ML20062F509

First Set of Interrogs & Requests for Production of Documents from Dept of Justice to Intervenor Cities of San Antonio & Austin.Cert of Svc Encl

ML20062F509
Person / Time
Site:	South Texas
Issue date:	11/30/1978
From:	Clark R, Harris J, Parmenter F JUSTICE, DEPT. OF
To:
References
NUDOCS 7812180412
Download: ML20062F509 (24)

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NRC PUBLIC DOCU' DENT ROOM O'.

1 . > '7 ' UNITED STATES OF AMERICA g< y NUCLEAR REGULATORY. COMMISSION W[i g (.

. Jjf G BEFORE THE ATOMIC SAFET AND LICENSING BOARD {- h [#

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In the Matter of )

) Docket Nos. 50-498A HOUSTON LIGHTING AND POWER ) 50-499A CO., et al. )

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(South Texas Project, Units )

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FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS FROM DEPARTMENT OF JUSTICE TO THE CITIES OF AUSTIN AND SAN ANTONIO _

Preface The Department of Tustice (" Department") hereby requests, pursuant to Sections 2.740b and 2.741 of the Commission's Rules of Practice, that Applicants Austin and San Antonio answer in writing the following interrogatories i'

and produce the pertinent documents. Each interrogatory should be answered separately and fully in writing under oath or affirmation by the person (or persons) making it.

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A. Definitions

1. " San Antonio" 'ineans the City of San Antonio, Texas, acting by and through the City Public Service Board of San Antonio, and any other agency, creature, division, 78121808 % @

, -c or part of the governing structure of the City of San Antonio having any relation to, contact with, or participa-tion in matters affecting or relating to the sale, purchase, transmission, or exchange of electrical power or energy.

2. " Austin" means the City of Austin, Texas, including its electrical utility department, and any other agency, creature, division, or part of the governing structure of the City of Austin having any relation to, contact with, or participation in matters affecting or relating to the

. sale, purchase, transmission, or exchange of electrical

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power or energy.

3. " Identify" when used with respect to documents, means that the type, author, recipient (s) of the original, recipient (s) of copies, date, and subject of the document should be specified.

" Identify", when used herein w.'h respect to any person means that the person's name, current (or past if retired) business address, job title and employet should be specified.

" Identify" when used herein with reference to any corporation, association, cooperative, or other legal entity, means to state the name and current address of said organization or entity and if the current address is unknown, provide the la'st known address.

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4. " Documents" means all writings and records of 1

every type in the possession, control or custody of Applicants Austin or San Antonio, their directors, officers,-

I attorneys, employees or agents, including but not limited-J to memoranda, correspondence, reports, surveys, evaluations, charts, books, minutes, notes, agendas, diaries, transcripts,-

microfilm, accounting statements,-telephone and telegraphic communicatien, speeches, and all other records, written, eleecrical, mechanical or otherwise, but excluding documents relating to the design, construction or routine operation-of electrical facilities. Where engineering feasibility:

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studies or reports are furnished, the underlying detailed data need not be supplied.

" Documents" shall also mean copies of documents, even-though the originals thereof are not in the possession, custody or control of Applicants Austin or San Antonio, their directors, officers, attorneys, employees or agents-and every copy of a document which contains handwritten or other notations or which'otherwise does not duplicate the-original or any other copy.

5. " Electric Utility" or " Utility" shall mean a private

~i or public corporation, cooperative, rural electric coopera-tive, municipality, joint stock association, or any political subdivision, agency or instrumentality of the federal, state, or municipal government, or a lawful association of any of the foregoing which owns, controls,.

or operates, or proposes to own, control, or operate facilities for the generation, transmission or distribution of electricity.

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6. " Coordination" shall refer to firm power sales

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, (including partial requirements sales to supplement other

, power supply resources), reserve sharing, spinning reserve charing, economic dispatch or economy interchange, stagger-ed additions of generating or transmission facilities, ~'

em'ergency and maintenance power interchange, joint'mainte-nance scheduling, transmission service, connections or-interconnections, short term power interchange, diversity interchange, pooling, or sales, purchases or exchanges of any form of wholesale power among utilities. " Coordination" t (

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and " coordinating" shall also include joint ventures in the sharing of, or participation in, the ownership, operation, or output of generating facilities and the sharing of ownership, construction, or use of transmission facilities.

