ML19308A404

Testimony in Response to Tx Utils Generating Co & Houston Lighting & Power First Set of Interrogatories

ML19308A404
Person / Time
Site:	South Texas, Comanche Peak
Issue date:	08/01/1979
From:	Gross R PSI ENERGY, INC. A/K/A PUBLIC SERVICE CO. OF INDIANA
To:
Shared Package
ML19208C305	List: ML19208C304 ML19208C306 ML19208C308 ML19208C310 ML19208C312 ML19208C314 ML19208C315 ML19208C322 ML19308A389 ML19308A390 ML19308A391 ML19308A392 ML19308A393 ML19308A398 ML19308A399 ML19308A400 ML19308A401 ML19308A402 ML19308A403 ML19308A404 ML19308A405 ML19308A406 ML19308A407 ML19308A409 ML19308A410 ML19308A412 ML19308A413 ML19308A414 ML19308A415 ML19308A416 ML19308A417 ML19308A418 ML19308A419 ML19308A420 ML19308A421 ML19308A422 ML19308A423 ML19308A424 ML19308A425 ML19308A426 ML19308A427 ML19308A428 ML19308A429
References
ER76-149, NUDOCS 7909260162
Download: ML19308A404 (10)

Text

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PUBLIC SERVICE COMPANY OF U DIANA, INC.

FPC DOCKET NO. ER76-149 PREPARED TESTIMONY OF ROEERT M. GROSS, JR.

l 1 Q PLEASE STATE YOUR NAME AND ADDPISS.

2 3 A My name is Robert M. Gross, Jr.

My business address is 1000 Crescent 4

Avenue, N.E., Atlanta, Georgia 30309.

5 6Q WHAT IS YOUR EDUCATIONAL BACKGROUND?

7 8A I graduated from Georgia Institute of Technology in 1965, receiving 9

the deF';ee of Bachelor of Industrial Engineering.

I also attended 10 Georr,la State University. and in 1971 received the degree of Master 11 of Basiness Administration, majoring in finance.

12 13 Q P1 EASE STATE YOUR PROFESSIONAL EXPERIENCE.

14 15 A I have been employed by Southern Engineering Company of Georgia for 16 a9 proximately eight years.

During this time I have been involved in 17 the Preparation of cost of service studies of investor-owned utilities, 18 rural electric cooperatives and municipal syste=s and hr.ve participated 19 in cholesale and retail electric rate consulting assignments in 23 20 states.

I am a registered professional engineer in the State of Georgia.

21 22 Q HAVE Y0l' EVER TESTIFIED IN OTHER COMMISSION PROCEEDD;GS?

23 24 A Yes, I have testified as a rate expert and cost of service witness 25 before the State Co= missions of Kentucky, Indiana, Michigan, Vermont k

26 and Virginia.

I have also testified before the Federal Power Co= mission 27 in proceedings involving the Missistioni Power _ Comoany, FPC Docket No.

28 E-7625; Central Vermont Public Service Corporation, FPC Docket No. E-7685; 29 A_ppalachian Power Company, FPC Docket No. E-7775; Duke Power Company, 30 FPC Docket ljo. E-7994; Gulf States Utilities Comnany, FPC Docket No.

31 E,-8121; Gulf Power Comoanv, FPC Docket No. E-8911; Appalachian Power 32 Company, FPC Docket No. E-9101; Vircinia Electric & Power Comoany,

3 FPC Docket No. E-9147; and Arizona Public Service Company, FPC Docket y,

No. E-8624, 35 36 Q BY mIOM IS SOUTHERN ENGINEERING COMP /GY RETAINED Di THIS PROCEEDING?

37 A

Southern Engineering Company is retained by Wabash Valley Electric 38 39 Power Association (Wabash) and the,13 Indiana Electric Membership 40 Cooperatives; the Indiana Municipc.1 Electric Association (I.M.E.A.

