost of service studies submitted by the utilities in these cases be corrected to reflect (i) the proper allocation of maintenance expenses for the transmis-sion plant and (ii) the inclusion of all revenues and associated expenses attributable to the energy adjustment clauses of both companies?
3.
Should net the rates for large industrial customers be designed to encourage rather than discourage high load factor operations by those customers?
O.
Summary of the Arcument The proper standard for. measuring the reasonableness of a utility's rates is the cost to serve its various customer classes.
Ideally a utility's tariffs should produce approx-imately equal rates of return from service to the various classes of customers.
Wr.er e discrepancies exist in such rates of return under existing rates, any revisions to the rates should move the returns from various classes closer towards rather than further away from the overall or system average rate of return.
The only cost of service evidence introduced in these proceedings supports the general approach taken by the two n
utilities in distributing the recuested rate increases among V.
their customer classes.
When the errors in the companies' studies are corrected as recommended by the expert witness for a number of the industrial complainants in his cost of service studies, it becomes evident that the general service customers of each utility are contributing at rates greater than the system average rates of return for the two compan-ies.
Accordingly, those customers should receive increases that are slightly below the average increases in revenues l
granted to the utilities so that the return on service to the general service customers would move closer to the system avera'ge rates of return for both companies.
' ate schedules for service to the largest indus-The r
O tri 1 cu tomer-or tae e oti11 tie-aoo1a de ae tenea to i
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recognize the nature of the. costs which occasioned the need for the rate increases and to encourage more efficient, higher load factor operations by those industrial customers'.
To do so, the increases in the demand component of the charges to those customers should be equal to or greater thar. the increases in the energy components.
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Preliminarv Observations Sethlehem has been an activo participant in the almost continuous proceedings before this Commission since the time d
of the accident at Three Mile Island in March of 1979.
Throughout those earlier proceedings and these current ones Bethlehem has frequently expressed its concern that the customers of these two utilities be assured of an adequate and reliable supply of electric service at reasonable rates during these difficult times for Metropolitan Edison Company and Pennsylvania Electric Compaay and their customers.
1 The Commission in its Order of May 23, 1980 concluded that Met Ed was to continue to operate as a public utility
~ iven the means to achieve its financial O
- and would be g
rehabilitation.
In that same Order the Commission also acknowleged the crucial nature of the timely return to service of Unit.1 at Three Mile Island in the program for the rehabilitation of that company.
In his testimony in these proceedings, Robert L.
Packard, Director of the Commission's Bureau of Rates, after noting that insolvency was not a solution to the problems confronted by Met Ed (Trial Staff Stmt. RLP-2, p. 4)',
stressed that the return of TMI Unit 1 to service is critical to the survival of Met Ed and he specifically urged that the Commission encourage the return of TMI-l to service (Trial Staff Stmt. RLP-2, pp.4,8).
O aeta1eae= coacur= ta the view ta t the e r1r retura to service of Unit 1 at Three Mile Island is crucial to the
O financial stability of the General Public Utility companies, and particularly Met Ed.
' Bethlehem also notes that the early reactivation of that facility offers the only prospect j
in the foreseeable future for relief from the burdensome purchased power costs which the customers of these two utilities must now bear.
Bethlehem has on numerous occasions in various forums publicly stated its interest in the return of Unit One to service at the earliest possible date consis-tent with public safety.
Bethlehem urges the Commission to redouble its efforts to encourage the responsible federal officials to expedite their proceedures for the relicensing h
of that facility so that it can soon begin to provide power for the customers of these two companies.
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m Argument During the hearing phase of these proceedings Bethlehem has focused its attention and its efforts primarily on the cost of service and rate design issues.
This brief is correspondingly focused on those issues.
A.
The Cost of Service Standard The most widely acknowledged standard by which the reasonableness of a utility's rates is measured is the cost of serving the various customer classes.
In his treatise, Princioles of Public Utility Rates (Columbia University Press, 1961), Professor James C.
Bonbright statee that one standard of reasonable rates can fairly be said to outrank all others in the importance attached to it by experts and by publiv opinion alike - the standard of cost of service..."
A utility's rates are generally considered to be fair and reasonable. to ;ts various customer classes when each class is charged on the basis of the costs incur-red in serving that class, including a fair rate of return which is approximately equal for all classes.
