ML19347E686
| ML19347E686 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/17/1981 |
| From: | Rasmey Robinson, Ryan B BETHLEHEM STEEL CORP., DECHERT, PRICE & RHOADS |
| To: | |
| Shared Package | |
| ML19347E637 | List:
|
| References | |
| C-80072105, C-80072106, R-80051196, R-80051196-C009, R-80051197, R-80051197-C014, NUDOCS 8105130224 | |
| Download: ML19347E686 (11) | |
Text
.
O BEFORE THE t
PENNSYLVANIA PUBLIC UTILITY COMMISSION PENNSYLVANIA PUBLIC UTILITY COMMISSION and BETHLEHEM STEEL CORPORATION et a.1 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 BETHLEHEM STEEL CORPORATION'S REQUESTS FOR FINDINGS OF FACT AND CONCLUSIONS Bethlehem Steel Corporation films the following re-quests for:
Findings of Fact 1.
Metropolitan Ed.ison Company (" Met Ed") and Pennsyl-vania Electric Company ("Penelec") are each public utilities providing electric service to the public for compensation in designated areas in Pennsylvania.
2.
Bethlehem Steel Corporation
(" Bethlehem")
is an industrial customer of Met Ed taking service primarily under rate schedule TP at Bethlehem's Lebanon plant and an indus-t trial customer of Penelec taking service primarily under rate schedule LP at Bethlehem's Johnstown plant (Bethlehem complaints and the answers of Met Ed and Penelec thereto).
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IMAGE EVALUATION NNNN TEST TARGET (MI-3)
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3.
Both Met Ed and Penelec submitted fully allocated d
cost of service studies for the proposed new rates (Met Ed and Penelec Exhibits C-3).
Those studies were used in allocating the proposed rate increases among the customer classes of Met Ed and Penelec and in designing the rate schedules to produce the higher revenues requested in their respective base rate filings (Met Ed and Penelec Stmts.
C, pp. 17-21).
4.
The cost of service studies offered into evidence by Met Ed and Penelec allocate the maintenance expenses for the transmission plant on an. energy basis rather than the demand basis on which the investment in that plant was allocated (Exnibits C-3, pp. 8 and 10 for Met Ed and Pene-0 1ec>
tr. 1144-45) nd do not inc1=de enerer dsusement clause revenues and associated expenses, thus understating the rates of return on service to the large industrial customers of both utilities (Industrial Stmts. 1 (ME) and 1 (PN) at pp. 6-9; tr. 969-70).
5.
The cost of service studies offered by Met.Ed and Penelec show that at the proposed rates the rate of
_ return to be earned on service to general service customers is above the system average rate of return for both utili-ties while the rate of return to be earned on service to the residential class customers is below the system average (Met Ed and Penelec Exhibits C-3, p. 5 of 22).
6.
The only other cost of service studies offered O
into evidence in these proceedings were those submitted by Mark Drazen, an expert witness who testified on behalf,
O of a number of industrial complainants, including Bethlehem.
Those studies correctly allocated transmission plant main-tenance expense on a demand basis, give somewhat greater weight to winter demands in the Penelec study and include revenues and expenses from the energy adjustment clauses of Met Ed and Penelec (Industrial Stmts. 1 (ME) and 1 (PN) at pp. 5-9).
Those cost of service studies indicate that the rates of return to be earned on service to the general service class as a whole and to the largest industrial customers in particular (on schedules TP for Met Ed and LP l
for Penelec) are above the system average rates of return for the two utilities and considerably above the rates of I
return on service to their respective residential classes (Industrial Stmt. 1 (ME), Schedule 2 and Industrial Stmt. 1 (PN), Schedule 3).
7.
Neither Met Ed nor Penelec include any correction in their respective energy cost rates for the widely recog-nized greater energy costs involved in serving lower voltage customers compared to serving higher voltage customers (Industrial Stmts.
1 (ME) and 1 (PN) at pp. 9-10; tr.
1160).
8.
The design of rates TP (for Met Ed) and LP (for Penelec) as proposed by Met Ed and Penelec place the greater part of the proposed increases on the. energy components rather than the demand components of. those rate schedules lO even thoueh increased enerer costs are recovered ehroueh the energy adjustment clauses of both utilities (Industrial
/
Stmts. 1 (ME) and 1 (PN) at pp. 10-13). -
O O
e.
The gregesed desien of retes TP and cP for Met Ed and rate LP for Penelec recommended by Mark Drazen, as set forth on Schedules 7 and 9 attached to Industrial Stat. 1 (ME) and Schedule 6 attached to Industrial S ta t. -
1A (PN), copies of which are attached to these Requests for Findings, aligns the demand and energy components of those rates more closely with the associated costs while avoiding excessive impacts on the lower load factor customers served under those rate schedules (Industrial Stmt. 1 (ME),
- p. 12).
Conclusions 1.
The allocation of any base rate increases granted to Met Ed and Penelec in these proceedings should be made in a manner which is consistent with the cost of service studies in this record, and the cost of service studies offered by Mark Drazen on behalf of a number of industrial complainants are the proper ones to be used for this pur-pose.