41 Cities); and the five muni:ipalities to which PSCI provides partial electric service (Interconnected Cities). Witnesses Solomon, 42 43 Chayavadhanangkur, Livingstone, Stolnitz, and I will be Southern Engineering Company's witnesses in these proceedings.

44 45 46 Q WHAT WAS YOUR ASSIGNMENT IN THIS PROCEEDING?

47 48

^ My assignment was to review direct testimony, exhibits and other avail-49 able information of Public Service Company of Indiana, Inc. (PSCI) 50 concerning the cost to serve PSCI's wholesale customers.

Specifically

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-possaol6 *'

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I was to consider whether the methods employed by PSCI for Period I i

2 and Period II to develop the overall Company cost of service and-3 the allocation of cost of service (in Statements "L" and "M" for 4

Period I and Period II, respectively) are proper and according to 5

Commission precedent and sound ratemaking procedures.

In addition, 6

based upon the adjustments to PSCI's cost of service which were found 7

necessary by other witnesses, I was to prepare an overall cost of 8

service study which accurately reflects the rates of return which are t

actually being earned by PSCI under its present wholesale electric 9

tariffs 10 ud which will actually be earned by PSCI under'its proposed wholesale electric tariffs.

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12 13 Q WIIAT DATA IIAVE YOU REVIEWED IN PREPARING YOUR TESTIMONY AND RELATED 4

14 EXIIIBITS?

I 15 16 A I have reviewed those portions of the Company's filing which relate 17 to its cost of service studies, including testimony and exhibits of 1S PSCI's witnesses and other information which PSCI s'upplied in response 19 to the FPC Staff's and the Intervenors' request for data.

20 21 Q WOULD YOU BRIEFLY SUMMARIZE THE CONCLUSIONS WHICll YOU AND THE OTHER 22 WITNESSES FOR THE INTERVENORS II/NE REACHED AS A RESULT OF STUDYING 23 PSCI'S COST OF SERVING ITS WHOLESALE CUSTOMERS.

j 24 25 A The cost of service studies presented by PSCI in this proceeding sig-26 nificantly overstate the cost of serving PSCI's wholesale customers.

27 The following major errors have been'made by PSCI in its Period II 28 cost of service study', necessitating adjustments by the intervenors:

29 j

30 1.

PSCI's use of the average of the beginning and end of year 31 electric plant-in-service account balances to determine the t

32 plant investment 1cyc1 for the test year does not accurately 33 reficct the overall average investment in PSCI's plant in 34 service for the test period, i.e., the twelve months ending 35 June 1976.

The most accurate method is the use of the 13 36 m nth average of plant-in-service balances.

37 38 2.

PSCI improperly included in its rate base amounts for com-i 39 pensating bank requirements as a component of its cash work-40 ing capital.

41 42 3.

As testified to by Mr. Solomon, PSCI's method of accounting 43 for revenue derived from the application of the Company's 44 fuel cost adjustment provision does not properly match cuch 1

l 45 revenues with fuel expenses incurred during the test period 46 (Period II).

47 l

48 4.

As testified to by Dr. Livingstone, PSCI has inflated its rate 49 base by improperly calculating rates for Allowance For Funds 50 Used During Construction.

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5.

As testified to by Dr. Livingstone, PSCI has improperly 2

computed the deduction from income taxes for interest 3

expense associated with both long-term debt and notes 4

Payable for Period II.

5 6

6.

As testified to by Dr. Livingstone, PSCI has improperly 7

normalized its treatment of the income tax effect of 8

Account 283 and portions of Account 282.

9 10 7.

As testified to by Mr. Chayavadhanaugkur, PSCI has assigned 11 a disproportionately large amount of transmission plant and 12 associated expenses to its wholesale customers. Moreover, 13 some transmission facilities were specifically assigned by 14 PSCI to wholesale customers on a basis that differs from 15 that on which assignments were made to the retail class of 16 customers, even though such transmission facilities used to 17 serve retail customers are functionally similar to trans-18 mission facilities used to serve wholesale customers.

