ML20031E996
| ML20031E996 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/13/1981 |
| From: | Fullenbaum H FLORIDA POWER & LIGHT CO., NATIONAL ECONOMIC RESEARCH ASSOCIATES, INC. |
| To: | |
| Shared Package | |
| ML20031E995 | List: |
| References | |
| ISSUANCES-A, NUDOCS 8110190007 | |
| Download: ML20031E996 (25) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICEMSING BOARD In the Matter of
)
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FLORIDA POWER & LIGHT COMPANY
)
Docket No. 50-389A (St. Lucie Plant, Unit No. 2)
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AFFIDAVIT OF M. FULLENBAUM (October 13, 1981)
My name is Martin S.
Fullenbaum.
My business address is 1800 M Street, N.W.,
Washington, D.C. 20036.
I am a Senior Economic Analyst with National Economic Research Associates, Inc.,
(N.E.R.A.) a group of consulting economists kith principal offices in New York City, Washington, D.C.,
Los Angeles, California, Philadelphia, Pennsylvania, and Palm Beach, Florida.
I hold a Bachelor (Univ. of Pa.) and Doctor's Degrees in Physics (Univ. of Md.) and an M.B.A. Degree in Finance and Fconomics from Lehigh University.
Before coming to N.E.R.A.
I was employed by Gilbert Associates, Inc. in Reading, Pennsylvania where I specialized in electrical utility rate studies and have submitted testimony r-lated to those studies to the Federal Energy Regulatory Cummission.
My research assignment was to determine the extent to which municipal electric utilities served at wholesale by investor-owned utilities are located outside the general service territory of the supplier.
For this purpose, I defined service N
8110190007 811013 PDR ADOCK 05000389 M
PDR territory to include the geographic area served at retail by and investor-owned utility.
Municipals separated from their supplier only by a cooperative also were considered within the supplier's service territory, since as a general matter, cooperatives are not legally permitted to provide service to municipal utilities.
Because of the limited time available, I concentrated on the 20 largest investor-owned systems.
The 20 largest systems were determined on the basis of each system's 1979 annual season peak, as reported in the August 1980 issue of Electric Light and Power and included 40 operating companies, eight of which are located in the same Southeastern Electric Reliability Council area as is Florida Power and Light Company.
In total, these systems accounted for 227,626 megawatts of generating capacity in 1979, 49.0 percent of the total for investor-owned systems.
In 1979, these 20 systems served 243 municipal utilities at wholesale.
Attachment A lists the systems and their operating utilities.
My research made use of published data supplemented by telephone contacts.
Wholesale municipal utilities served by the 40 operating utilities in the sample were identified using each firm's Annual Report
'.o the Federal Energy Regulatory Com-mission, Form No. 1.
Next, the county in which each municipality is located was determined.
Finally, using-the Electrical World
. map of electric utility service territories, I determined whether municipal utilities were within or adjacent to their supplier's service territory.
Where there existed any doubt about a municipality's location, I contacted rate personnel at the supplying utility.
I also contacted utilities to as-certain the circums'inces surrounding wholesale sales made to extra-territorial municipal systems.
Of the 243 wholesale municipal systems considered, only one clearly was located wholly within the service territory of another investor-owned system.
In two other instances, extra-territorial municipal sales were made under more nebulous cir-cumstances.
A clear instance of an extra-territorial sale involves the City of Bowie, Texas, a wholesale customer of Texas Electric Service Company (TES) for more than 30 years.
Bowie became a customer because of the close proximity of TES's transmission system.
When the City's generating station had an unexpected outage, TES provided emergency service.
Finding wholesale power less expensive than self-generation, the City continued to take wholesale power.
A more uncertain situation involves the City of South Haven, Michigan, a wholesale customer of Indiana & Michigan Electric Company (I&M) for more than 20 years which is located no more than two miles from I&M's territory.
It is not at all clear whether I&M's or Consumers Power's facilities were closer to w-N -
3.,-
South Haven when service was initiated.
Company personnel were unable to state the circumstances under which service to South Haven was begun.
Finally, we have identified a sale made by Detroit Edison to the Michigan Municipal and Cooperative Power Pool, a group of municipalities and cooperatives which was initiated in 1975.
However, based on my examination of the municipal members' Form 12's for 1979, those municipals who are members of the pool and are located outside Detroit Edison's service arca did not purchase any power from Detroit Edison.