7. "FERC" shall mean the Federal Energy Regulatory Commission or any predecessor agency and the Department of i

, Energy (DOE).

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'/ 8. "FPC" shall mean the Federal Power Commission and I

5 any successor agency including FERC and DOE.

9. " Relating to" means relating to in any way and includes documents which are the subject of the request.

(e.g. " relating to a contract" includes the contract I i

itself). Requests concerning a subject or item should be I l

understood to include all possible or contemplated actions-with respect to such subject or item. For example, requests for documents relating to interconnection plans would include documents relating to interconnection arrangements that have been considered but rejected.

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10. "ERCOT" means the Electric Reliability Council of Texas.

. 11. " TIS" means the Texas Interconnected System and its f o;

predecessor organizations, the South Texas Interconnected

System and the North Texas Interconnected System.

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12. " Houston Lighting and Power (HL&P)" means the Houston Lighting and Power Co., and its parents, subsidiar-les and affiliates and all predecessor companies, includ-ing Houston Industries.

13. " Texas Utilities (TU)" means the Texas Utilities Generating Company and its parents, subsidiaries and af-filiates and all predecessor companies, including Dallas Power & Light Company, Texas Electric Service Company (TESCO), Texas Power and Light Campany, and Texas Utilities Co.

14. " West Texas Utilities (WTU)" means the West Texas Utilities Company and its parents, subsidiaries and af-filiates and all predecessor companies, including Central Power and Light Co., Central and Southwest Corporation, and C&SW Inc.

B. Documents No Longer in Utility's Possession, Custody or Control

, If any document described in this section was, on or after December 19, 1970,(date of enactment of P.L.91-560), but is no longer in San Antonio or Austin's possession, or subject to its control, or in existence, 1

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r state whether it (a) is missing or lost, (b) has been  !

destroyed, (c) has been trcnsferred to others, or (d) has l

been otherwise disposed of. In each instance, expla.in the circumstances surrounding such disposition and identify the person (s) directing or authorizing same, and the 4 date(s) of such direction or authorization. Identify each such document by listing its author and addressee, type (e.g., letter, memorandum, telegram, chart, photograph, i

etc.), date, subject matter, whether the document (or.

copies) is still in existence and, if so, its present location and custodian (s).

C. Period Covered and Privilece Unless otherwise indicated, the documents which the Department requests be furnished shall include all docu-ments from the files and records of Applicants Austin and San Antonio dated January 1, 1965, to the present.

It is requested that any documents withheld by the

( Applicants by reason of any assertion of privilege, be identified individually by listing the person (s) preparing, sending, or receiving the same, the subject and date thereof, and a brief statement on the basis for asserting privilege as to each document.

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All documents for..which privilege is claimed shall be I submitted to the Licensing Board under seal no later than the last day for this document production.

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4 D. Documents Available at the Federal Power Commission (FPC) or Federal Energy 9agulatory Commission (FERC)

In the event that any of the documents or material requested are available on FPC forms 1 or 12 or in any

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other public filing made with the Federal Power Commission, or its successor agency, FERC, such documents and materials need not be supplied. However, each such document should L-be individually and specifically identified including the FPC or FERC file number and the specific location of the requested information on any standardized FPC or FERC *

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form. I E. General Instructions

1. In any situation where a document is supplied in response to a request, such document should be referenced and identified as to the interrogatory (including subpart) to which it responds. Should any of the documents requested pursuant to this set of interrogatories and requests for document production have already Seen made available for the t .-

Department's inspection, it will be sufficient that this be so noted along with the following information: (1) production number, if any; (2) date, author, addressee (if any), .

persons receiving distribution of such document or copies thereof; and (3) a description of'the nature of the document.

All pertinent documents' and/or identifying information shall

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be submitted along with the response to this set of interroga-tories. j

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'2. Pursuant to the directive of the Board, issued at j p

. the prehearing conference on June 21, 1978, these interrog-atories and requests for documents are of a continuing nature and require supplemental answers should the recipi-ent Applicants Austin and San Antonio obtain further pertinent information or documents between the time their

answers are filed and their documents produced and the time of the evidentiary hearing.