I 19 have adjusted for these inequities by using the " rolled-in" 20 method of transmission plant allocation.

21 22 8.

As testified to by Mr. Chayavadhanangkur, PSCI overstated 23 purchased power expense for the test year by underestimating 24 it s ability to make short term sales to interconnected utilities.

25 I have reduced Period II purchased power expense according to Interven r's Exhibit (JC-1).

26 27 28 Q HAVE YOU PREPARED COST OF SERVICE STUDIES WHICH SHOW THE EFFECTS OF THE 29 INTERVENORS' ADJUSTMENTS ON THE RATES OF RETURN THAT PSCI EARNED UNDER 30 THE PRESENT WHOLESALE TARIFF AND WOULD EARN UNDER THE PROPOSED WHOLESALE 31 TARIFF?

32 33 A I have prepared an exhibit which shows the effects of intervenors' cost 34 of service adjustm2nts.

Intervenor's Exhibit (KMG-1), entitled " Cost 35 of Electric Service Study, Public Service Company of Indiana, Inc.,

i 36 Year Ended 6/30/76 (Period II) Adjusted Cost of Service," incorporates 37 all of the adjustments that must be made to PSCI's study to reflect 38 accurately the rates of return earned under the present tariffs and 39 proposed tariffs as shown on Schedule 1, Page 1.

40 41 Q WOULD YOU PLEASE EXPLAIN WHY YOU USE THE AVERAGES OF TIE 13-MONTHLY 42 BALANCES INSTEAD OF THE AVERAGES OF THE BEGINNING AND END OF YEAR 43 BAIANCES IN DETEPMINING THE TOTAL RATE BASE FOR PSCI FOR PERIOD II.

44 45 A In determining its rate base, PSCI has used the average of the beginning 46 and end of year balances for electric plant in service, depreciation 47 reserve, plant held for future use and accumulated provision for deferred 48 taxes. The averages of the beginning and end of year balance yields an 49 approximation of the electric plant in service during the test year which 50 in some cases may be adequate for ratemaking purposes. Generally, however, I

1 it is recognized that the proper synchronization of revenues, expenses 2

and electric plant in service can be accomplished only by matching the 3

monthly plant-in-service balance with the billing periods, which are 4

the Periods of metering for sales to wholesale customers.

Billing is 5

d ne n a m nthly basis. Therefore, a monthly average is the most 6

accurate method for synchronization of the expenses during the month, 7

the energy produced during the month, and the revenues collected during the month. The average of the 13 electric plant in service end of g

9 month account balances accomplishes this monthly averaging, since the beginning balance and the ending balance of each month during the test 10 period is weighted equally in the co:nputation. Moreover, the 13-month average method avoids the necessity of determining how to properly weigh large or irrcgular additions to plant which are placed in service 13 during the test period. The 13-month average method, therefo're, is more 14 accurate for matching revenues and expenses with the facilities in service 15 during the test year.

i 16 17 The relative superiority for ratemaking purposes of the 13-month average 18 method is demonstrated by its use in calculating PSCI's rate base.

19 Applying that method to the latest data available from PSCI on its 20 estimated monthly net plant balances for Period II produces the following 21 average net plant amounts:

($1000) 22 23 Production Transmission Distribution Gennral 24 25

$497,570

$194,578

$235,241

$35,119 t

26 27 These figures compare with the Company's beginning and end of year net 28 plant balance averages as follows:

($1000) 29 30 Production Transmission Distribution General 31 32

$533,233

$ 191,694

$236,328

$35,369 33 34 My calculations thus show that the Company's method appears to be ade-35 quate for all functional net plant in service balances except for pro-36 duction and transmission plant.

The $35,662,000 difference between 37 PSCI's figure for net production plant and my figure is due to the in-38 service date of the Gibson No. 1 unit.