In sum, based upon this sample which covers utilities owning half of the investor-owned sector's total capacity and which I therefore consider to be representative, it seems clear that the general practice in the electric utility industry is that wholesale service purchased by municipal systems is provided by electric utilities serving in adjacent areas.
Based upon my research, I found only two municipals, or slightly less than 1 percent of the 243 total municipals, that were clearly served by wholesale suppliers who did not serve the adjacent area at retail.
In each of those instances, the wholesale supplier's transmission facilities were connected directly with the facilities of the wholesale customer.
Further affiant sayeth not.
NA.
/
I.. I b.t(aa..1 Martin S.
Fullenbaum Subscribed and sworn to before me this 13th day of October, 1981.
g) g id
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,- Notary Public
'f' [ District of Columbia Na D CW a: IC ; *p.;
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t Attachm'ent A Paga 1 cf 2 4
MAJOR ELECTP,1C UT11JTY SYSTEMS USED IN THE ANALYSIS 1979 Data
\\
Season Company Operating Company Peak (mW)
(1)
(2)
Southern Company Alabama Power Company Georgia Power Company Gulf Power Company Mississippi Power Company 18,015 American Electric Power Company Appalschian Power Company Indiana & Michigan Electric Company Kentucky Power Company Ohio Power Company Columbus & Southern Ohio Electric Company Michigan Power Company Wheeling Electric Company 17,793 Commonwealth Edison Company 13,804 Pacific Gas & Electric Company 13,215 Southern California Edison Company 12,464 Texas Utilities Company Dallas Power & Light Company Texas Power & Light Company Texas Electric Service Company 11,202 Middle South Utilities,Inc.
Mississippi Power & Light Company Louisiana Power & Light Company New Orleans Public Service, Inc.
Arkansas Power & Light Company Arkansas-Missouri Power Company 10,687 Duke Power Company 9,844 Houston Lighting & Power Company 9,602 Plorida Power & Light Company 8,791 n/e/r/a
Att chm:nt A Paga 2 cf 2 i
MAJOR ELECTRIC UTILITY SYSTEMS USED IN THE ANALYSIS 1979 Data Season Company Operating Company Peak (mW)
(1)
(2)
Virginia Electric & Power Company 7,929 Central & South West Corp.
Central Power & Light Company Public Service Company of Oklahoma Southwestern Electric Power Company West Texas Utilities Company 7,838 Detroit Edison Company 6,829 Public Service Electric and Gas Company 6,736 Consolidated Edison Company of New York, Inc.
6,702 General Public Utilities Metropolitan Edison Company Pennsylvania Electric Company Jersey Central Power & Light Company 6.173 Carolina Power & Light Company 5,907 Niagara Mohawk Power Corporation 5,641 Philadelphia Electric Company 5,641 Union Electric Company 5,557 Source:
Col. (1): Electrical World, Directory of Electric Utilities (New York, N.Y.: McGraw-Hill Publications Co.) 1980-1981 edition.
col (2): "The Top 100 Electric Utilities' 1979 Operating Performance,"
Electric Light and Power, Vol. 58, No. 8, August 1980, p.13.
n/e/r/a 1
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APPENDIX C i
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l' APPENDIX C i'
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UNITED STATES DISTRICT COURT OF THE S CU T*iE RN DISTRICT OF FLORIDA
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i D9 Case No. 79-5101-Civ-JLK 3,
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THE CITY OF GAINESVILLE AND THE GAINESVILLE-
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- i ALACHUA COUNTY REGIONAL UTILITIES 2OARD, THE
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l 5 ? LAKE WORTH UTILITIES AUTHORITY, THE UTILITIES
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COMMISSION OF NEW SMYRNA BEACH, THE SEERING
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l 6
UTILITIES COMMISSION, THE CITIES OF ALACHUA,
,; BARTOW, FT. MEADE, HOMESTEAD, KISSIMMEE,
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j MOUNT DORA, NEW3ERRY, ST. CLOUD, STARRE and
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TALLAHASSEE, FLORIDA,
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j s4
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j Plaintiffs,
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j 9i
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10.
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FLORIDA POWER AND LIGHT, i
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De fendant.
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I 13 l 3
s 14 Southeaat 15 National Bank Blc9 Miami, Florida 15!