F. Interrogatories & Document Production j

z' l. Providing the identity of the requestor, the date of the request (s), the individual contacted and the nature of response (s), describe each occasion upon which an Electrical Utility engaged in interstate commerce, or interconnected with an Electrical Utility engaged in interstate commerce, contacted San Antonio and/or Austin, regarding: (a) a request to purchase, sell, or exchange electrical power or energy, including but not limited to wholesale transactions; (b) requests for the use of transmission services; (c) requests for membership in the Texas Interconnected System (TIS); (d) requests for membership in the Electric Reliability Council of Texas (ERCOT); and (e) provide all documents which relate to (a)-(d) above.

2. Inorderofth$irrelativeimportance, describe the underlying policies or bases upon which San Antonio.

and Austin justify their refusal to engage in the inter-state transmission or reception of electrical power er

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! energy or to'be interconnected with any other Electric

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Utility engaged in interstate commerce; provide any documents which state or describe these policies or bases.

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3. With respect to the South Texas Project, identify and describe: (a) all requirements which had to'be satisfied before any Electrical Utility would be allowed to partici-pate in the project; (b) all provisions of the South' Texas participation agreement, if any, which limit participation to Electrical Utilities engaged only in intrastate commerce; (c) whether there is any method whereby it is technically feasible to operate the South Texas Project in a situation where one of the participants is engaged in both intrastate and interstate commerce, while all the other participants are engaged exclusively in intrastate commerce; (d) if there is a technically feasible method to allow this manner of operation, state how much it would cost to implement this

, method, specifying all assumptions, methods of calculation, and techniques employed in making that estimate; and (e) provide all documents which relate to (a)-(d) above.

4. State in current dollar amounts what cost, if any, would be borne by San Antonio and Austin if ERCOT were interconnected with the Southwest Power Pool. State all assumptions underlying these calculations, who made such

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1 calculations,when they were made, and whether these calculations were undertaken for any purpose other than to use in this or related litigation. Provide all studies, drafts, working papers, etc. relating to the calculations of any such costs.

5. (a) State every occasion since 1965, if any, on which San Antonio or Austin communicated with or considered communicating with any other Electrical Utility to dissuade that utility from commencing to operate, or te discontinue r

its then current operation, in interstate commerce. (b)

With respect to each such occasion identified in response to (a), describe and/or identify all individuals involved in any such communications or contemplated communications, the surrounding circumstances, the substance of any such communications, the individuals (and the entities for which they worked) to whom such communications were made, and the response (s) of those individuals or entities.

(c) Provide all documents which relate to the response

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to this interrogatory.

6. (a) Identify each and every occasion, if any, upon which San Antonio and/or Austin communicated with West l Texas Utilities Company or Central Power & Light Company on the subject of possible interstate operation by WTU or CP&L, giving the date(s) of any such communication (s), the surrounding circumstances, the individual (s) so communicat-ing, the recipient (s) of any such communication (s) and the

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9 response (s), if any, of the recipient (s). (b) Provide all documents which relate to the response to this interrogatory.

7. '(a) State whether San Antonio or Austin through any of its management or executive employees has ever promulgated, published, circulated, or in any way communi-cated throughout the Utility or city government'or to any external person or entity, that it maintained a policy or practice of operating exclusively in intrastate commerce. (b) State whether San Antonio and/or Austin through any of its management or executive employees has ever promulgated, published, circulated, or in any way communicated throughout the Utility or city government or to any external person or entity, that it intended in the future to operate exclusively in intrastate commerce. (c)

If the answer to either (a) or (b) is in the affirmative, give the date(s) of any such commun.ication(s), the surround-ing circumstances, the individual (s) so communicating, the recipient (s) of any such communication (s) and the specific

, response (s), if any, of the recipient (s). (d) Provide all documents which relate te (a)-(c) above. -

8. With respect to the FERC's Fort Worth regional office study, " STAFF REPORT ON ELECTRIC RELIABILITY COUNCIL OF TEXAS INTERCONNECTION AND RELIABILITY' EVALUATION," March, {