PSCI's beginning and end of 39 year ' average method of calculating plant-in-service attributes the g

Gibson unit to be in commercial operation throughout 1976, although 41 in preparing its Peri d II t st year projections, the Company. estimated 4,

Gibson Unit would not be in con =iercial operation until the month th of April 1976.

In f act the Gibson Unit #1 became con:nercial on May 3, 43 1976.

I have adjusted the 13 month average to reflect the actual May, 1976 in-service date. When PSCI computes its rate base using the 45 beginning and end of year plant in service balances, it seeks a return 46 on the Gibson Unit investment as if it was in service for 6 months of 47 the test year rather than the two months in which it was actually in 48 service.

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It should also be pointed out that although most units generally are 2

of some value prior to comnercial operation because of test energy, 3

the company has recognized that value by increasing miscellaneous 4

steam power expense (FPC Account 506) $1,016,000 for the " fair value" 5

f the estimated kilowatt hours produced in the pre-operational 6

testing of the unit.

(See Response to question 2b of verbal request to Mr. C. W. Campbell at the p(re-hearing conference held on May 25, 7

1976 Intervenor Exhibit RM3-2)).

)

8 9

10 Add'itionally, prior to final co=nercial operation, the Company con-11 tinues to capitalize its Allowance for Funds Used During Construction.

12 so that the final capitalized value of the plant-in-service reflects 13 capitalized AFUDC incurred during the period January through April of 14 1976.

Over the life of the facilities, the Company will recover these 15 costs through depreciation and return on rate base. Therefore, to allow 16 the Company to calculate its rate base on a beginning and end of year 17 production plant investment balance results in this case in a double 18 return to the Company. PSCI would earn a full return on the weighted 19 value of Gibson included in the rate base representing the pre-commercial 20 period January through April.

PSCI would also capitalir.e AFUDC on the 21 Gibson investment for the same January to April period, see Intervenor's 22 Exhibit (dig -3) ).

23 24 The averaging of the 13-monthly plant balances eli.ninates this overlap 25 and provides for a proper relationship between plan'.-in-service for i

26 rate of return purposes and AFUDC taken on pre-commercial investment.

l 27 23 FPC precedent dictates the use cf the 13-month average plent balance l

29 method. For example, the Commission required the use of the 13 -month 30 average in Mississioni Fuel Corporation, 11 FPC 288 (1952), Idaho Power 31 Company, 46 FPC 364, 420 (1971) and most recently in Connecticut Licht 32 U Power, 1976 FPC Docket No. E-7743, Opinion No. 761.

33 34 Clearly, both logic and precedent, as well as good ratemaking procedures 35 require the use of the 13-month average net electric plant-in-service 36 in PSCI's cost of service for production and transmission plant balances.

37 38 Q HAVE YOU PREPARED AN EXHIBIT WHICH SHORS THE DEVEIDPMENT OF THE 13-MONTH t

39 ACCOUNT BAIANCES THAT YOU DIPLOYED IN YOUR COST OF SERVICE STUDY?

i 40 41 A Yes, Inturvenors' Exhibit (RMG 4) contains the development of the 4

42 monthly account balances which I used for gross plant-in-service, and 43 accumulated reserve for depreciation.

The Company was unable to provide 44 monthly balances for deferred taxes, therefore, I have used the beginning 45 and end of year average.

46 47 Q YOU STATED THAT PSCI'S PERIOD II COST OF SERVICE STUDY WAS BASED ON AN 48 ESTIMATED GIBSON #1 ComiERCIAL DATE OF APRIL,1976.

49 50 A Yes. - -

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l Q WHAT IS TIE IMPACT ON PSCI'S COST STUDY AS A RESULT OF THE ONE MONTH 2

DELAY IN GIBSON #1 COMMERCIAL OPERATION.

3 4 A In addition to the impact on PSCI's Rate Base, test year depreciation l

5 and purchase power expense must be adjusted for this delay, (see 6

Intervenor's Exhibit (RMG-4) Page 2). I have reduced test year 7

depreciation expense by $302,000, which represents one month of g

depreciation expense on Gibson #1.