Thursday,._pril 30, 1951 j
9:15 o' clock a.m.
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17 i' DEPOSITION OF GEORGE KINSMAN I
IS i
.i 19 ! Taken be fore MARTIN B.
LESHAW, Of ficial Court Reporter and i
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i 20 l Notary Public in and for the State of Florida at Large, 21 ? pursuant tc Notice of Taking Depositior. filed in the above ;
22 stylad cause.
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24!
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- j NEW YCRx NATIONAL REPORTING SERVICE t o CC.kT 4*.
MARTY LE5 HAW mt OFFIC.A COURT A E 7 0 4 TE.4
"'Q 2123
- ft 4 2442
- 3 3;.7235 4
CR C UIT C C b stT OF THE 1,
- se JUDIC:A'.
- 3. 4 ':G'T. DACE OCUNTY F *. A.
9 e
Kinsman Deposition 55 APPENDIX C i
i 1
the three cenp an ie s, and we talked to the varicus i
?
l d.
2 imanufacturers, and t!.ey gave varicu, e w.osalc.
The were trying to beat the doors dcun te sell us!
3 ;! manufacturers l
!l reactors.
We were trying to find out which was the best.
4 i'
l' q
5' Q
Mr. Roland, Mr. Walch and ycurscif would r
6 attend mectings?
I A
Probably.
Generally all three of us
- g 1
3 covered the meetings.
l f
i' O
Did you all see the same manufacturers at 9 :n 9
10 ' the same time, or did one manufacturer come to 71erida i
j
- 11. Power & Light?
6
.I i
12 A
Both.
I don't remember 37.e ci fic mee tings 1
13 i with the manuf ceture rs, with just the three of us.
Ther i
.1...*
14 {swas a great deal of sales work going on by the.T.anuf acture rs tl e
il i
15 t, during that period.
Our job was just to keep our ohjectivec I
t 16 !! fo rme d, and what is new.
1 1
17 j Q
If a manuf t eturer came to Florida Powar L i
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t la i Light, would you share that information?
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19 i A
Yes.
i 20 Q
Who did you share it with?
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21 A
The in formatio n, besides the other s tuf f, 22 f was a manufacture r trying to sell us a piece o f equipment.
I; 23 i.l If they called on us, I would make sure they called on
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24 !! them, too.
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25 'j Q
Would you make sure they called on Orlando?
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is ceust sr.
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C:se c u t? : Dust CF Ti4 t 11Tu.UDICI A L CIM OUl*.
D. "t E OC.: **
- 4
Kincm:n Dsposition _,
APPENDIX C r
res.
1 2-Q What about Jainesville?
3 A
I don't knew.
1 G
Tallahassee?
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i..
l 5
A As far as I know, nonc of th2: war 2 i
6 intcrested in nuclear powe71.
t 7
O What about Fort Pierce?
j i
6 A
I don't suspect they were intorested.
I
.i didn't know they were.
I didn't know they were, if they j
9 10 Vere interested.
i 11 hR. GUTTMAN:
I will offer this as Plaintiffs' 12. Exhibit 19 for Identification, c document dated February 1,I li 13 l1962, inter-office memo stationery, to Mr.
P.. H.
- Fite, 14 :. regarding the Atomic Power Conmittee meeting in St.
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15 :; Petersburg.
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16 !
(Thereupon, the document r e fe rre d i
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17 to was marked as Plaintiffs' l
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Exhibit No. 18 for Identification.)
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19 it O
(By Mr. Guttman)
Can you tell me if you 20 recall that document, after you have had a chance to read i
t-21 h it?
I 22,
A Very well.
23h Q
Did you indeed write this?
i i
i 24 ;
A Yes.
i es it
.,.f 25 [
Q Do you generally recall the events?
l' new yea:<
NATIONAL REPORTING SERVICE is cou=: sr.
.1 ARTY LE5HN.*/
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ua u ta 57-orricini. Coua? 3cronten ain t'i::u:
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3,3.,33 CIRCUlf CCUR" or THE ll's JWQ40sA. C*M CV!T. DAOC O C 'J NTY. r;,/..
