Petition to Intervene in Proceeding.Urges Commission to Accept Interconnection Agreement for Filing,Suspend Agreement Operation for One Day & Set Issue for Immediate Conference & HearingML19309C896 |
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Grand Gulf ![Entergy icon.png](/w/images/7/79/Entergy_icon.png) |
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Issue date: |
03/28/1980 |
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From: |
Mcdiarmid R MICHIGAN, STATE OF, SPIEGEL & MCDIARMID |
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Shared Package |
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ML19309C895 |
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References |
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NUDOCS 8004090368 |
Download: ML19309C896 (8) |
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Category:INTERVENTION PETITIONS
MONTHYEARML20080R5951984-02-21021 February 1984 Answer Opposing Jacksonians United for Livable Energy Policies 840213 Supplemental Request for Hearing & Petition for Leave to Intervene.Proposed Contentions Speculative, Vague & Unspecific.Certificate of Svc Encl ML20080Q4331984-02-21021 February 1984 Answer Opposing Suppl to Jacksonians United for Livable Energy Policies 831211 Amended Petition for Leave to Intervene.Certificate of Svc Encl ML20080J7351984-02-13013 February 1984 Suppl to 731117 Request for Hearing & Petition for Leave to Intervene.Jacksonians United for Livable Energy Policies Contentions 1,2 & 3 Submitted.Certificate of Svc Encl ML20083D9971983-12-22022 December 1983 Response Opposing Jacksonians United for Livable Energy Policies 831211 Amended Petition to Intervene & Request for Hearing.Petition Fails to Satisfy Commission Requirements. Notice of Appearance & Certificate of Svc Encl ML20083A4981983-12-14014 December 1983 Answer Opposing K Lawrence & Jacksonians United 831117 Petition to Intervene & Request for Hearing on Liveable Energy Policies Re Amend 10 to License NPF-13.Petition Failed Requirements for Standing.W/Notice of Appearance ML20082T7031983-12-11011 December 1983 Amend to Jacksonians United for Livable Energy Policies Request for Adjudicatory Hearing on Amend 10 to License NPF-13 & Petition to Intervene.Procedural & Standing Requirements Met.Certificate of Svc Encl ML20082E4651983-11-17017 November 1983 Petition of Jacksonians United for Livable Energy Policies for Leave to Intervene & Request for Hearing on Licensee Application for Amend 10 to License NPF-13 ML20063P8801982-10-11011 October 1982 Brief Supporting State of La Jul 1982 Petition to Participate as Interested State.Good Cause Shown for Untimely Petition.Certificate of Svc Encl ML20063J4231982-08-31031 August 1982 Suppl to 820819 Answer Opposing State of La Petition to Participate as Interested State & to Reopen Proceedings. Waste Disposal Contentions May Not Be Considered in Hearing.Certificate of Svc Encl ML20062M9031982-08-19019 August 1982 Answer Opposing State of La 820721 Petition to Participate as Interested State in OL Proceeding.Aslb Lacks Jurisdiction to Grant Relief Re Unit 1.Requirements for Late Intervention Not Satisfied.W/Certificate of Svc ML20062F2871982-08-10010 August 1982 Opposition to State of La 820721 Untimely Petition to Intervene.No Good Cause for Late Filing Demonstrated.Balance of 10CFR2.714 Factors Weigh Against Intervention.Notices of Appearance & Certificate of Svc Encl ML20058D6541982-07-21021 July 1982 Petition to Participate as Interested State in OL Proceedings & to Reopen Proceedings to Precipitate Commission Rulings Consistent W/Recent Court of Appeals Decision.Notices of Appearance & Certificate of Svc Encl ML19309C8961980-03-28028 March 1980 Petition to Intervene in Proceeding.Urges Commission to Accept Interconnection Agreement for Filing,Suspend Agreement Operation for One Day & Set Issue for Immediate Conference & Hearing 1984-02-21