Additionally, Mr. Chayavadhanangkur 9

has provided revised purchase power expense amounts, as shown on 1

10 Intervonor's Exhibit (JC-1) for the test year, which in part show i

11 the impact on PSCI's interconnected utility transactions as a result l

12 of the unavailability of Gibson #1 during the month of April, 1976.

13 14 Q MR. GROSS, DO YOU AGREE WITH PSCI'S DEVELOPMENT OF ITS WORKING CAPITAL 15 REQUIREMENTS?

16 17 A No. PSCI overstated its cash workine capital recuirements and therefore 18 its rate base by the inclusion of $2,572,000 for minimum bank balances.

19 20 Q WHY DO YOU DISAGREE WITH THE COMPANY'S TREATMENT OF MINIMUM BANK BALANCES?

21 A There are several reasons why I disagree with PSCI'.s inclusions of mini-22 mum bank balances as a component to cash working capital. First of all, 23 PSCI's witnesses state that the normal cash working capital allowance of 24 25 45 days of annuc1 operation and maintenance expense less purchase power 26 is not sufficient to provide enough, cash to fulfill compensating bank 27 balance requirements.

I have carefully reviewed the testimony and 28 exhibits of the Company's witnesses and I find no studies prepared'by 29 the Company showing that the standard 45 days' cash working capital 30 allowance is deficient.

I believe that if additional cash working 31 capital amounts, over and above the standard 45 days allowance, are to 32 be included in the rate base, then PSCI must show a detailed analysis 33 of its total cash working capital needs based upon all cash receipts 34 and disbursements.

35 36 This Commission has consistently limited the cash working capital 37 determination to the 45 days allowance. Any attempts to expand or 38 reduce the 45 days allowance through specific treatment of any one 39 item, has been met with the requirement to show all cash flow leads 40 and lags (with the exception of FIT Accruals, prior to Sierra Pacific 41 Power Company,0 pinion No. 730).

Particularly, the Commission has 42 rejected the specific addition of compensating bank calances in some 43 cases because of the availability of counterbalancing amounts of cash 44 generated through certain accruals.

Along this line, PSCI has not 45 made a showing that cost free funds from tax or other accruals would 46 not be continually available for bank deposit and thus act to satisfy 47 fully any requirement for compensating balances.

48 ARE l CI'S MONTHLY TAX ACCPUALS OF A SUFFICIENT AMOUNT TO COUNTERACT

• 49 Q

o 50 THE $5,572,000 STATED MINIMUM BAIE BALANCE REQUIRD4ENT?

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1A From the information that PSCI has provided, I find that the tax accrual 2

balance for June 30, 1975 (beginning of the test year) was $19,894,000 3

and the estimated June 30, 1976 balance to be $17,299,000. These amounts 4

were taken from Volume 9, Schedule 4, Sheet 1 of 1 of PSCI's initial 5

filing. The beginning and end of year figures do not provide an accurate 6

measure of the continuous amounts available to PSCI because of tax 7

ceruals.

I have prepared Interonor's Exhibit (RMG-5) showing for 8

the twelve -month period, April 30, 1975 through March 30, 1976, the actual 9

monthly tax accrual balances given by PSCI in its " Monthly Operating and 10 Stat.istical Reports." The average of the 12 monthly balances is shown to 11 to be $24,685,723. These balances are the result of PSCI's booking tax 12 expense on a current basis but with actual payment to the taxing entity 13 usually not due until some later date.

Since rates are based on current 14 tax expense, a cash leading situation develops as cash inflows from 15 revenues are received well prior to the actual cash disbursement to the 16 taxing entity.

17 18 It is obvious from this data that PSCI has a substantial amount of cash 19 available because of a large monthly tax accrual balance generated 20 primarily by local anm state real estate and personal property taxes 21 which ere expensed in the current period but are not payable until sume 22 later date. The Company's estimated tax accrual balances for the 12 23 months caded June 30, 1976, (Intervenor's Exhibit (PJ!G-6) shows that 24 PSC! has available considerable interest free accruals that result in cash 25 amounts which could and most probably are deposited in bank accounts and 26 indeed act to fulfill any compensating bank balance requirement.

