ML19208C314

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

ML19208C314
Person / Time
Site:	South Texas, Comanche Peak
Issue date:	08/01/1979
From:	Springs D GEORGIA POWER CO.
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
E-7679, NUDOCS 7909260036
Download: ML19208C314 (9)

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TESTIMONY OF ) AVID A SPRINGS FPC DOCRET NO. E-7679 1 Q PLEASE STATE YOUR NA'IE AND PLACE OF RESIDENCE. -

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2 A David A. Springs, 4514 North Peachtree Road, Chamblec, Georgia.

t i 3 Q UOULD YOU STATE YOUR EDUCATIONAL BACRGROUND, PLEASE.

4 A I was graduated f rom Georgia Institute of Technology in 1948 with a 5 Bachelor of Electrical Engineering Degree, and again in 1949, with

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6 a Degree of Master of Science in Electrical Engineering.

7 Q WOULD YOU STATE BRIEFLY YOUR ENPERIENCE.

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! 8 A Duriag graduate uork at Georgia Tech, I had the unique experience of 9 working 15 nonths as Assistant Operator of the Georgia Tech AC Network

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10 Calculator. At that time the calculator was the cost advanced tool

! 11 for studying the overall operations of power systens. This experience 12 gave me a very early understanding of load flow and stability problems

[ 13 on large utility systems.

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14 Af ter graduation I worked for Southern Engincaring Company in i

i 15 Atlanta, G2orgia, for approxinatel'y three years doug distribution 16 design work, transnission systen design and long range power supply 17 planning.

j 18 Frem 1952 to 1963, I w;1 with the South Carolina Public Service 19 Authority, first'as supervisor in charge of Wholesale Billing, and

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20 then for a period of six years as their Planning Engineer.

21 Since returning to Southern Engineering Coapany of Georgia in

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22 1963, I have been in charge of the P ter Supply Planning and Power 23 System Planning Section.

24 Q ARE YOU A REGISTERED PROFESSIONAL ENGINEER?

25 A Yes, I am regist cred in the State of Georgia.

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1 Q TO WHAT SCHOLASTIC AND PROFESSIONAL SOCIETIES Do YOU BELONG?

2 A I an a nember of the IEE and the Georgia Society of Professional

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3 Engineers. I am also a nenber of 'Prn Beta Pi (Scholastic Engineering) 4 and the Eta Kappa Nu (Scholastic Electrical).

5 Q HAVE YOU EVER TESTIFIED I:, OTHER FEDERAL POWER C0:01ISSION CASES?

6 A Yes. I have previously testified in the following proceedings:

7 Georgia Power Company, FPC Docket No. E-7548; Carolina Pouer and Light, 8 FPC Dochet No. E-7564; and Mississippi Power Company, FPC Docket No.

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, 10 Q BY WPOM IS YOUR FIRM EMPLOYED IN THIS PROCEEDING AND FOR WHAT PURPOSE?

11 A The electric cooperative intervenors (Cooperatives) requested our 12 company to perform a detailed analysis of the filing made by Florida 13 Power Corporation (Florida Pover) in this proceeding and of its Case-

! 14 in-Chief. We were to determine if the cost of service study submitted 15 by Florida Power accurately reflects the cost of serving the affected 16 Cooperatives. If we found that it was erroneous in any respect, we i 17 were to nake the necessary 4.djustments in the Florida Pouer study to 18 show the actual cost of serving the Cooperatives. We were also to 19 point out any unreasonable provisions in the neu tariff, including the

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20 contract forms and fuel clause, filed by Florida Power.

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21 Q HOW DID YOU DIVIDE YOUR FIRM'S ASSIGN: ENT AMOUNG YOUR DIFFERENT WITNESSES?