1978, do San Antonio an,d Austin contend that: I

, (a) the report is incorrect in assessing the amount of cost necessary to interconnect ERCOT and SWPP as being $31,175,000 (p. 32);

! (b) the report is incorrect in asserting: "' Internal' load flows for single contingency loss of the largest generating unit in South Texas (South Texas Project 1,250 MW unit) and single contin-gency loss of the largest generating unit in

- North Texas (Comanche Peak 1,130 MW unit) were i

made for ERCOT interconnected with SWPP and the

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rest of the eastern interconnected systems group for 1982. No over loads or adverse effects,were observed" (p. 28);

(c) if the answer to (a) or (b) is affirmative, and San Antonio or Austin does reject that finding of the study, explain the basis for that rejection; (d) provide all documents which relate to (a)-(c) 7 above.

9. (a) Do San Antonio and Austin assert that their s costs of regulation under FERC regulatory authority would be greater or less than their costs of regulation under the Texas Public Utility Commission; (b) If San Antonio and Austin assert that greater costs will result from FERC regulation, state the' basis upon which that contention rests; and (c) provide all documents which relate to (a)-(b) above.

10. Do San Antonio and Austin contend that' if they become subject to FERC. jurisdictional authority, the

Commission could order them to implement interconnections, provide transmission services, or take other action, the result of which would be detrimental to their customers?

If so, state the basis of that contention and provide all ,

documents relating to that contention.

11. (a) State for every wholesale customer of San Antonio or Austin, if any: the full name or title of the customer; complete address of the customer; the amount of wholesale power purchased by that custorer by year for the period 1950-1978; and the previous supplier of that

(;  ; customer, if any. (b)-State all requests received by San Antonio and/or Austin for wholesale service whether or not such service was :rer provided, specifying when the request was received, by whom the request was made, and whether the requesting party was at the time of the request engaged in interstate commerce. (c) Provide all documents relating to the response to this interrogatory.

12. State the purpose for which ERCOT was formed and provide all documents relating to its formation. Do San Antonio and/or Austin contend that ERCOT engages in activities different from, or has more power and authority than, other regional reliability councils such as SERC (Southeast Reliability Council)?

13. State the purpose for which the TIS was formed.

l Provide all documents relating to its formation. List every occasion upon which an Electrical Utility has requested membership in TIS and provide all documents relating to such request and the response to that request.

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14. In reference to the formation of ERCOT, identify each occasion upon which any employee of San Antonio or Austin engaged in any communication with any other party,

! individual or entity, specifying the substance of each such communication, the employee of San Antonio or Austin

who made it, the date, the recipient of the communication, i and the recipient's response, if any, relating to

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(a) the advisability of limiting membership in ERCOT t

to Electric Utilities engaged only in intrastate commerce; i ( (b) concern about possible antitrust implications of so limiting membership to intrastate Electric Utilities only; (c) alternative devices or understandings, either I

formal or informal, whereby Electric Utilities engaged in interstate commerce coulo be fore-closed from membership in ERCOT without " intra- 'N state only" operation being made an explicit

( requirement for membership; and (d) provide all documents relating to (a)-(c) above. ,

15. (a) Describing the circumstances and providing the date., persons participating, and facilities inspected, identify each occasion upon which employees of San Antonio and/or Austin (including attorneys retained by either

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Electrical Utility) visited the generating plants, relays, installations, or equipment of the other Utility, either alone or accompanied by. employees of the Electrical Utility owning,the facility, for the purpose of inspecting any. relays, mechanical devices, or other equipment designed to prevent the flow of electrical power or energy in interstate commerce; j (b) Describing the circumstances and providing the dar?< persons participating, and facilities inspected, identify each occasion upon which employees of San Antonio or Austin visited the generating plants, relays, installa- s tions, or equipmen?. of any other entity or Electrical Utility (i.e., other than San Antonio or Austin) for the purpose of inspecting any relays, mechancial devices, or other equipment designed to prevent the flow of electrical power or energy in interstate commerce; i (c) Identify each occasion, occurrence, or date upon which any employee of San Antonio or Austin requested, provided or received any pamphlets, printed material, reports, or other written matter, pertaining to the installation or maintenance by any Electrical Utility, of any relays, mechanical devices, or other equipment designed to prevent the flow of electrical power or energy in interstate commerce, specifying the date, material request-ed, material received or provided, and the individuals and Electrical Utilities involved;

(d) estimate how much money has been expended, if l any, since 1965 by San Antonio and Austin for the purpose of seeking to inspece relays, mechanical devices, or other equipment of another electrical company or Utility to ascertain whether any electrical power or energy was flowing from that equit. 'nt into interstate commerce; and (e) provide all oct sents which relate to (a)-(d) above.

