ML20133F658

Requests NRR Reevaluate Decision Re No Significant Antitrust Changes That Would Necessitate Antitrust Review. Util Financial Status Discussed

ML20133F658
Person / Time
Site:	Clinton
Issue date:	10/09/1985
From:	Batz R AFFILIATION NOT ASSIGNED
To:	Office of Nuclear Reactor Regulation
References
A, NUDOCS 8510110176
Download: ML20133F658 (13)

Text

,

I <

4-Maybeck Place Elsah, IL 62028 Oct. 9, 1985 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission gg , gj g{

Washington, D.C. 20555

Dear Sirs:

I request that your department reevaluate your decision re. Illinois Power Co. et al that was registered in the Federal Register on Sept.

13, 1985 to the effect that you found no significant antitrust changes which would necessitate a formal operating licence antitrust review of the Clinton Unit 1 Power Station.

I have been studying the Clinton situation for three years in various capacities; please see enclosures of my testimony before the ICC on Sept. 12, 1984 and the oral statement that I delivered on June 18, 1985. In addition, I have posted to your office a xeroxed copy of the complete study that I conducted--which is referred to in the aforementioned testimony. These documents summarize my understanding of the situation as of June.

Since June, evidence has come to my attention which indicates that the coops are in dire fiscal crises--I have no hard facts in my hands to that effect, but know that others do.

It is highly likely that one or more of the 22 distribution coops will go into a chapter 11 bankrupey soon--and perhaps even WIPCO, since three of the seven coop boards now have a near majority of board members that were elected this summer of 1985 on an anti-rate / anti-Clinton slate.

In essence, the economic situation re. Clinton is in shambles. The October 1984 accord between the coops and IP will be vigorously challenged by myself and others in the ICC docket 84-0472 which is in process. We, the member-owners of the 22 distribution coops, are being constrained to participate in an-power purchase agreement with WIPCO and Soyland--who are locked into an 111 fated investment in the Clinton plant. The Oct.

1984 accord hurts both IP and coop customers; IP customers have to assume more of the capital costs for Clinton and the coop customers have to g pay more for the fewer kw that we will get for Clinton electricity as g our percentage of ownership decreases.

5 I urge you to investigate the financial records of all 22 distribution i/J coops and WIPCO and Soyland before you rule that indeed the competitive act climate has not changed in Illinois re. IP and Clinton. In a few months, D some of the coops may sell out to investor-owned utilities, go into 64 chapter 11, and/or reorganize themselves into new entities. All of these

- activities will effect IP's fiscal status re. Clinton.

O I,therefore, urge that you review your decision in this case. I remain

{ggg available to work further on this issue as seems appropriate.

c;g"11 1-Roger B tz, Phd pod pe:W M/M B

Enclosures:

Sept. 12, 1984 and June 18, 1985 ICC testimony of Batz.

Illinois coop map.

A-~ '

• o .o r

h STATE OF ILLINOIS ILLINOIS COMMERCE COMMISSION ILLINOIS CO M ERCE COMMISSION )

On Its Own Motion )

) Docket No. 84-0055 An investigation to consider a )

plan for moderating the initial )

rate increase associated with )

placing Illinois Power Company's )

Clinton Unit No. 1 generating )

station in service. )

ORAL

• HEARING ~ STATEMENT OF DR. ROCER BATZ Ph.D.

h Dr. Roger Bats, Ph.D.

2 #2 S. Elsah Hills Rd.

. Elsah, IL 62028 June 18, 1985 ps

_ - . _ _ _ _ . , , _ ___ _ - _ _ _ - ~ - - _ - _ . _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ , _ , ,

q I appreciate the opportunity to participate in this docket as an independent citizen

!V and having this time to discuss the evidence with the commission. As a sociologist and MJM distribution cooperative member-owner, I have been studying the impact of Clinton Unit 1 mainly on WIPCO distribution cocaperative member-owners, but also on other entities involved--which included a study of the energy use behavior (through interviews in the home) of 1019 systematically sampled WIPCO distribution cooperative member-owners.

Such behavioral and attitudinal evidence can be more reliable than econometric modeling

! or an extrapolation of historical trends--particularly in unique situations. Since officially projected cooperative electric rates were unprecedented, this methodology and on-site data gathering technique seemed most appropriate for this study.