See also
- Welch, Cases and Text on Public Utility Regulation 250 (Public Utility Reports, Inc. 1968).
Fundamental fairness in rate making is not the only l
reason for the desirability of cost related rates.
Ignoring cost of service in rate' design can result in continued S
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O attrition of the earnine= of the ue111tv if ene ou tomer-whose rates far exceed the cost of serving them switch to other energy sources.
Ac those customers whose rate sch-edules produce rates of return well above the system average either greatly reduce or terminate their purchases of the utility service, the burden of meeting the utility's fixed costs falls increasingly on the remaining customers.
If the rate schedules applicable to those remaining customers do not provide a rate of return at least equal to the system average rate of return considering all rate schedules, the utility's earnings will decline below the intended rate of return, and each additional customer added to the low return rate schedules will add to the decline in earnings. In other words, the utility's fixed costs will have to be spread among the remaining smaller volume customers as the large volume users switch to other energy sources.
The accuracy of this principle was testified to by Bethlehem's expert, Mr. Drazen (Industrial Stmts. 1 (PN) and 1 (ME), pp. 3-4), and the concomitant rate design objective of enhancing revenue stability was acknowledged by Mr.
Carter, the cost of service and rate design witness for Met Ed and Penelec (tr. 1105), and by Mr. Japak, a Trial Staff witness on rate structure (Trial Staff Stmt.
WJ-1, p.2).
The result of a f ailu: e to track the cost of service in designing rates can thus be more frequent rate filings with substantial increases for smaller volume customers as the p) w utility attempts to collect the needed revenues from a diminishing number cf customers.
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B. The Cost of Service Evidence The only cost of service studies for the.various 1
customer classes of' Met Ed and Penelec which were entered into the record in these proceedings were -hose sponsored by Eugene Carter, the expert witness for Met Ed and Penelec on this subject, and those sponsored by Mark Drazen, an expetrt w'itness who testified for Bethlehem and a number of other industrial customers of the two utilities.
The Commission Trial Staff introduced rate structure testimony through its witnesses Walter Japak and Robert Rosenthal with respect-to certain specific matters of rate design, but neither of the Trial Staff witnesses offered any other cost of service studies.
In fact, while he criticized several aspects of the studies submitted by the utilities, Mr. Japak recom-mended that whatever level of increases the Commission decided to grant to Met Ed and Penelec, those increases should be allocated in similar proportions to those proposed by the utilities, thus accepting, for all intents and validity of the cost of service purposes, the general,
studies prepared by the companies.
The Consumer Advocate specifically declined to offer any testimony on the subject of rate structure.
Mr. Carter introduced a fully allocated cost of service study identified as Exhibit C-3 in each base rate case and testified that these studies ' wer e used extensively in i
O desienine the rates in the gregosed eariff suggiemenes (Mee Ed Stmt.
C, p.21 and Penelec Stmt.
C, p.21).
Although he 0,_
noted that the cost of service was not the only factor to be considered.in designing rates, he acknowledged that it was the dominant one, stating that in designing rates he would "... rely 80% on the cost of service with an additional 10% weighting to the value of service and 10% to continuity in rate making (tr. 1104).
Bethlehem's witness Mark Drazen generally agreed with the approach Mr. Carter said that he had used in designing the proposed rates, but Mr. Orazen added that value of service considerations"-(mentioned by Mr. Carter on p.21 of his prepared statements in each case, Met Ed Stmt. C and Penelec Stmt. C) should play little if any part in designing a utility's rates.
Mr. Drazen noted that "value of service" is simply a variant of monopolistic pricing (or "what the traffic will bear") which has no place in a rate settir.~
context (Industrial Stmts. 1(ME) and 1(PN) at pp. 4-5).
He also pointed out that since no one really knew the value of electric service to each of the various customer classes, it would be impossible to design rates that reflect those values (Industrial Stmts. 1 (ME) and 1 (PN), p.5).
On cross-examination Mr. Carter acknowledged that there were no studies he knew of which would establish what the values of electric service are to the dif ferent customer classes (tr.
1103).
Mr. Drazen also concurred with Mr. Carter's express-ed desire to bring the inter-and intra-class rates of ce-turn closer together in order to improve the equity of the rates (tr. 1150; Industrial Stmts. l(ME) and 1(PN) at p.
5).