22 A Mr. O. Franklin Rogers and Mr. Stephen Page Daniel will also testify.

23 Mr. Rogers will testify concerning the necessary adjustments to Florida 24 Power's operating expenses and the assignment thereof, adjustments to 25 Flcrida Power's rate base, adjustments to the interest expense used by

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Florida Power in conputing Federal income taxes, and certain unreason-

{ l able provisions in Florida Power's proposed tariff, including the fuel 2

3 adj us tment clause. Mr. Rogers and I shall turn over to tk. Danici the 4 results of our studies for use in his exhibits. Mr. Danici vill also 5 receive f rom the exhibits sponsored by the Municipals' witness Bathen 6 adjustments uhich are necessary to Florida Power's rate base. h..

7 Daniel uill then allocate Florida Power's overall cost of service as 8 adjusted by Mr. Rogers, Mr. Eathen and me to the various classes of A

9 customers.

. 10 Q WI!AT L'AS YOUR PERSONAL ASSIGNMENT?

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11 A 7'y personal assignm.cnt in this proceeding uas a limited one. In its 12 cost of service study Florida Power assigned electric plant in service 13 based on the average of the beginning and the end of the year figures y 14 as shown on its books, to allocation categories and made a correspond-

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15 ing assigunent to accumulated provisfon for depreciation to the same 16 allocation categories. These assignments are shoun in Tables 2 and 17 3 of Statenent M (Exhibit No. (FP-201)). Florida Pouer took the 18 total electric plant in service uith one mincr adjustment, broken down f 19 by account numbers and assigned the dol.1,rs in each account to the 20 Production Function Transmi sion Function, Distribution Function,

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l General Function, and Intangible Plant. The transmission function was 21 22 further breaen doun into the following categories:

23 Generation Step-Up Facilities 115 KV System 24 115 KV Direct Assignments 69 KV System 25 69 KV Direct Assignments

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1 The amounts assigned to each of these functions was then allocated l 2 to the ciif f erent classes of customers.

I 3 My first assignment was to determine whether the assignments 4 nade by Florida Power en Tables 2 and 3 were properly rnade.

5 My second assignment was to determine whether the rate dii; centials 6 provided for in Florida Power's proposed ne'.c tariff to reflect cost dif-7 ferentials for service at different voltage 1cvels were reasonabic.

8 Q WIIAT DATA DID YOU REVIEW IN PERFOR'IING YOUR FIRST ASSIGN'IENT?

9 A I reviewed the testimony and Exhibits of Florida Power witness Keith,

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10 the FPC Form 1 and Form 12 Reports for the test year 1970 filed by I

i 11 Florida Power uith the Corraission, certain information furnished

12 by Florida Power at the request of the intervenors, and the testi-13 nony of Staff witness Orecchio and Staff Exhibit No. .

( 14 Q WilAT CONCLUSIONS DID YOU REACll AS A RESULT OF YOUR ANAIXSIS OF TIIE 15 FLORIDA POWER STUDY?

16 A 1 found that Florida Pow:r rode direct assignments of certain trans-

• 17 niasion plant investment ubich results in unfair treatraent to its 18 wholesale cestomers.

19 Q I 1!AND YJU EXilIBIT (DAS-1). WAS TIIIS EXIIIBIT PREPARED UNDER

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20 YOUR DIRECT SUPERVISION?

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21 A Yes. ,

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22 Q PLEASE DESCRIDE Tile EXIIIBIT.

23 A The Exhibit consists of two sheets: Tabic 2 and Table 3. These tables 24 follou the exact format of Tables 2 and 3 appearing in Statement M 25 (Exhibit No. (FP-201)) of Florida Pouer's study. There are only

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'l 1 tuo basic changes in Table 2 of my Exhibit from the Florida Power

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2 Tabic 2. The total electric plant in service, as adjusted, is 3 changed f ro:a $6SS,573,215 shown on Floric' . Power's TabJ e 2, Line 3,

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4 Coluan (a), to S631,105,000. The latter fi.;ure was turnished to me 5 by the Enicipal witness Bathen and is deve:.oped on Exhibit 6 (Bathen-2) and appenrs on Line 7, Column (f) of that Exhibit. Exhibit I 7 (Bathen-2)shows the adjustments to electric plant in service broken l

8 doun into production plant, transmission plant , distribution plant, and I

/ 9 general plant. Ilouever , it does not break those categories dowa by 10 account nunbers. I have made on Line 2 of Tabic 2 of my Exhibit the I'

11 assignment of the amount of the adjuctment to account numbcrs based on 12 the ratio of the investment amounts appearing in such accounts in 13 Florida Pover's books to the total investment amount for all accounts For example, transmission

( 14 with_n that functional plant classification.