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APPENDIX y
APPENDIX D UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA The Fort Pierce Utilities Authority
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of the City of Fort Pierce, the City )
of Gainesville and the Gainesville-
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Alachua County Regional Utilities
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Board, tha Lake Worth Utilities
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Authority, the Utilities commission
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of New Smyrna Beach, the Sebring
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Utilities Commission, and the Cities )
of Alachua, Bartow, Fort Meade,
)
Homestead, Kissimmee, Mount Dora,
)
Newberry, St. Cloud, Starke, and
) Civil Action No.
Tallahassee, Florida,
)
) 79-5101-Civ-JLK Plaintiffs,
)
)
v.
)
)-
Florida Power and Light Company,
)
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Defendant.
)
DEPOSITION OF EVERETT B. HOWE Taken in the above-styled cause, at City Hall in Fort Meade, Florida, on the 17th and 18th of September, 1980.
Reported by:
M.
Kim Odom, CVR VOLUME II OF II
(
Southern Reporting Servlees 219 South Calhoun Street F.o. sex eos TaMahassee. Florida 333o3 (904) nas.6oes I
hows Deposition 131 i
APPENDIX D 1
,.,Q When did you first become aware that R..W. Beck and 2
Associates had suggested that it would be feasible and per-3 haps desirable for the Twelve Cities, either by themselves 4
or acting with some other cities in Florida to pnymed with 5
the power pool?
6 A
I need about a one-minute conference.
7 0
Mr. Ilowe, before you take a break, I think it 8
is fair to say that I'm going to ask you the omitant of the 9
conference when you come back.
10 Whereupon a short recess was held off-the-record.
11 A
Okay proceed.
There's a question pending.
12 13 Q
My question, I can paraphrase it for you.
My 14 question when did you first become aware that R.
W. Beck had proposed to the Twelve City Group that it would be a good 15 idea for the Twelve Cities, either acting by themselves or 16 17 acting with some other cities in. Florida to pursue a power g
j 18 pool?
19 A
I don't recall specifically, but St. Cloud was also a member of the Ten-Twelve City Groups, and I recall j
20 a
discussing in the interim, when the cities vere in a law-
~h 21 a
suit with Florida Power Corporation and R. W.
Beck and d
22 s
Associates were also the consultants a.t that time, and I f
23 don't know whether that's the first time he came up or not.
24 25
Howa Deposition 132 APPENDIX D
(
1 That power pooling was--- Between the time that I was City 2
Manager for St. Cloud, you see, there's abcut a 2 year 3
elapse time in which I was in Georgia, then came back here, 4
this city, again and was tied back into Central Florida 5
Municipal Electric.
I'm trying to be honest, this is what 6
I'm trying to recall.
That's the best I can do.
7 Q
Have you 4".ne anything since 1971 to try to make 8
this city pool come into being?
9 A
I can't recall any specific action.
10 Mr. Jablon:
Does that complete your answer?
11 Whereupon a short recess was taken.
12 0
Mr. Ilowe, let me show you another piece of paper 13 which I'll ask the Reporter to mark as HOWE Exhibit 17.
14 Whereupon HOWE Exhibit 17 was marked for identification 15 by the Reporter.
16 0
The second page of this, Mr. Howe, entitled, 17
" Minutes, Meeting of the Twelve City Public Power Committee, g
18 Robert Myer Hotel, Orlando, Florida, September 10, 1968.
19 Mr. Ilowe, it shaas that you attended this thing as a visitor, j
20 and that you were then the City Manager of the City of St.
21 Cloud, and it says just below that, " Chairman Shreve noted l3 22 that a quorum was present - eight of the twelve members."
S 23 The eight (8) members, appear to be the eight (8) cities 24 above where the visitors listed.
Is it true that St. Cloud 25 was not a member of the Twelve City Group in 1968?
1.
O e
F APPENDIX E f
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APPENDIX E IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA.
(
THE CITY OF GAINESVIL'LE AND
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THE GAINESVILLE-ALACHUA COUNTY
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REGIONAL UTILITIES BOARD, THE
)
LAKE WORTH UTILITIES AUTHORITY,
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THE UTILITIES COMMISSION OF
)
NEW SMYRNA SEACH, THE SEBRING
)
UTILITIES COMMISSION AND THE
)
CITIES Of ALACHUA, BARTOW,
)
FORT MEADE, HOMESTEAD, KISSIMMEE.)
CIVll ACTION N0.
MOUNT DORA, NEWBERRY, ST. CLOUD, )
79-5101-CIV-JLK STARKE, and TALLAHASSEE, FLORIDA.)