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1 The results of the cost of service studies prepared by the companies for their proposed tariffs are set forth on pages 5 of 22 of their respective Exhibits C-3.
For both companies, these studies show that at the proposed rates j
the rate of return on service to the general service customers would be above the system average rates of return, while the returns on service to residential custcmers would be below the system averages.
Mark Drazen, however, testi-fled that certain adjustments should be made in the compan-ies' cost of service studies (principally to reflect the impact of the energy clause revenues and to correct an improper allocation of the maintenance experFes for the transmission plant *)
and that when those corrections are made, even greater disparities are revealed between the rates of return on service to residential compared to general service customers.
The results of the cost of service stucies prepared by Mr. Drazen including these recommended adjustments are set forth on Schedule 2 of Industrial Stat. 1(ME) with respect to Met Ed and on Sche-dule 3 of Industrial Stmt.1 (PN) with respect to Pennsyl-vania Electric Company.
The coroparable figures from the Met Ed, the Penelec Frnese recommended adjustments are described in detail in Section C below..
and the Drazen cost of service studies are as follows:
RATES OF RETURN Met Ed Penelec Customer Class Co. Study Drazen Study Co. Study Drazen Study Total Retail 10.700%
10.70%
10.540%
10.65%
(system average)
Residential class 9.369%
E.17%
9.614%
9.38%
General Service class 11.77%
11.94%
11.170%
11.55%
Largest Industrial class (TP)l0.934%
12.37%
10.223%
10.94% (LP)
Thus the only cost of service studies in evidence in these proceedings all indicate that the general service classes are contributing to the overall return of these two utilities at a much higher rate than O
are the residential classes, and those differences are even more pronounced when the corrections described by Mr. Drazen are taken into account.
The ultimate allocation of whatever base rate increases are authorized by the Commission should reflect these differences so that the return from both residential and general service customers will be moved closer towards the system average rate or return for each of these utilities.
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C.
Proposed Adjustments to Comoany Cost of Service Studies Mark Drazen suggested several adjustments that should be made to the cost of service studies as prepared by the companies in this case. The first of these adjustments relates to the allocation of the maintenance expenses for the transmission plant in those cost of service studies.
Although this Commission in a prior rate proceeding for Pennsylvania Electric Company (at Docket RID 392) ruled that operating and maintenance expenses for the tr. an smis sio n plant should be allocated on the same basis as the invest-ment in that plant, both utilities in this proceeding chose to allocate the maintenance expense on an energy basis rather than the demand basis used for allocating the plant investment (Exhibits C-3, pp. 8-10, lines 4-9; tr. 1144-45).
The operatians expensets for the transmission plant were properly allocated by the two companies on the demand basis but the maintenance expenses were incorrectly allocated on an energy basis.
This procedure in violation of the Commis-sion's earlier, ruling on this point involves an overstate-ment of expenses attributable to rate LP in the Penelec proceeding of approximately S100,000 and an over statement of expenses attributable to rate TP in the Met Ed case of approximately $33,000 (Industrial Stmts. 1(FN) and 1(ME) at p.6).
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The other, and much more sienificant, error in the methodology used by the companies in their studies r:lates 1A-
.to the treatment of the revenues (and the associated expen-ses) each company recognizes from its Energy Cest Rate (referred to as the " Energy Cost Adjustment clause" or "ECA" in Mr. Drazen's prepared testimony and hereafter un this brief). Neither Met Ed nor Penelec included the revenues earned under their ECA clauses or the associated fuel costs in their cost of service studies; these omissions tend to understar2 the actual rate of return realized by the two l
companies from service to their large industrial customers.
To understand the reason for Mr. Drazsn's proposal that these additional revenues and expenses be incorporated into the cost of service studies, one munt consider the operation O
of the ECA c1auses used er doth of these comganies.
zn neither clause is there any adjustment for the recognized lower energy costs involved with service to customers taking electric service at high voltage as compared to those who take their service at lower voltages.
The ECA clauses simply assume the same percentage losses in the transmission and distribution system for all customers, even though it is widely acknowledged that service to high voltage customers is more efficient (and hence less costly) than service to the lower voltage customers.
To deliver a kilowatt hour of energy to a customer at low voltage requires that a greater number of kilowatt hours be produced at the generation plant than are required to deliver a kilowatt hour of energy to a O
high voltage customer because of the greater losses on the.