The aggregate data gathered and interviews and observations conducted since the June 1984 publication of this study have generally validated the study results. MJM's 50% rate increase (from 8c/KWH in 1983;to 12.Sc/KWH in 1985) and other similar coop rate hikes (up to 14.5c/KWH in another WIPCO coop in 1985) have caused customers to use less electricity through conservation and/or switching to more economical 'available alternatives like wood, propane, and active or passive solar. In addition realtors and trailor courtnowners are>> commenting about the difficulty of attracting new residents

because of the high electric rates--more that double the ratea, in some cases, than the t investor-owned utility (IOU) servicing the area; furthermore, people are citing high i

electric rates as reasons for moving out of coop territories. WIPCO's total' sales decline

.2% in 1984 over 1983; four distribution coops sold fewer KWH two sold more (4% and 1%) and one sold the same. Large and small farmers comment about being forced one step l

closer to insolvency because of the high rates; their cash flow is already'being threa-r tened by the worst economic conditions in the rural Illinois farm economy since the 3

great depression. Some large industries like ADM are finding it more econo'mical to generate their own fuel in the future and other enterprises are opting for cogeneration.

Coop member-owners are demanding rate relief from their coop boards either by directing their boards to conduct legal studies to determine the feasibility of breaking the all j power supply contract the coop holds with WIPCO (MJM); signing a petition directing the board to actively explore the feasibility of ' selling the coop to adjacent 'IOUs (Illinois Valley Electric coop received such a petition signed by over 3000 of their 5',500 members)

I or by trying to direct the board to cancel the WIPCO all power supply contract (Menard member-owners motion to that effect rejected for procedural reasons but coop attorney

! offered a counter-motion to conduct a study of the feasibility of breaking'the contract,

' t which the' member-owners approved). In addition, one coop board (Southwestern) has already j conducted such a feasibility study concerning their contract with Soyland.'

3

-e - - * -. , . . . , - + - . . , . _ . _ - , __,,_-_ ._ . _ _ , . , . _ . . _ . . , . _ , _ . . _ . , . . - . . , , . . . , , _ _ _ _ . ~ , . - . _ . , . _ , . , . . _ _ _ _ , _ _ _ , , _ . ,

t  :

The evidence in the preceding paragraph tends to run counter to and call into question the testimony given by an 1111nois Power employee (Tr.1001-02,'1033-34, ~1037) and Illinois Power (IP Reply Brief pp. 46-47) that electric sales are expected to grow in the coop territory with farmers contributing to much of this growth. Even one of the two coops that services an area described as experiencing " substantial i growth" (IP Reply Brief p. 47)-Corn Belt Electric--sold fewer:KWH in 1983 than it  !

did in 1980. If indeed there was growth in this part of the coop's territory cited I

by IP, it was more than counterbalanced by decline in other parts of the coop i

territory. In fact, this pattern was identified in many enumeration districts and townships in vhrious coops in the WIPCO area during our study;a coop gain in urban fringes was more than compensated for by loses in coop load and customers in the

, more outlying rura1 areas. In addition, most of the coop members lost in the rural I areas lived in large relatively o1d farm houses-observed in our studies as abandoned; whereas, most of the new coop members on urban fringes lived in newer, smaller homes

! with much more insulation and weatherization in them than the old farm houses--many of which had no insulation in the walls and little,1f any, in the ceiling. The farm residents very likely used much more electricity for their business and in the farmhouse than the new coop residents use in thqir smaller, better insulated homes. Furthermore, O it is hi.h17 uniixeir that newer farmhouses bu11t on the farm site use more erectricitr i chan the old leaky farahause. In addition, less electricity rather than more electricity is being used in the farming areas, as larger farmers buy up the acreage of the departing farmers, abandon their old residences, and use their gasoline-driven machinety to till the soil and harvest the crops. Indeed, as we discovered in our study, these larger farmers were more likely to switch to energy alternatives more economical than electricit) than many of the smaller farmers--because they had more discretionary capital to invest in these alternatives. Furthermore, they simply could not afford the large' economic loss

) , caused by significantly higher electric rates; economies of scale in fact drive down electrical consumption in rural areas rather than' the opposite. This evidence con'flicts lwiththecontentionsofIllinoisPower(IPReply'Briefp.47andTr.1033-34,1036)that

