ML19344E571

Requests That Info Be Provided to All Parties Re Wheeling Rate Development Per 800826 Discussions.Discusses Principles to Be Considered Re Smaller Util Participation in Facility Ownership

ML19344E571
Person / Time
Site:	South Texas, Comanche Peak
Issue date:	08/28/1980
From:	Spiegel G BROWNSVILLE, TX, SPIEGEL & MCDIARMID
To:	Gooch R, Mark Miller, Sampels M BAKER & BOTTS, ISHAM, LINCOLN & BEALE, WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY
References
NUDOCS 8009020282
Download: ML19344E571 (4)

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L.Aw CPriCas cacRGE seetGat. ec SPIEGEL dC McDIARMID Rom u. LANosMAN l,0j$ I,"7,,'*lf' 2600 VIRGINIA AVENUE, N.W. g g,, gg3, TNoMAs C. TRAuGER RoreRT A. JAeLoM WASHINGTON. D.c. 20037 JONN MICNAEL ADRAGNA JAM!s N. NCRWCCO D AtaNJ.RoTN t- TELaPMoNs tacas ass.Asco cVNTNIA s. 80GORAD )

f GARY J. NEWEL i RRANCEs S. PRANCis gh g T8L8C

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• 3 MARC R. PQlRIER .

DANIEL 1. D AVIDsON MARTA A. MANILDI THHMAs N. McNuGN, JR. l ETEr JossPN L VAN EATON FETER st. MATT ,

sTsPNaN C. N CNots o^v'o R. sTRAus g usNRc August 28, 1980 l DB29g

on cov=esu Office of the u.cyo c. cirTRiCN %g g

' Branch i

4 ru Michael I. Miller, Esq. Fred K. Werkenthin , Esq.

Isham, Lincoln & Beale Small, Craig & Werkenthin One First National Plaza 2600 Austin National Bank Towe Chicago, Illinois 60603 Austin, Texas 78701 1 R. Gordon Gooch, Esq. Jon C. Wood , Esq.

Baker & Botts Matthews , Nowlin , Macfarlane 1701 Pennsylvania Ave., N.W. & Barrett Washing ton , D.C. 20006 1500 Alamo National Building San Antonio, Texas 78205 Merlyn D. Sampels, Esq. Jerry L. Harris, Esq.

Spencer C. Relyea , Esq. City of Austin Worsham, Forsythe & Sampels P. O. Box 1088 2001 Bryan Tower Austin, Texas 78767 Suite 2500 Dallas, Texas 75201 .

Re: Houston Lighting & Power Company, et al.,

(South Texas Pro]ect Units 1 and 2),

NRC Docket Nos. 50-498A, 50-499A; Texas Utilities Generating Company, et al.,

(Comanene Peak Steam Electric Station Units 1 & 2),

NRC Docket Nos. 50-445A, 50-446A; Central Power & Light Co., et al.,

FERC Docket No. EL 79-8 Gentlemen:

This is with reference to the interesting and infor-mative discussion on August 26 at Baker & Botts , Washington ,

of possible transmission rates and services which might be developed and embodied as conditions or provisions in settle-ment agreements with the ultimate objective of attaining a surcease from the vast litigation spawned by the three major Texas electric utilities ("Three Texas Companies") and their O g '

legions of attorneys and consultants. } $

\

There were a number of proposed methods of devel-eping wheeling rates, whether through single systems, through multiple systems within one region, and through the 8009080 N

DC facilities (which some favor as an alternative to AC con-nections between ERCOT and the rest of the Continental United States). It struck me that there was considerable

( inevitable) confusion because of communication difficulties.

Further, very often, the validity of a rate-making method cannot be determined without calculating the results to see if it produces something inherently reasonable, or compares favorably with other results, or is as least livable. In short, while perhaps some utilities think that determining transmission costs is clear and definable (as long as it is done their way) most of the parties recognize that cost allo-cation is neither exact nor entirely scientific.