16. (a) Identify ove:v occasion known to San Antonio

or Austin upon which TFSCc 9ither threatened to open or in

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t fact did open any or all ' its interconnections with West .

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! Texas Utilities Co. (b) Witu respect to each such occasion 1 identified in response to (a) describe and/or identify, if known, all individuals in Ived in either threatening to open or in actually openier interconnections, the surrounding circumstances, che abstance of any such threats, the recipient (s) of c.q threats, and the re-l sponse(s) of all involved individuals er entities to any

! threatened or actual disconnect i a's. (c) In addition,

.I l identify and describe each reason, justification, or policy known to San Antonio or Austin which led TESCO either to threaten disconnectior or actually to disconnect from WTU. (d) Provide all documents which relate to the response to this inteirogatory.

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17. (a) Identify by date each occasion or period upon I

or during which San Antonio and/or Austin was interconnec-ted with any Electrical' Utility transmitting or receiving l

electrical power or energy in interstate commerce, or was interconnected with any Electrical Utility that was in turn interconnected with an Electrical Utility transmitting or receiving electrical power or energy in interstate

! commerce; (b) state in detail all detrimental financial consequences or disadvantageous engineering ramifications, t

( if any, that occurred during these periods, occasions or l

instances of interstate interconnection which were a

! direct result, and/or were caused or effected by, this

! t interstate interconnection; and (c) provide all documents relating to (a)-(b) above. N

18. (a) Identify every contract,. agreement or under-l standing, if any, relating to the purchase, sale, exchange, or transmission of electrical power or energy, to which g

San Antonio or Austin is a party, which contains any language, provision, or section that limits, prohibits, or has the effect of foreclosing San Antonio, Austin, or any other l Utility from transmitting or receiving electrical power or energy in interstate commerce, or which requires, mandates, I or specifies that before San Antonio, Austin, or any other Utility may engage in the interstate-transmission or reception

' of electrical power it must notify any other Electrical Utility (including but not limited to signatories under the contract); and

(b) provide a copy of any contracts, agreements or understandings identified in response to part (a) of f

this interrogatory.

I 19. Pertaining to the May 4, 1976, disconnections by i Houston Lighting and Power and TU from Electrical Utilities .

l with which they had been interconnected, state:

i (a) whether prior to these disconnactions, any 6 communication took place between any employees or agents l of HLSP and/or TU and employees of San Antonio or Austin, g ([' "

3 regarding what action these Electrical Utilities ought to undertake in response to WTU's radial tie and transmission i,

of electrical power and energy into interstate commerce; (b) whether subsequent to these disconnections, any 5 '

communication took place between any employees or agents i

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! of HL&P and/or TU and employees of San Antonio or Austin i

regarding under what conditions HL&P and/or TU would 4

g reconnect with any Electrical Utility, including but not limited to San Antonio and Austin; (c) if the answer to either part (a) or-(b) of this ,

i interrogatory is affirmative, then relate in detail the ,

substance of each such communication, the individuals .

involved, the date on which each such communication took ,

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. place, the response to each such communication, and the [

l surrounding circumstances; and ,

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l (d) provide all documents relating to (a)-(c) above.

f 20. Under current circumstances, if San Antonio or I

j Austin were offered the opportunity to purchase competitively priced electrical power or energy from an Electrical a Utility engaged in interstate commerce:

! (a) would San Antonio or Austin decline to purchase i

i such electrical power because it was offered by I

l an Electrical Utility sngaged in interstate commerce.