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20080R5951984-02-21021 February 1984 Answer Opposing Jacksonians United for Livable Energy Policies 840213 Supplemental Request for Hearing & Petition for Leave to Intervene.Proposed Contentions Speculative, Vague & Unspecific.Certificate of Svc Encl ML20080Q4331984-02-21021 February 1984 Answer Opposing Suppl to Jacksonians United for Livable Energy Policies 831211 Amended Petition for Leave to Intervene.Certificate of Svc Encl ML20080J7351984-02-13013 February 1984 Suppl to 731117 Request for Hearing & Petition for Leave to Intervene.Jacksonians United for Livable Energy Policies Contentions 1,2 & 3 Submitted.Certificate of Svc Encl ML20083D9971983-12-22022 December 1983 Response Opposing Jacksonians United for Livable Energy Policies 831211 Amended Petition to Intervene & Request for Hearing.Petition Fails to Satisfy Commission Requirements. Notice of Appearance & Certificate of Svc Encl ML20083A4981983-12-14014 December 1983 Answer Opposing K Lawrence & Jacksonians United 831117 Petition to Intervene & Request for Hearing on Liveable Energy Policies Re Amend 10 to License NPF-13.Petition Failed Requirements for Standing.W/Notice of Appearance ML20082T7031983-12-11011 December 1983 Amend to Jacksonians United for Livable Energy Policies Request for Adjudicatory Hearing on Amend 10 to License NPF-13 & Petition to Intervene.Procedural & Standing Requirements Met.Certificate of Svc Encl ML20082E4651983-11-17017 November 1983 Petition of Jacksonians United for Livable Energy Policies for Leave to Intervene & Request for Hearing on Licensee Application for Amend 10 to License NPF-13 ML20063P8801982-10-11011 October 1982 Brief Supporting State of La Jul 1982 Petition to Participate as Interested State.Good Cause Shown for Untimely Petition.Certificate of Svc Encl ML20063J4231982-08-31031 August 1982 Suppl to 820819 Answer Opposing State of La Petition to Participate as Interested State & to Reopen Proceedings. Waste Disposal Contentions May Not Be Considered in Hearing.Certificate of Svc Encl ML20062M9031982-08-19019 August 1982 Answer Opposing State of La 820721 Petition to Participate as Interested State in OL Proceeding.Aslb Lacks Jurisdiction to Grant Relief Re Unit 1.Requirements for Late Intervention Not Satisfied.W/Certificate of Svc ML20062F2871982-08-10010 August 1982 Opposition to State of La 820721 Untimely Petition to Intervene.No Good Cause for Late Filing Demonstrated.Balance of 10CFR2.714 Factors Weigh Against Intervention.Notices of Appearance & Certificate of Svc Encl ML20058D6541982-07-21021 July 1982 Petition to Participate as Interested State in OL Proceedings & to Reopen Proceedings to Precipitate Commission Rulings Consistent W/Recent Court of Appeals Decision.Notices of Appearance & Certificate of Svc Encl ML19309C8961980-03-28028 March 1980 Petition to Intervene in Proceeding.Urges Commission to Accept Interconnection Agreement for Filing,Suspend Agreement Operation for One Day & Set Issue for Immediate Conference & Hearing 1984-02-21
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20140J0731997-06-0505 June 1997 Affirmation Authorizing Jj Hagan to Sign & File W/Nrc, Response to GL 92-08 RAI for Facility ML20136E7591997-03-0707 March 1997 Comment Supporting Proposed Generic Communication, Effectiveness of Ultrasonic Testing Systems in Inservice Inspection Programs ML20116G9431996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re, Mods to Fitness-For-Duty Program Requirements ML20098D0271995-10-0202 October 1995 Comment on Draft Reg Guide DG-1038 (Proposed Rev 2 to Reg Guide 1.82), Water Sources for Long-Term Recirculation Cooling Following Loca TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20086N6551995-07-14014 July 1995 Comment on Proposed Generic Ltr Re 10CFR50.54 Process for Changes to Security Plans W/O Prior NRC Approval. Agrees W/ Proposed Clarification of Language & W/Provided Screening Criteria in Notice ML20086D8841995-06-29029 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style