Accordingly, I repeat (and now amplify) the requests made at the meeting , on behalf of tha Public Utilities Board of Brownsville , Texas , that information be provided post haste to all the parties, as follows :

1. As to firm power wheeling agreements or arrangements now in place, or in place during the last five years:

a. The names of power seller, purchaser, and wheeling utilities;

b. The term of the transaction in months or years;

c. The kw of firm contract demand , the kw peak deliveries and the kwh, by years;

d. The provisions governing the deter-mination of the rates and charges; and

e. The actual rates and charges, as well as the total billing by months or years.

2. As to firm power wheeling under the provisions of the Texas Inteconnected System Transmission Facilities Policy Guidelines, indicate which of the transactions under

• paragraph 1 above were developed under these TIS Guidelines;

3. Based upen the most recent year for which data is available (1979, if possible) what would the rates and charges be to wheel firm power to Brownsville, under the TIS

Guidelines, assuming the following firm power transactions:

a. 50,0 30 kw and 20,00O kw delivered from the output terminals of the Northern DC converter station to Browasville;

l

=~ ~

-4 Same as to the Southern DC converter

b. 1 station; ,

c. 50,000 kw and 20,000 kw sold by (i) Texas P&L to Brownsville, (ii) Dallas Power & Light Co.

to Brownsville, and (iii) by Texas Electric Service l Co. to Brownsville;

d. 50,000 kw and 20,000 kw sold by EL&P. to ,

Brownsville;

e. 50,000 kw and 20,000 kw sold by San Antonio to Brownsville;

f. 50,000 kw and 20,000 kw sold by Austin to Brownsville ;

g. 50,000 kw and 20,000 kw scid by Lower Colorado River Authority to Brownsvt.lle.

4. With reference to any of the wheeling rate structures presented for discussison by representatives of any of Central and South West Company, Texas Utilities , or Houston Power & Light Company, it is requested that the same test cases (as requested in 3 above) be run.

It may be that other parties , af fected by the pro-posed settlement among the Three Texas Companies, may also need similar cases run. .

It is recognized that, in some cases , this request If so ,

(unless modified) may involve a substantial expense.

please call me so that I can devise alternates, approximations, I have the or other ways to obtain the results desired.

' impression that the Three Texas Companies have considerable should be possible to computer sophistication, so that it obtain meaningful data at a reasonable cost.

I do not see how the smaller utilities involved in

these proceedings can evaluate the various proposed settle-ments without this kind of data and information. .

It is Brownsville's position that any settlement must include fair and computable wheeling tariffs to be filed i

as part of the settlements with adequate protection against i

substantive unilateral changes.

I 1

We airo reiterate that, if the costs and limita-tions of DC can be justified (as compared to' the costs and flexibility of AC), then it must be recognized tha t , for the Three Texas Companies (or at least for the two directly investing in DC f acilities) , these costs would be recognized for general rate-making purposes as system improvements for which all customers .(retail, wholesale and wheeling) mus t bear a pro-rata allocated cost. If, however, the DC alter-native is selected for other than economic reasons, any DC cost penalty should not be allocated to any customers. These matters need to be resolved in any overall settlement.

Wheeling customers should not bear more than their system pro-rata share of DC costs.

The foregoing principles must be considered in developinc proposals for the smaller utilities to participate in ownership of, or to wheel power over , the DC conversion facilities. They should not be requis'd to invest or pay more than would be involved if the interconnections were accomplished on a conventional AC basis.

It is recognized that it may be necessay for the Three Texas Companies to confer among themselves (as well as with other TIS utilities) to determine which utility should supply which data.

? lease do not hesitate to call or write me with reference to any of the foregcing.

~

Sincerely yours, George Spiegel Attorney for the Public Utilities Board of the City of Brownsville, Texas GS/vha cc: All Parties .

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h AUG 2 91983 > [.

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