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(b) if the response to part (a) of this interrogatory I

is in the affirmative, specify every reason, l ( justification, policy, or condition that would l prevent or foreclose San Antonio or Austin f rom i

j purchasing interstate electrical power or energy.

j 21. (a) State whether San Antonio and/or Austin ever i

j communicated to any other Electrical Utility that if that Utility engaged in interstate transmission or reception of i electrical energy, or interconnected with any Utility engaged in interstate commerce, that San Antonio and/or

, Austin would disconnect from that Electrical Utility

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(b) if the response to part (a) of this interrogatory s  ; is in the affirmative, identify each.and every occasion, date, j occurrence and situation upon or during which such communica-

". tion was made to another Utility, specifying in detail the sub-l a mus w w se az. mmew.r== .w wwww==-wguu-asumm-m sw-w ww--ww-sumes , s ar a s=uuuuuuurwar.e. rx_-wouumeww - - a m anummassa. a..J

stance of each such ccmmunication, the individuals and Electrical Utilities involved, the date on which each such communication took place, the response to cach such communication, and the surrounding circumstances; and (c) provide all documents which relate to (a)-(b) above.

22. Specifying the substance of each communication, i the individuals, companies, organizations or untities I

involved, the date on which each communication occurred, the response to each communication, and the surrounding circumstances, state every occasion upon which San Antonio or Austin contacted any individual, company, organization, or entity for the purpose of soliciting, requesting, encouraging or persuading the recipient (s) to:

(a) discontinue or decrease self-generation and commence to receive part or all of its electrical requirements from San Antonio or Austin; I (b) discontinue or decrease taking any or all of 1.s electrical requirements from another Electrical Utility and instead receive part or all of its electrical requirements from San Antonio or Austin; (c) relocate exist'ing plants, manufactur ing installa-i tions, or any other facility within the service arc.a of Austin or San Antonio; i -

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s d (d) build new plants, manufacturing installations, or 4

any other facility within the service area of Austin or San Antonio; and (e) provide all documents relating to (a)-(d) above.

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l Respectfully submitted, k_^

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Q =os R. re-A.

Jhdith L. Barris i Ronald H. Clark 1

Federick H.Parmenter

! Attorneys, Energy Section Antitrust Division U.S. Department of Justice Washington, D.C.

j; (_l November 30, 1978 ( -

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UNITED STATES OF AMERICA NUCLEAR REGULATOPY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

• In the Matter of )

)

HOUSTON LIGHTING AND POWER ) Docket Nos. 50-498A CO., et al. ) 50-499A

)

(South Texas Project, Units )

1 and 2) )

)

)

( '

CERTIFICATE OF SERVICE I hereby certify that service of the foregoing FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION

OF DOCUMENTS FROM DEPARTMENT.0F JUSTICE TO THE CITIES i

OF AUSTIN AND SAN ANTONIO has been made on the following j parties listed hereto this 30th day of November 1978, by I depositing copies thereof in the United States mail, first class, postage prepaid.

Marshall E. Miller, Esquire Richard S. Salzman, Esquire

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l U.S. Nuclear Regulatory U.S. Nuclear Regulatory

Commission Commission

! Washington, D. C. 20555 Washington, D. C. 20555 Jerome E. Sharfman, Esquire

( Michael L. Glaser, Esquire U.S. Nuclear Regulatory 1150 17th Street, N.W.

Washington, D. C. 20036 Commission l Washington, D. C. 20555

} Sheldon J. Wolfe, Esquire

< U.S. Nuclear Regulatory Chase R. Stephens, Secretary Commission Docketing and Service Branch -

1 Washington, D. C. 20555 U.S. Nuclear Regulatory Commission l Washington, D. C. 20555

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Samuel J. Chilk, Secretary Office of the Secretary.of the Commission Jerome Saltzman U.S. Nuclear Regulatory Chief, Antitrust and -

Commissfon Indemnity Group Washington, D. C. 20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D. C. 20555

< i Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 ,

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Michael I. Miller, Esquire Chairman and Chief Executive Richard E. Powell, Esquire Officer David M. Stahl, Esquire -