' electricity usage in farming areas increases with mechanization and replacement of farm l houses with newer homes on site or in urban fringes. The energy use patterns' of farmers' i

are significantly different from non-farmers; net income can not be used as an indicator of electric usage--and the same conservation factor should not be used for farmers and non-farmers as Illinois Power does (Tr. 1117). Electricity sales in coop territories-- '

and'likely in Illinois Power rural aress--will continue to decline because of shifting demographic trends significantly accelerated by the large electric rates which push l

the twenty-two distribution coops--and WIPC0 and Soyland--closer to insolvency since the coops are unable to sell enough electricity at these high prices that they need to charge because of Clinton-related costs passed on by WIPCO and Soyland in the cost of power. Then WIPCO and Soyland will be unable to meet their financial and contractual obligations--as distribution coops fall away and the remaining coops are unable to assume the large debts. Therefore, the ICC should consider any contractual agreement between the two G&Ts and IP void--including the Oct. '84 agreement--and any financial' arrangements'between- these entities nonaexistent'isrtheir : evaluation of the economics of cancelling or completing Clinton. As such, the cancellation case for Clinton is even more economically feasible that has heretofore been clearly demonstrated in this docket.

In the face of this fiscal crisis. WIPCO and Soyland on May 16, 1985 refused to authorize Illinois Power to release WIPCO and Soyland's load forecasts for considera-

~

tion in this docket. Therefore, we need to rely on two documents to estimate the future load forecasts and electricity prices for WIPCO--the W1PCO commissioned March 1984 "1984 Power Requirement Study", which projects a 24c/KWH retail rate for WIPCO distri-bution customer's if Clinton is completed by 1986 and the 1984 WIPCO Annual Report which contains a table labeled " Demand and Energy: Actual and Estimated Future".

This table shows VIPCO demand and energy sales slightly declining from 1985 to 1988 and for some reason, signifi.antly increasing in a unilinear fashion to the~end of the scale in 1996 when energy demand reachs about 190 Megawatts and energy sales reach about 780,000 Megawatt Hours-up.from 135.7 Megawatts of demand and 583,600 Hegawatts in energy sales in 1984. No reason is given in this document for'these dramatic increases. Indeed, evidence seems to indicate that such a trend is very speculative and quite optiilistic; any projections'that far into the future, given-

~

changing energy use patterns are very questionable.

j It is more significant that the WIPCO projection concurs,with the "1984 Power Requirement Study" in its projection that "... price increases in future years will also cause negative growth in energy sales during the 1984-88 period. It is an'ticipated that many customers will convert electric heating' systems and electric watier heaters to oil or gas systems as a result of the price increases." (p. 1).

Given this declining trend in electric use, one wonders why electric use will i

accelerate towards 1990 while rates are increasing to 24c KWH7 It should be noted that the Oct. 1984 agreement will moderate rates for coop customers an officially ~

estimated'4C KWH--an amount that seemed large to Illinois Power's' Mladiner iTr.1013) and

~is being contested by some coop member-owners. However, even given thie moderat:ionI

^

coop rates are projected to be 20c/KWH by 1990-which is precisely the price at which today active solar photovoltaics are expected to be cost effective, acc'ording to general knowledge and corroborated by Mladiner (Tr. 1035). In essence, WIPCO's

,,.eJ O Pro 3ections berend 1988 are verv sPecu1stive and iven the 1 arse retait rates their distribution customers will pay then--even more dubious. It is more likely that sales will continue to decline as rate shock, price elasticity and insolvency set in then if not before. Indeed, the size of the total Clinton debt in relation to the net assets of both WIPCO and Soyland wilt accelerate their economic demim..

For example, WIPCO's net assets in 1984 were $386,129,092 (1984 WIPCO Annual Report) and they are faced with a capitalized debt of at least $455,000,000 when and if Clinton comes on line-in addition to the $38,000,000 paid by WIPCO customers from 1984-86 in a surcharge now 2.4c/KWH and projected to rise to 3.6c/KWH in 1986 to cover interest on interest to carry the debt to the point of capitalization. This is a capitalized debt of over $10,000/WIPC0 distribution coop member-owner. Interest .

payments alone on this debt are projected tp cost 9C/KWH. Finally, the coops' Clinton share declines as the total Clinton capital costs rise; the coops share is now 17% .

--or 162 MW at $5800 KW. When the Clinton costs rise to $3.148 Billion, the coops share of Clinton will be 14.3% --or 136 MW at $7,000 KW. If Clinton costs rise to

$3.5 Billion as Vos contends, the coops' share of Clinton will shrink to 12.9%-or 124 MW at $7,700 KW or if Clinton costs go up to $4 billion as V0B contends and O se as ti*e1. 7 the c Ps's* re er c11nten witt ee 113x--er to7 #w at sa.9ao xv.