, 15 plant as shavn en Florida Power's Table 2 is broken doun betueen Lines 16 (Accounts 3503, 354-359) and Substations (Accounts 350A, 352 and 353).

17 On line 2, Column (c) and (d) of Table 2 of my Exhibit, I have broken 18 down the $304,000 adjustment to transmission plant based on the ratio i

19 'of $119,614,923 shoun in Column (c) of Florida Power's Tabic 2 to the l

20 su.n of this $119,614,923 and the $47,032,694 shoun in Column (d) of Florida

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1 21 Power's Table 2. The $304,000 adjustment is *.he total of the adjustments of 22 ($1,831,000) shoun in Line 3, Column (c) cf E::hibit (Bathen-2) and 23 $1,527,000 shown in Line 3 of Column (c). All of the other assignments 24 of adjustments on Line 2 of my Tabic 2 were made on the same basis and 25 the adjustments came frem the same source.

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1 My assignments into the Allocation Categories appearing in my C

2 Table 2 as snown on Lines (5) through (3S) other than those appearing 3 on Lines (6) through (9) were obtained by prorating the figures in r

,I 4 Line 3 of ray Table 2 on the same basis as Florida Power assigned its

- 5 c1cetric plant in service as adjusted to the allocation categories.

6 For Example, the $3,952,000 figure appearing in Line 12, Column (a)

, 7 of my Table 2 was derived by dividing the $119,614,923 shown in Line 1

8 (3), Column (c) of Florida Power's Table 2 into the $3,961,237 figure t 9 shown in Line 12, Column (c) of Florida Power's Table 2, and multi-10 plying the resultant percentage times the $119,39: ,000 appearing in I 11 Line 3, Column (c) of my Table 2 ehich results in $3,952,000.

12 In calculating Lines 6 through 9, I applied the same pro rata l

13 assignment as described above and in addition I combined the result-(, 14 ing 115 KV and 69 KV direct assignment figures that would have been 15 shownonLines7and9intothe11[KVsystemand69KVsystemfigures 16 shown on Lines 6 and 8 respectively. The reason for doing this is:

17 The direct cssignments shoun in Florida Pover's Table 2 of 115 KV 18 transr..ission plant and of 69 KV transmission plant as explained by 19 Florida Power uitness Keith on Page 11 of his prepared testimony, con-20 sisted of " Radial taps and other lines devoted entirely to the service

.! of .' articular customer o; class of customer. . . ". These radial 21 22 taps and other lines uhich vere assigned by Florida Pouer directly 23 to particular classes of customers vould have been properly so assigned if all transmission facilities devoted entirely to the service of 24 25 particular classes were also directly assigned. Those that Florida

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1 Peuer did assign directly are sho.m on Pages 3 through 6 of my Exhibit

( This tabulation of direct assignments was supplied by

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3 Plorida Pouer at the request of Staff.

4 I!ovever, there are va:7 other transmission facilities of Florida 5 Pouer which are devoted entirely to the service of the retail class 6 of customers but have been assigned on a system basis. Accordingly, 7 if the 69 KV and 115 KV transmission facilities listed above were to S be assigned directly, then the vast dollar amount of other transr.ission 9 facilities devoted entirely to the service to the retail class of 10 custoners would be required to be assigned directly to the retail class 11 of customers, if a fair and proper allocution of cost of service is to 12 be made to the different classes of customers.