)
2E- -
Plaintiffs.)
)
)
vs.
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FLORIDA POWER & LIGHT COMPANY,
)
)
Defendant.)
)
THE DEPOSITION OF:
J0E B.
DYKES VOLUME I,
PAGES 1 THROUGH 87 TAKEN AT INSTANCE OF:
THE DEFENDANT DATE:
WEDNESDAY, JULY 30, 1980 TIME:
COMMENCED:
10:05 A.M.
CONCLUDED:
4:55 P.M.
LOCATION:
LAW 0FFICES 305 SOUTH GADSDEN STREET TALLAHASSEE, FLORIDA AS REPORTED BY:
B.
J.
EBERHARD CERTIFIED COURT REPORTER REGISTERED PROFESSIONAL REP 0RTER CERTIFICATE OF PROFICIENCY NOTARY PUBLIC IIABERMHAW dE, EBERHARD COURT REPORTING MERVICM B.J.EBERHARD MUE M. II AHERMII AW (904) 222-4964 (p04) 886-8380
Dykes Deposition APPENDIX E 56.
Q Do you recall this paper (indicating)?
A Maybe vaguely.
I don't know that I've been 2
1 3
through all the ramifications in it, no.
I probably listened 4
to his presentation.
5 Q
Take a look at page ten, if you would, which has 6
in the lower right-hand corner the number 316494.
And if 7
you would, take a look at the second full paragraph.
g A
It starts, "To be perfectly frank..."?
Q Yes, sir.
If you'd read the fi rst two sentences to of that paragraph out loud, I'd appreciate it.
11 A
"To be perfectly frank, up until 12 now, your group as a whole has not 13 made sufficient progress in 34 sophisticated power pool planning to warrant sitting down with 15 Florida Power Corporation'and 16 Florida Power and bight and laying 17 18 out as a group a well-defined plan 19 of transmission in gereration 20 whereby you could show sufficient 21 mutual benefits to these major 22 utilities to justify their interest 23 in participating n your plans."
24 Q
.And the next. sentence, if you would, please.
25 A
"Up until now, perhaps you didn't ~
{
IIAHERMIIAW 6t, EBERHARD COURT REM.)RTING MERVIN B.J.EBERHARD MUE M. H ADI;HMII AW "U
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TALLAH A>m E HIDA 82302
C kos Dsposition 2
57.
APPENDTX E care and moreover didn't really j
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want their participation."
q{
3 Q
Does that accurately reflect your perception of 4
where things stood in March of 1966?
5 A
This was his assumption of where things stood.
It 6
did not necessarily reflect the aspirations of where various 7
parties might like to see the systems go to.
8 Q
All right, sir.
Well, leaving aside aspirations 9
for a moment, do you disagree with his statement that, as of to that time, the FMUA group as a whole had not made sufficient 11 progress in sophisticated power pool planning to warrant 22 sitting down with Florida Power Corporation and Florida Power 13 and Light Company?
Do you disagree with that?
14 A
It cannot apply to all members, you know.
Is Q
Would it apply to Tallahassee?
16 A
We may have been at that point in time, not as 17 informed as we ought to be about the various options.
18 Q
All right, sir.
Have you ever been involved in i
19 an organization called Yankee Dixie?
20 A
No.
I've attended meetings where they made 21 presentations, but I've never been a party of it or 22 partcipated in it or things of this nature.
23 Q
You've never attended a l
24 A
John Kelley was a big promoter of the Yankee Dixie 25 concept from the Florida group.
IIABERSIIAW 66, EBERHARD l
COURT HEPORTING MEHVIN B.J.EBERHARD
- Un u. naucusuaw en, ewYina
43 ***-"8**
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tau.Ana sesoe
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j APPENDIX F s
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i APPENDIX F
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c PRELIMINARY
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POWER SUPPLY STUDY
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FOR THE i
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FLORIDA MUNICIPAL POWER AGENCY l
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Dl; FINAL REPORT 4
i d
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-s i.
t R.W. BECK AND ASSOCIATES
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l ENCa*vt125 AND CONSULTANTS j
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FE!3RUARY,1979 4
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APPENDIX F IV 'i C.
Long-Range Period (1991-2000) r To meet Agency loads and/or other potential Members' loads and/or joint projects with others from units not presently planned, the fol-lowing have been evaluated:
O 1.