The state of Ohio cancelled the Zimmer plant when it was 97% complete because it was uneconomical, Michigan cancelled the Midland plant and Initiana cancelled the Marble Hill plant for similar reasons. Illinois must follow suit and cancel Clinton .

Unit 1 because it is not economical to complete. It is simply too expensive; no-one ,

can pay the bille now and especially in the future. We have two options: 1) The plant will cancel itself in the future over the wreckage of insolvent coops and many bank-rupt farmers--and lawsuits, or 2)I hope that Illinois Power Company and the' Illinois Commerce Commission will have the courage to cancel Clinton now and avoid at least some of the future costs and litigation and I hope that they will have the the vision to implement cancellation in the most humane and equitable way possible. The time '

has come for everyone to stop fighting everyone and for us all to come together with the realization that Clinton Unit 1 is simply an imprudent investment-cancg1 it, divide up the debts equitably and expediously and be on with the business of meeting 1111nois's future energy needs. IP can survive; the bills can be paid--shareholdars, customers, the coops REA and IP can divide up the debt. We don't need sacrificial lambs or s'capegoats; we need prudent, honest, forthright, open, visionary, courageous.

O hum.no and coo,-auve acuon. Oay then can the fut-e debaue be avaded..

e e J Submitted as part of request filed in ICC docket # 84-0055.

Sept. 12, 1984 h 1, Roger Batz, having been sworn and upon oath do state the following:

1. I am an Associate Professor of Sociology at Principia College in Elsah, Illinois.

I earned a B.A. in Psychology from Oberlin College in 1962, an M.A. in History f rom Central Michigan University in 1967, and a PhD in Sociology from Louisiana State University in 1974.

2. In June 1984, I completed a study entitled Socio-Economic Impact Analysis of Electric Rate Increases in Rural West Central Illinois. This research project, which involved interviewing a random sample of 1019 WIPCO customers, was autho-rized by Principia College. The study has been selected for presentation at the 1984 meetings of the Society for Applied Sociology and the Illinois Sociological Association *.

N 3. The purpose of the study was to assess the impact on WIPCO's 44,000 customers of 3.arge ciectric rate increases because of WIPCO's ownership of 9.5% of the Clinton Nuclear Power Plant. Upon completion of the C1fnton Nuclear Power Plant Western Illinois Power Cooperative (WIPCO) of ficials state that rate payers in west central Illinois rural electric cooperatives will face a doubling of rates--from the present 8 cents /KWH to at least 15 cents /KWH. WIPCO has invested about $300 million in the plant and expects to spend a total of about $440 million--$10,000 per' customer /

owner.

Most coop rate payers are farmers, many of whom are already at the margin of failure.

Double or more electric rates will increase the severity of their economic condi-tions. It is not known how many rate payers will start investing more heavily in conservation measures, shif t to wood or gas as fuels, and/or install alternatives kg such as solar cells or wind machines to generate residential electricity. Costs of

i \/

(~)

solar and wind alternatives are decreasing and are expected to cross below the costs of nuclear electricity in a few years. By studying the energy use behavior of WIPCO customers, we will forecast the size of the coming market for conservation techniques and alternative energy methods. The Rcral Electrification Administration (REA) has encouraged further research on the impact of Clinton--including this project; the total study is designed to give needed information to REA, WIPCO and its customers.

J

4. The results indicate that there is an excess of electricity throughout the Midwest area, the population is declining in the WIPCO region (because of poor economic conditions and farm foreclosures), and WIPCO is selling less electricity than it did two years ago, Furthermore, individual customers have gradually used less electricity over the.past few years as rates have gradually risen. If rates double or more, 80%

!( ) of the customers will use less electricity and/or switch to combinations of available energy sources, usually because they are cheaper (wood or gas) or will be cheaper (wind or solar) than the projected coop electricity cost.

Rural farmers and non-farmers were very aware of energy costs and were determined to select the most cost ef fective energy sources; many already relied on two or more energy sources on the farm and/or in the home. 25% already use wood as their main home heating source--usually supplemented by gas or electricity; another 9% use wood as a secondary source. Retail electric rates have increased gradually over the years. Such gradual increases in electric costs were correlated directly with cus-i tomer shif ts to alternative fuels, increased insulation and weatherization of homes,

' and decreased use of electricity; rate shock was not needed to initiate changes in energy use. Many people felt alienated f rom community and organizational power

() structures and were angry that decisions were made without their advice or consent.