13 Florida Pouer's transnission systen key maps shou!ng wholesale customer delivery points which were provided by Florida Power at the

( 14 15 requrst of Intervenors indicate that the entire system area around 16 St. Petersburg serves nothing but retail customers. The same is true 17 in the area surrounding the City of Orlando. For this reason, if it 18 vere practical to do so, all such facilities should be assigned directly 19 to retail business. Ilouever, since Florida Pouer has not nade a 20 sufficiently complete direct assignment study and since the Intervenors 21 do not have sufficient data nor specific knouledge of the operation 22 of the Florida Pouer system to attempt such a study, the most fair 23 and reasonable nethodology is to nahe no direct assignments of trans-24 mission facilities, but to include all transmission facilities in 25 cither the 115 KV system or 69 KV system. That is precisely what I

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I have done in ny Exhibit. This results in each class of customer 1

2 beiring its fcir share of the tran mission cost.

3 I should note that I have made no changes in Florida Pover's

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) 4 tr t>atncnt of production function, distribution function or intangibic 5 plant,

6 Q UHAT ADJUS E:E:;TS DID YOU PaKE TO FLORIDA PO'.?ER'S TABLE 3 0F FXilIBIT i

7 NO. (FP-201)?

I S A Uith one exception, my Tabic 3 nerely reflects the changes in Florida f

9 Power's Tab]c 3 flouing f rom the adjustments I made to Florida Power's l

10 Table 2. Since nost of the electric plant iters in Table 2 were adjusted, 11 the accumulated provision for depreciation related to those itens 12 necessarily c.ust also be adjusted. In addition to the adjustments 13 in Tabic 3 ubich flou f rom the adjustnents nade in Table 2, the adjust-to 13-

14 nents appearlug in Line 2 of ny Table 3 include an adjustnent

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15 month averages to reflect depreciatien reserve requirements computed 16 on remaining lif e basis shcun in Exhibit (P,a t he n- ), Page 4a.

17 Q inIAT ::ATER11.L5 DID YOU P.EVIO IN CO',5ECTION WITII Yolnl SECO::D ASSIG:!'IE!;T 18 UlllCH YOU I!!.YE STATED UAS TO DETERMINE UIET!!ER tie PATE D7.FFEIENTIAI S 19 PROVID"D FOR I': FLORIDA FOWER'S PROPOSED HEN TARIFF TO ISPLECT COST 20 DIFFERENTIALS FOR SERVICE AT DIFFERE:;T VOLTAGE LEVELS ARE REASONABLE?

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21 A In addition to revieuing generally the same data ravicued for my first 22 assignment, I revieued the testimony of Florida Power uitness Roland 23 and a stateraent on derivation of voltage level differentials submitted 24 by Florida Pouer in response to a data request from Staff.

25 Q UOULD YOU EF.PLAIM WilAT PLORIDA PO'1ER IS PROPOSII;G IN THE UAY OF VOLTAGE s

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2 A As a part of the proposed tariff, Florida Pouer shows rate differentials 3 betueen the rate schedules applicable to the different standard voltages 4 of delivery; 115 IN delivery, 69 KV delivery, 12 or 25 IT delivery, and 5 below 12 KV delivery. As explained by Mr. Roland on Page 7, Lines 5 6 through 13 of his direct testimony, these rate differentials are contained 7 in the energy costs for the first 250 kilouatt-hours use per kilowatt of S billing denand under each schedule for each delivery voltage. Mr. Roland 9 has computed the rate dif ferentials at Line 11 on Page 7 of his direct 10 testimony.

11 Q D3 YOU AGREE TIIAT THESE PATE DIFFEPI::TIALS FOR DIFFEPI:!T VOLTAGES OF 12 DELIVERi API PIASO::ALLE?

13 A Yes, I do. I do not quarrel with the concept employed by Florida Power I 14 in arriving at the rate differentials and I agree that the per KU amounts 15 of the c'ifferentials do reflect appreninately the cost differenticis and 16 are therefore justified and reasonable.

17 Q 110'.? DID YOU COME TO TIIIS CO::CLUSIO:;?

18 A The cost data upon which these rate dif- .entials are based comes directly

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19 from Florida Power's Statement M filing and reflect approximately the 20 dif ferences in cost of service on its system at these different voltage 21 levels. Florida Power's response to Staff's information request shows 22 in detail the derivation of the unit cost differentials. The computation 23 is not an exact computation, but it is close enough to be a reasonabic 24 representation of the dif ferences in cost.

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