27 23 Q DO YOU llAVE OTHER PIASONS FOR PIJECTING PSCI'S TREATMENT OF MINIMUM BANK 29 BAIMCES?

30 31A Yes.

Additionally, even if PSCI could make a showing that compensating 32 bank balances were of such singular significance that both the normal 33 45 days cash working capital allowance and other cash advances available 34 to PSCI, such as tax accruals, were not sufficient to fund the minimum 35 bank balance requirement, I still believe that it would be improper to 36 recognize this item as a ratemaking component. The Company witnesses 37 acknowledge that the requirement for compensating bank balances is not 33 a specific and absolute amount.

PSCI in its April 1976 Prospectus (Notes 39 to Financial Statements), Page 28, states that- "the Company has informal 40 arrangements with respect to maintaining average compensating bank balances...".

There is no apparent contractual relationship between the 41 42 Company and the bank with regard to maintaining compensating amounts.

43 Indeed PSCI Witness llovde indicates that there are methods other than main-44 taining compensating balances that can be used as a means of satisfying 45 a banking relationship, Mr. Hovde explains on Lines 42 and 43 of Page 3 46 of his testimony that cash fees could be used to replace the compensating 47 balances if the customer elected to do so.

PSCI, as most utilities, has 48 elected to satisfy its banking relationship by maintaining compensating 49 balances since apparently it is the most economical alternative available.

50 I question, however, whether it is the most economical alternative to 1

e 1

PSCI's customers if such amounts are included in the rate base. Using 2

PSCI's requested rate of return, the inclusion of the $5,590,000 com-3 pensatin,g balance in the rate base would produce an annual revenue 4

requirement of slightly more than $1,000,000 ( $5,572,000 x 9.35% +

5 50% = $1,042,000).

On the other hand, if PSCI clected to drop com-6 pensating bank balances and pay the bank a fee for services rendered, 7

then using Mr. Hovde's 6% " earnings allowance" shown on Line 53 of Page 7 g

of his testimony, a banking fee of $330,000 per year (6% x $5,570,000) 9 would be experienced by PSCI.

Obviously, from the customer's standpoint it u uld b f r more economical to compensate PSCI for its banking fees 10 annually as an expense item than to pay a full return on capital funds 11 PSCI professes to be tied up in compensating balances. This example 73 13 seems to emphasice to me the absurdity of PSCI charging its customers for 14 a full return on bank deposits when PSCI has not made a showing that such 15 deposits do not result from its normal day-to-day operations.

PSCI finds 16 that it is wholly practical and economical to use these amounts as 17 deposit s in ban > s rather than to pay a banking fee.

Certainly, PSCI 18 should not be allowed to charge its customer a full return on these 19 amounts particularly when PSCI has not made a showing of the true source 20 of funds used to maintain compensating bank balances.

21 22 Q UOULD YOU PLEASE DESCRIBE INTERVENORS ' EXHIBIT (RMG -7).

23 24 A This Exhibit rhows the details of the adjustments in Intervenors' 25 Exhibit (RMG-1) necessary to reflect the testimony and exhibit of 25 (JLL-1) Dr. Livingstone.

27 28 Q PLEASE EXPIAIX HOW YOU HAVE ADJUSTED THE THREE ITEMS REIATED TO COST OF 29 SERVICE TO WHICH DR. LIVINGSTONE TESTIFIED?

30 31 A I have incorporated the results obtained by Dr. Livingstone on the 32 three issues on which he testifies into the cast of service study that 33 I have prepared as follows:

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I have excluded from the rate base the electric plant 36 balance amounts which Dr. Livingstone says must be 37 excluded in a proper recognition of the allowance 38 for funds used during construction by PSCI since 1970.