(v"h More people would like to see Clinton cancelled than wanted it completed--mainly because of its cost.

Rural electric cooperative members told us that they would, quietly or noisily, cut back or shift their energy base from electricity to alternatives, because of the cost of electricity, a desire to be independent of others, an unwillingness j to pay for the economic mistakes of others,and/or general anti-nuclear reasons.

In short, the coop electric sales in rural areas served by WIPCO will decrease regardless of whether there is an immediate rate shock or a gradual rate increase associated with Clinton expenses. Farmers and non-farmers will cut back and/or switch in direct response to the amount of electric rate increase. To gradually increase electric rates in order to pay for Clinton construction and/or interest costs will only magnify the problem--particularly given the distrust and alienation towards REA and others felt already by WIPCO customers.

Since the population is declining in the.WIPCO area, electricity usage is decreasing among WIPC0 customers, and since people say that higher electric rates will further cut their ciectricity use, it is unclear if WIPCO will be able to sell enough electri-city to cover their Clinton debts. One of the largest (if not the largest) WIPCO electric rate hikes occurred on May 1, 1984; in an unprecented move, REA allowed an immediate 1.2 cents /KWH "CWIP" (about 15% rate increase) for all WIPCO customers--

with another 1.2 cents /KWH planned for 1985 and 1986 for a total projected rate increase of,about 45%--in order to recover in the next three years $38 million in interest related to Clinton costs. Rate shock, price elasticity and eventual insolvency are still future possibilities--which would have serious repercussions on Soyland and Illinois Power Company.

O On month after this study was completed, a merger between WIPCO and Soyland was proposed by the Soyland and WIPCO boards of directors which--before it is ef fective--

~4-must be approved by 2/3 of the distribution cooperatives of each of the two genera-tion and transmission cooperatives. WIPC0 officials state that they do not know if WIPCO can survive without a merger, l

f i i  !

The impact of Clinton's costs on electric rates of Soyland and Illinois Power and

! on the electricity demands of Soyland and Illinois Power customers needs to be 4

carefully considered--particularly given the additional WIPCO costs that may have

$ to be assumed by Soyland's customers if the proposed merger is approved. It is

questionable whether the two generation and tran,smission cooperatives will need--

or be able to pay for--all of their Clinton power, plus the 400,000 KWH that they will receive from Illinois Power because of their recent agreement with Illinois Power Company.*

In addition, officially estimated KWH costs for Clinton don't include unexpected l operation and maintenance costs for the nuclear power plant during its 20-30 year lifetime. Other GE boiling . water nuclear power plants have had problems with cracking 4

pipes which have resulted in costly shutdowns; perhaps, new NRC regulations will lessen such difficulties, but nuclear technology is very complex nd still developing, i

Finally, the nuclear industry is now in the midst of its most severe crisis with i

various utilities discussing bankrupcy because of cost overruns on nuclear power

! plants; other plants such as the Zimmer plant, the River Bend plant, the Marble Hill i plant and the Midland plant have been recently cancelled. Rural electric cooperatives associated with some of these nuclear power plants face fiscal crises similar to i

WIPCO's and Soyland's.

Many of the results of this study can probably be generalized to Soyland customers l

!O i e th v 1 etr < r a tiv i re satz 1 11 8r eaie 1 i-l-

the same state; they also have a share of Clinton. As such, Soyland customers will also experience rate increases because of Clinton costs--even though they can distribute

)

,...e..

J

( their 10.5% investment costs over twice as many members as WIPCO can. However, more research needs to be done to determine the degree of similarity of socio-economic, ecological and energy-use factors in the two generation and transmission l cooperatives before WIPCO results can be fully extrapolated to Soyland. Furthermore, i

many of these WIPCO results can reasonably be applied to Illinois Power customers who live in rural areas; although their rate structure is different because they have a larger share of CWIP. in their rate base, they will experience gradual, yet I significant, rate hikes over the next few years because of Clinton construction costs.

These rate hikes could very well trigger a gradual decrease in their electricity con-sumption--particularly as they see their coop neighbors switching to alternative i

energy sources, i .

O v

1

' Further affiant sayeth not.

x 1

R er Batr so I

%> dLw$,. -C w Y /

a d\

M p,iq ep M7fAW PUGUC, STATE of ItllN013 M? QvwS 0N IINH1 Off 30, 1983 O

A

- Maybeck Place Elsah, IL 62028 Oct. 9, 1985 Director of Nuclear Reactor Regulatior U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Sirs:

I request that your department reevaluate you decision re. Illinois Power Co. ct al that was registered in the Federal Register on Sept.