2.
The Energy Cost Rate clauses for both Met Ed and Penelee should be modified to include an adjustment for the greater losses experienced in serving low voltage customers, in the manner provided in the tariff of their sister com-pany, Jersey Central Power & Light Company, 3.
The design of the rate schedules for the large industrial customers of Met Ed and Penelec should place O -
O equal or greater increases in the demand components as in the energy components of those rate schedules in the manner proposed by Mr. Drazen.
=x Bernard A.
Ryan, Jr.
OF COUNSEL:
William L. Moyer r
800 North Third' Street DECHERT PRICE & RHOADS Harrisburg, PA 17102 Roger W. Robinson Michael J. Delaney Martin Tower Bethlehem, PA 18016 Attorneys for Bethlehem Steel Corporation l
l l
l O
9. -
t Sch dulo 6 l,
Pc9e 1 cf 2 l
O PENNSLYVANIA ELECTRIC COMPANY c
Reconnended Rate LP Line Description Rate
$600.00 1
Customer 2
Demand, per kW 6.18 3
Reactive demand, per rkVA
.275 4 1 CurtallaBle*creditf per.-kW 2.60 Energy, per kWh 5
On peak
.0195-6 off-peak
.0155 i
O-I e
9
ca...u.6
...we g
p-
.' Sch2dulo 6 Pcg3 2 of 2 PENNSLYVANIA ELECTRIC COMPANY Proof of Revenue - Reconrnended-Rate LP Billing Line Description Units Rate Amount (1)
(2)
(3)
I customer 647
$600.00 388,200 2
' Demand - kW 6,223,440 6.18 39,460,859 3
Reactive demand - rkVA 4,o88,683
.275 1,124.388 O
Energy 4
on-peak kWh 1,189,525,586
.. 95 23,195.749 5
off peak.kWh 1,798.643,593..
.u155
-- 27,878,976.-
6 To ta l!.....
2,988,,1.69,179.I...G 51,074,725.-i.'-
7
- curtallable credit.- kv- '
83,604i - $ (2.60)'
(217,370) 8 Total
$90.830,524 l
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Exh'Ibit MMD-1 (
)
2 Schedule 7 Ptg2 1 of 2 O
METROPOLITAN EDISON COMPANY Recommended Rate TP j
Based on $6,313.000 increase Effective Present Proposed increase Line Description Rate Rate Amount Percent
)
(1)
(2)
(3)
(4) 1 l
$700.00
$700.00 1
Customer charge O
2 o
- e =" re-53 75
$
- 72 5
95 25 52 Energy charge 3
On peak 1.08e 1.68e
.60e 4
Off peak 1.08c 1.13e
.05c 5
Average 1.0Bc 1 37c*
.29c 26.9%
- Veighted average using on peak and of f peak usage.
m
\\
m Exhibit MtiD-1 (
)
Schedule 7 Page 2 of 2 METROPOLITAN EDISON COMPANY Proof of Revenue For Rate TP 81111ng Line Description Units Rate Amount (1)
(2)
(3) 1 Customer 228
$700.oC S
159,600 2
Demand 2,610,688 4.72 12,322,447 Energy 3
On peak 546,465,848
.0168 9,180,626 4
off peak 737,221,838
.0113
_ 8,330,607 5
Total revenues
$29.993,280 6
Revenues at present rates 23,663,671 7
increase S 6,329,609 r
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l Exhibit MHD-1 (
)
8
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Sch2dule 9 Pcg2 1 of 2 O
METROPOLITAN EDISON COMPANY
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l EOCOM hE Comparison of Present Rate LP wi th Cc r'-" g1C#
(2)
(3)
(4)
Load Factors from 3h% to 62%*
$75.00
$ 75.00 1
Customer charge, per mo.
2 Demand charge, per kW
$4.235
$ 5.84
$ t.605 37 9 %
Energy charges, per kWh L, 3 on-peak 1.39c 1.97c 0.58 e 41.7 %
i s
4 off-peak 1 39c 1 37c (0.02)e
( 1.4):
Load Factors Above 62%**
575.00
$ 75.00 5
Customer charge, per mo.
(
6 Demand (harge, per kW
$ 5 09
$ 5.84
$ 0.75 14.7 %
Energy charges, per kWh 7
on peak 1,20c 1 97c 0.77c 64.2 %
8 off-peak 1.20e 1 37c 1 37c 14.2 %
- Between 250 kWh/kV and 450 kWh/kW.
- Above 450 kWh/kW.
O
s.
O CEPTIFICATE OF SERVICE I certify that I have today served copies of the attached Brief and Requests for Findings of Fact and Conclusions of Bethlehem Steel Corporation on all active part.ies of record in these proceedings by first class mail, postage prepaid, at the addresses indicated on their respective pleadings in these matters.
Dated:
February 17, 1981.
I A
Bernard A.
Ry an, J r.
^
Attorney for Bethlehism S eel Corporation
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