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transmission and distribution system for service to low voltage customers.
See Industrial Stmts.1 (ME) an,d 1 (fN) at pp.
7-8.
Mr. Drazen in his testimony actually compared the revenues received under the ECA clauses from the large industrial customers of each ccmpany to the additional energy costs associated with those revenues and demonstrated that the failure of the ECA clauses to reflect -such ine losses overcharges rate TP customers of Met Ed by approxi-mately Sl.7 million and overcharges LP customers of Penelec by approximately S800,000.
See Schedule 1 attached to Industria2 Stmt.1 (ME) and Schedule 2 attached to Indus-trial Stmt. 1 (PN).
If the revenues and expenses associated with the ECA clauses were included in the cost of service studies, the overcharges resulting from the ECA clause would be reflected in the rates of return indicated for the variods customer classes.
The effect, of course, would be to show a higher rate of return on service to these industrial classes than is indicated on the studies offered by the companies as Exhibits C-3 in their base rate cases.
This procedure of incorporating ECA revenues and expenses in the cost of service studies was actually followed by Jersey Central Power and Light Company, the other GPU operating subsidiary, in the cost of service sttdies submitted by that company in recent rate proceedings in New Jersey (Indust:ial Stmt.1 (ME) at p.
8 and Industrial Stmt. 1 (PN) at p.9; tr.
r) 969-70).
Mr.
Drazen produced his own cost of service studies O
using the companies' studies as his base and following 1
the same' general methodology used by the companies but incorporating the several adjustments he recommended.
The chart in Section B above shows the results of Mr. Drazen's studies and compares them to the results under the compr7-les' own studies.
While no glaring discrepancies between the rates of return for the different classes of customers are revealed by that comparison, both the studies by the two companies and Mr. Drazen's studies (which, as noted above, are the only such studies in this record) establish that tne large industrial customers of both companies would be making significant contributions to the return of these companies under the proposed tariffs, contributions which are sub-stantially greater than those made ' by the residential customers of Met Ed and Penclec.
Taking all of these cost studies into account, one can only conclude that in allocating any allowed rate increase among the various customer classes, the residential class as a group should receive an increase somewhat greater than the average increase while the general service class should receive increases somewhat below the average increase.
In his prepared testimony in the Metropolitan Edison Company proceeding, Mr. Drazen suggested that the disribution of any revenue increase granted to Met Ed be based on a criterion that no class would deviate from the system average rate
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of return by more than 5%.
He went on to criticize that company's proposal under which the residential class would receive lower than average 9rcentage increases (which in l
turn vould produce a much lower than average rate of return) while an above average increase would be imposed on the general service class, thus moving the rate of return on service to the general service class even higher and further away from the average return for the company as a whole. See pages 8 and 9 of Mr. Drazen's prepared testimony, Industrial Stmt.1 (ME).
Schedule 3 attachtf to Mr. Drazen's testimony shows the proposed distribution of the increase requested by Met Ed in terms of the percentage increase compared to existing rates
- O and the resulting index of return under those proposed rates.
Schedule 4 attached to that statement shows the same figures using Mr. Drazen's proposed distribution of the requested increase.
Under the company proposal, the indices of return would vary from a low of 84.4 for the RS class to a high of 116.6 for the TP class while the range of those indices under Mr. Drazen's proposal would be from a low of 95.0 for the residential class (and general service class GSSH) to a high of 105 for GS, GP and TP customers.
If Met Ed is given less than the full amount of the increase it has requested, Mr. Drazen recommended that the dollar increases listed on his Schedule 4 be scaled back proportionally to
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produce the desired result.
Mr. Drazen's proposal for the allocation of any rate increase thus tends to move the-.
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rates of return from the various customer classes closer to the system average, consistently with the cost of service evidence in these proceedibgs.*
D.
Rate Design Mr. Drazen also offered two proposals with respect to the design of the rates established to produce whatever amount of additional base rate revenues are eventually awarded to these two utilities.
His first proposal was that the energy cost adjustment for these companies be modified to reflect the different line losses experienced in provid-ing service to customers at different voltage levels.
Such a
method of comp.cing the energy cost adjustment is not a new one and, in fact, is part of the energy adjustment O
c1ause for the other cPo overatine suesidiary. Jersey Central Power and Light Company.
Mr.