Coal-fired units in +he 600-800 MW range; 2.
Nuclear units in the 900-1300 MW range.
D.
The study includes a discussion and review of the applicability for l.
future Agency projects of nuclear units in the 400 MW range using the Consolidated Nuclear Steam System (CNSS) concept.
A discussion of the evaluation of these ai:ernatives and the results are incladed in Sections VIII and X of this report.
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TABLE VIII-3 FLORIDA MUNICIPAL POWER AGENCY PRELIMINARY POWER SUPPLY STUDY ESTIM ATED PRINCIPAL AMOUNT OF BONDS BASE LOAD NUCLEAR UNITS WITH COMMERCI AL OPERATION DATES IN 1992
$(000)
Line Capacity No.
900 MW 1,7.00 M W (a)
(b)
(c) 1 Direct Construction Cost (1)
$1,627,200
$1,860,000 2
Initial Working Capital (2) 88,300 100,900_
3 Sub-Total
$1,715,500
$1,960,900 Financing Costs:
4 Bond IMacount (3) 85,400 97,600 5
Debt Service Reserve (4) 229,500 262,300 6
Reserve and Contingency Fund (5) 23,000 26,200 7
Gross Interest During Construction (6) 991,200 1,133,400 8
Less Investment Earnings (7)
(l7, 700)
(226,200) 9 Tetal Estimated Principal Amount of Bonds
$2,846,900
$3,254,200 (1)
From Table VIII-l for earliest practicable commercial operation date.
Includes initial fuel core.
p (2)
Estimated for initial fuel core and reload, 'wo months' other O&M costs, and fixed charges.
'o (3)
Estimated at 3% to cover financing, legal, engineering, and Agency administrative expenses.
(4)
One year's level debt service on 30-year, 7% bonds.
(5)
At 10% of annual debt service.
g' y (6)
Includes interest for one year past commercial operation date.
yy (7)
Estimated at 6% on unexpended construction funds.
y M
3 a,
APPENDIX F X-5 7.
Construction by FMPA or by individual members of slow i(
speed (150 rpm) or medium speed (450 rpm) heavy oil-burning diesel generating units in 8-12 MW increments with the number of units at any plant possibly being limited by environmental or Department of Energy regulations.
4 1
Long-Range Pe riod (1991-2000)
FMPA should form standing committees to study internally and with others the potentiality and practicality of jointly constructing and nwning generating projects in the long-range period having the following priority:
f 1.
Nuclear units in the 900-1200 MW ra.nge at sites to be selected based upon joint studies with others. This alternative is subject to present uncertainties regarding nuclear fuel reprocessing, spent fuel disposal, and
(
other regulatory matters.
2.
Coal-fired units in the 600-800 MW range at sites to be determined based on joint studies with other potential participants.
Of the alternatives evaluated in the Interim Report, the projects not included in the priority listing above were (i) the construction by the Agency of 200 MW coal-fired units, (ii) combustion turbines for intermediate or peaking requirements and high-speed diesels burning No. 2 oil for peaking requirements, (iii) unit power purchases from FP&L's existing Turkey Point 3 and 4 and St. Lucie No. I nuclear units and from FP&L's St. Lucie No. 2 nuclear unit scheduled for 1983, and (iv) unit power purchases from FP&L's two 700 MW coal-fired units planned for 1985 and 1987 at its Martin site and from FPC's 640 MW coal-fired units planned for 1985 and 1987 at an unknown site (Fossil 1 and 2). The 200 MW coal-fired units were excluded due to the b
high overall cost of power compared to the other larger coal-fired units that could be installed in the same time frame. As for the combustion turbines for intermediate and peaking service and the high-speed diesels for peaking service, the se were not included since, on an overall basis, the Agency will not have deficiencies in the peaking and reserve range where this type of generation is normally best suited.
Unit power purchases from FPkL's existing nuclear units and i
St.. Lucie No. 2 were not included in the comparison of alternatives even though these were relatively attractive alternatives because a unit purchase would be less advantageous to the Agency than an ownership entitlement. By j
not including such unit purchases in the comparison of projected power costs i
1
(
from the various alternatives, it is not intended that such unit power purchases should be eliminated from consideration if that is the only method of partici-pation-in these nuclear units available to the cities as a result of their litigation.
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APPENDIX G
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