39 I have functionally allocated the excessive annual 40 electric plant amounts based upon PSCI's proportionate annual 41 increase in its plant in service by functional category 42 as shown on Intervenors' Exhibit (RMG-7) Page 1 of 6.

43 44 2.

I have flowed-through the tax effect of Account 283.

45 Additionally, when PSCI provides requested information 56 on the nature of the balances contained in account 282, 7

additional amounts of test year tax differences may 48 also be flowed-through for cost of service purposes.

49 50 3.

I have inserted into the income tax calculation, for t

Y 4

1 utility operations, the level of long-term debt interest 2

expense and other interest expense as indicated by 3

Dr. Livingstone.

4 5 Q HAVE YOU MADE OTHER ADJUSTMENTS TO PSCI'S COST OF SERVICE STUDY?

6 7 A Yes, I have increased the test year revenues for each wholesale class 8

under the present and proposed tariffs in the amounts provided by 9

Witness Solomon (Intervenors' Exhibit (JBS-1)). These amounts 10 represent the one-month lag in revenues associated with current fuel 11 expense arising through utilization of the Company's fuel cost adjust-12 ment provision as applied to the ubolesale class in Period II, 13 14 In addition, I have incorporated in Exhibit (E3G-1) the transmission 15 allocation method change advocated by Witness Chayavadhanangkur.

I 16 have rolled-in and allocated uniformly all transmission plant-in-service 17 amounts and functionally related costs as described in Witness i

18 Chayavadhanangkur's direct testimony.

1 h.ve also adjusted test year j

19 pur^hase power expense in accords with Intervenors' Exhibit (JC-1).

20 I have also adopted the staff's adjustment eliminating the reserve for 21 power outage expense.

22 23 Q WHAT WEP2 THE PISULTS OF THESE ADJUSTMENTS FOUND NECESSARY BY THE 24 INTERVENORS' WITNESSES WHEN 1%DE TO PSCI'S COST OF SERVICE TO ITS 25 WHOLESALE CUSTOMERS?

26 27 A As a result of making the required adjustment to PSCI's cost of 28 service study for Period II, the rates of return that PSCI earns under 29 its present tariff for wholesale customers increases from 7.32%,

30 7.20%, and 4.69% for Wabash, I.M.E.A. Cities and Interconnected 31 Cities to 9.26%, 9.00%, and 6.50% respectively.

Likewise, the 32 rates of return that PSCI would earn from its wholesale customers 33 under the proposed tariff increases from 9.74% as shown in PSCI's study 34 to 11.86% for Wabash, from 9.75% as shown in PSCI's study to 11.69%

35 for the I.M.E.A. Cities, and from 9.72% to 11.96% for the Inter-36 connected cities.

37 38 Q WHAT WHOLESALE LEVEL OF REVENUES DO THE INTERVENORS RECOMMEND IS JUST 39 AND REASONABLE FOR PSCI?

J 40 I

41 A Using the proper rate of return (for overall cost of capital) of 8.35%

42 as testified to by Dr. Stolnitz, and the cost of service as adjusted 43 by the Intervenors' witnesses,.the a=ount of revenuas that PSCI would l

44 be entitled from Wabash is $22,015,058, by I.M.E.A. Cities'is $11,777,493, 45 and by Frankfort City Light and Power (only city of the Interconnected i

46 Cities group not protected by Mobile-Sierra Rule) is $1,338,094.

47 48 As can be seen from Exhibit (PJ3G-1), Page 1 o'

.50 PSCI is already 49 receiving revenues from each customer group in excess of these amounts.

50 Accordingly, PSCI is entitled to none of the requested rate increases 1.

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1 from these customers.

2 3

Although this exhibit shows en increase for the interconnected c1*ies 4

of crawfordsville, Peru, Washington and Logansport, I a:I advised by 5

counsel that these ccatomers are pintected from any increase by the 6

so-cclied " Mobile-sierra Rcle".

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