Drazen recommerided that the Commission direct both Met Ed and Penelec to incorporate such an adjustment in their energy clauses, and he attached to his prepared statements cop;es of the ECA clause in the Jersey Central Power and Light tariffs which includes such an adjustment since it could be used as a model for this purpose (Indu. trial Stmt. 1 (ME), Schedule 5 and Industrial Stmt. 1 (PN), Schedule 4).
- Ine company proposals for allocation of the rate increa-ses i~n the Penelec base rate case track the cost of service i
evidence considerably better than do the Met Ed proposals.
In that case Mr. Drazen simply suggested that the allocation t
l of the increase granted Penelec should give Rate LP an l k increase closer to the average percentage increase while giving the Lighting class a slightly higher percentage increase than that which the company proposed.
Industrial l
Stmt.1 (PN), pp. 9-10.
The other rate design proposal made by Mr. Drazen involved the structuring of the rates charged to the largest industrial customers of these two utilities.
On Schedule 5 of Industrial Stmt. 1 (PN) and Schedule 6 of Industrial Stat. 1 (ME), Mr. Drazen shows the comparison of the current and proposed rates LP (for Penelec) and TP (for Met Ed).
He then notes that the proposed rates provide for increa-sing the effective demand charge by only 6.9% while increa-sing the energy charges by 42.9% for on-peak use and 29.8%
for off-peak use for Penelec.
With respect to Met Ed, that company's proposed rates would actually decrease the effective demand charge by 6.9% while increasing its l
l energy charges by 89.8% for on-peak use and 38.9% for
'O off-geak use.
See Industria1 Semt. 1 (Pu), 9 11, and Industrial Stmt.1 (ME) p.10.
Observing that the bulk of the energy cost is fuel cost and that most of the fue] expense is recovered through the energy cost adjustment, Mr. Drazen concluded that the requirement for base rate increases for these companies is primarily the result of demand related
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Costs.
In order to track the costs which gave rise to the need for the. rate increase, the new, higher rates should be designed so that the demand component is increased more l
than the energy component.
The rate design witness for Met Ed and Penelec, Mr. Carter, also recognized the propriety of this concept in his direct testimony where he noted that O
in the two part denand/ energy rates most of the increase was placed in the demand charge..."
Penelec Stmt.
t 1 l'
C, p.9 and Met Ed Stmt.C, p.8.
Mr. Drazen pointed out, l
- however, that the evidence submitted by the utilities themselves actually shows that the energy charges in their proposed tariffs for large industrial customers are over-stated because both the off-peak and the on-peak r.nergy charges in r.hese propcsed tariffs are above the aversge cost of energy, while the demand charges are actually below the demand costs.
This type of rate design destroys the incen-tive for high load factor customers to continue operating in that manner and tends to subsidize the low load factor customers in the same rate class.
See Industrial Stmt. 1 (PN), p.12 and Industrial Stmt. 1 (ME), p.ll.
Mr. Drazen submitted specific proposals for the design i
of Rates TP and GP for Met Ed (Schedule 7 and Schedule 9 respectively, attached to Industrial Stmt. 1.(ME)) and for Rate LP for Penelec (Schedule 6 attached to Industrial Stmt.
1A (PN)).
Copies of those recommended rates are attached to the r?;uests for findings and conclusions which follow this brief.
These recommended rates reflect slightly higher i
demand charges and slightly lower energy charges than the corresponding company proposals so that the new rates will not penalize the high load factor customers while rewarding the lower load factor customers, as the proposed rate schedules of the two companies would.
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- O Conc 1usion For the reasons set forth in this brief, the Commission should direct Metropolitan Edison Company and Pennsylvania Electric Company to allocate any increases they are granted in base rate revenues among their various customer classes in a manner consistent with - the corrected cost of service studies in the record for these proceedings.
The design of new rates for the industrial customers of.each company to collect the allowed revenue increases should increase the demand component of the charges as much as or more than the energy component so as to encourage those customers to operate at the more efficient high load factors.
O Reerectfu111 >uemitted.
Bernard A.
Ryan, Jr.
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OF COUNSEL:
William L. Moyer 800 North Third Street DECHERT PRICE & RHOADS Harrisburg, PA 17102 Roger W. Robinson Michael J.
Delaney Martin Tower Bethlehem, PA 18016 Attorneys for Bethlehem i
Steel Corporation 1
February 17, 1981 l
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