Central Power and Light Thomas G. Ryan, Esquire Company Isham, Lincoln & Beale P. O. Box 2121 One First National Plaza Corpus Christi, Texas 78403 Chicago, Illinois 60603 G. K. Spruce, General Manager Roy P. Lessey, Esquire ,

City Public Service Board Mi~chael Blume,-Esquire P.O. Box 1771 U.S. Nuclear Regulatory San Antonio, Texas 78203 Commission Washington, D. C. 20555 Perry G. Brittain President Jerry L. Harris, Esquire Texas Utilities Generating City Attorney, Company Richard C. Balough, Esquire ,

2001 Bryan Tower Assistant City Attorney

( m, Dallas, Texas 75201 City of Austin

(. P.O. Bax 1088 R.L. Hancock, Director Austin, Texas 78767 City of Austin Electric

( Utility Department Robert C. McDiarmid, Esquire i P. O. Box 1088 Spiegel and McDiarmid Austin, Texas 78767 2600 Virginia Avenue, N.W.

Washington, D. Cs 20036 G. W. Oprea, Jr.

1 Executive Vice President Dan H. Davidson

{ Houston Lighting & Power City Manager Company City of Austin P. O. Box 1700 P. O. Box 1088 Houston, Texas 77001 Austin, Texas 78767 l Jon C. Wood, Esquire Don R. Butler, Esquire l -

W. Roger Wilson, Esquire 1225 Southwest Tower

(_ Matthews, Nowlin, Macfarlane Austin, Texas 78701

& Barrett

1500 Alamo National Building Joseph Irion Worsham, Esquire j San Antonio, Texas 78205 Merlyn D. Sampels, Esquire

Spencer C. Relyea, Esquire Joseph Gallo, Esquire Worsham, Forsythe & Sampels Richord D. Cudahy, Esquire 2001 Bryan Tower, Suite 2500 j Robert H. Loeffler, Esquire Dallas, Texas 75201 l Isham, Lincoln & Beale l

Suite 701 Joseph Knotts, Esquire 1050 17 th Street, N.W. - Nicholas S. Reynolds, Esquire Washington, D. C. 20036 Debevoise & Liberman 806 15th Street, N.W.

Suite 700 Washington, D. C. 20005 l

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Douglas F. John, Esquire R. Gordon Gooch, Esquire Akin, Gump, Hauer & Feld John P. Mathis, Esquire 1100 Madison Office Building Baker & Botts 1155 15th Street, N.W. 1701 Pennsylvania Avenue, N.W.

Washington, D. C. 20024 Washington, D. C. 20006 Morgan Hunter, Esquire Robert Lowenstein, Esquire McGinnis, Lochridge & Kilgore J. A. Bouknight, Esquire 5th Floor, Texas State Bank William Franklin, Esquire Building Lowenstein, Newman, Reis &

900 Congress Avenue Axelrad Austin, Texas 78701 1025 Connecticut Avenue, N.W.

Washington, D. C. 20036 Jay M. Galt, Esquiro Looney, Nichols, Johnson E. W. Barnett, Esquire

& Hayes Charles G. Thrash, Jr., Esquire 219 Couch Drive J. Gregory Copeland, Esquire Oklahoma City, Oklahoma 73101 Theodore F. Weiss, Jr., Esquire es Baker & Botts

\_/

Knoland J. Plucknett 3000 One Shell Plaza Executive Director Houston, Texas 77002 Committee on Power for the Southwest, Inc. Linda L. Aaker, Esquire 5541 East Skelly Drive Kevin B. Pratt, Ssquire Tulsa, Oklahoma 74135 Assistant Attornay General P.O. Box 12548 John W. Davidson, Esquire Capital Station Sawtelle, Goode, Davidson Austin, Texas 78711

& Tioilo

! 1100 San Antonio Savings Frederick H. Ritts, Esquire Building Northcutt Ely

! San Antonio, Texas 7820S Watergate'600 Building

' Washington, D.C. 20037 i W. S. Robson I (, General Manager

~

South Texas Electric Cooperative, Inc.

Route 6, Building 102 Victoria Regional Airport

_- jd M. ffM Ronald H. Clark , Attorney Victoria, Texas 77901 Energy Section  ;

Antitrust Division Department of Justice

=e, I

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