13, 1985 to the effect that you found no significant antitrust changes which would necessitate a formal operating licence antitrust review of the Clinton Unit 1 Power Station.

I have been studying the Clinton situation for three years in various capacities; please see enclosures of my testimony before the ICC on Sept. 12, 1984 and the oral statement that I delivered on June 18, 1985. In addition, I have posted to your office a xeroxed copy of the complete study that I conducted--which is ref(rred to in the aforementioned testimony. These documents summarize my understanding of the situation as of June.

Since June, evidence has come to my attention which indicates that the coops are in dire fiscal crises--I have no hard facts in my hands to that effect, but know that others do.

It is highly likely that one or more of the 22 distribution coops will go into a chapter 11 bankrupey soon--and perhaps even WIPCO, since three of the seven coop boards now have a near majority of board members that were elected this summer of 1985 on an anti-rate / anti-Clinton slate.

In essence, the economic situation re. Clinton is in shambles. The October 1984 accord between the coops and IP will be vigorously challenged by myself and others in the ICC docket 84-0472 which is in process. We, the member-owners of the 22 distribution coops, are being constrained to participate in an-power purchase agreement with WIPCO and Soyland--who are locked into an 111 fated investment in the Clinton plant. The Oct.

?.984 accord hurts both IP and coop customers; IP customers have to assume more of the capital costs for Clinton and the coop customers have to pay more for,the fewer kw that we will get for Clinton electricity as our percentage of ownership decreases.

I urge you to investigate the financial records of all 22 distribution coops and WIPC0 and Soyland before you rule that indeed the competitive climate has not changed in Illinois re. IP and Clinton. In a few months, some of the coops may sell out to investor-owned utilities, go into chapter 11, and/or reorganize themselves into new entities. All of these activities will effect IP's fiscal status re. Clinton.

1 therefore, urge that you review your decision in this case. I remain available to work further on this issue as seems appropriate.

Co ially.

A R er B tz, Phd

Enclosures:

Sept. 12, 1984 and June 18, 1985 ICC testimony of Batz.

Illinois coop map.

~

Electric Cooperatives ofIllinois Good for ALL lilinois

""'"" ~ * ~ ~ ~~~ '~'

plied l b y .. .

so corran .

ruI l Da1 y 1"5'n d "'" j"" j  ;

m W

3

. .*** F artniles M s .... . g r- IIHnols VeHey Electric ] _

La a*.

L_ l E le. t,6c **'"""*

7^ S e , - - -

.n .

k-- 6;, .

i= - ' } Q . .. e.

l_,

• j

,/(( f ,

S ,F )

. . .. . y . E.se,r, ,1,,no,.

3 8 '

/j Po**'

cDonough , /; _

g

, P owe.r e .e . p ..==.*.rn e ~

6Mb

..,,..e Corn E eit Electric E "

. s_

r e'

< ~

I f' l{.L....

/ Iliini Electric Og / "*

Association of IHinois j //f j .

S f I sr 3 (E"C*''''

Springf6 eld V * ~

%  !%'c""l

, she, ColeWoultrie

?, Electric c"' s..

• Decetur r, . ... i. , n . n.nois. ..e

.. .. . ; r...o.r.

- s,i e, ,,,, ,E i;c,i,r,r,c,,,

z. . . . ..H l

yc -

S

> ()&

l mess.-

s) Ni

. E.lectr6 t

sovih. [e,n S g Supplied

. ., mm E ,.e,,,9 og -

gi.

..E- lec.tric

_.... ... -. .c,Ico.n n te r, t, . f, 1

E le W _

Wctric ---*

s Monro . ..,S..) Tricounty siestrie g weyriewhat. I cogryn ,., g '~~*

.- I a

-C S E,les trie I

i d P E.Jy..:"~'-M m (ND.

3 Eieettle -

.~ - M

$oI"*c"oS'$re'i,,e

. ue,,eon

'- SIPC southeeinern tule oie Elastric f

l

.. 0%rl

[ l. S Pr e , ,,,,, , e , , ,,, ,, n. , n . ,e, e .

heedquerter8 3. located

,_ _ ._ - , . . _ . , _ . . . . _ _ . _ _ _ , , _ . . _ . . , _ , . , _ _ _ , _ . . ..__,.__.,___.___,_,____.m__.__._____.,,. _ , . , , _ . _ - . _ _ . _ _ - ,