ML20085E5891995-06-0909 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20080A1331994-10-21021 October 1994 Comment Supporting Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Advises That Util of Belief That NRC Focus on Safety Significance in Insps & Enforcement Policy Can Be Achieved by Utilization of Risk Based Techniques ML20073M3261994-10-0303 October 1994 Comment on Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants ML20072S5431994-08-30030 August 1994 Comment Supporting Petition for Rulemaking 9-2 Re Public Access to Documents Maintained by Licensees But Not Submitted to NRC ML20072B8521994-08-0505 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements.Licensee Believes Reduction in Amount of FFD Testing Warranted & Can Best Be Achieved in Manner Already Adopted by Commission ML20065P4121994-04-25025 April 1994 Comment on Proposed Rule 10CFR50 Rule Re Code & Stds Re Subsections IWE & Iwl.Expresses Deep Concern About Ramifications of Implementing Proposed Rule ML20058G6211993-12-0606 December 1993 Comment on Draft NUREG/BR-0058, Regulatory Analysis Guidelines,Rev 2. Concurs W/Numarc & Nubarg Comments ML20056F3481993-08-23023 August 1993 Comment Opposing NRC Draft GL 89-10,suppl 6 ML20058E0251990-10-12012 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML20055E9871990-06-29029 June 1990 Comment Opposing Proposed Rule 10CFR55 Re Mod for fitness-for-duty Programs & Licensed Operators.Util Believes That High Stds of Conduct Will Continue to Be Best Achieved & Maintained by Program That Addresses Integrity ML20043D4781990-05-19019 May 1990 Comments on Notice Re Grand Gulf Document Collection ML20006A5481990-01-0808 January 1990 Comment Supporting Proposed Rule 10CFR50, Stabilization & Decontamination Priority,Trusteeship Provisions & Amount of Property Insurance Requirements. AECM-89-0045, Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants1989-02-25025 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants AECM-88-0229, Comment Supporting Proposed Rule 10CFR26 Re Fitness for Duty Program.Attachment to Ltr Provides Answers to Specific Questions Posed by Commission in Proposed Rule1988-11-18018 November 1988 Comment Supporting Proposed Rule 10CFR26 Re Fitness for Duty Program.Attachment to Ltr Provides Answers to Specific Questions Posed by Commission in Proposed Rule ML20205P9691988-10-26026 October 1988 Comment Supporting Proposed Rule 10CFR50 Re NUREG-1317, Regulatory Options for Nuclear License Renewal. Supports Contents of NUREG-1317 & Endorses NUMARC Comments on Rulemaking & Position Paper by NUMARC Nuplex Working Group ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons AECM-87-0187, Comments on Draft NUREG-1150, Reactor Risk Ref Document. Review of Document Indicates That Ability of Facility to Cope W/Severe Accidents Underestimated Due to Conservative Assumptions1987-10-0202 October 1987 Comments on Draft NUREG-1150, Reactor Risk Ref Document. Review of Document Indicates That Ability of Facility to Cope W/Severe Accidents Underestimated Due to Conservative Assumptions ML20214W8701986-12-0303 December 1986 Comments on Proposed Transfer of OL to Sys Energy Resources, Inc.No Objection Raised to Noted Request Re Transfer of Operating Responsibility.Certificate of Svc Encl ML20093N5291984-07-30030 July 1984 First Set of Interrogatories to Jacksonians United for Livable Energy Policies.Certificate of Svc Encl.Related Correspondence IA-84-665, Transcript of Commission 840726 Closed Meeting in Washington,Dc Re Discussion of Investigations & Possible Enforcement Actions.Pp 44-52.Portions Deleted1984-07-26026 July 1984 Transcript of Commission 840726 Closed Meeting in Washington,Dc Re Discussion of Investigations & Possible Enforcement Actions.Pp 44-52.Portions Deleted ML20134P2781984-07-26026 July 1984 Transcript of Commission 840726 Closed Meeting in Washington,Dc Re Discussion of Investigations & Possible Enforcement Actions.Pp 44-52.Portions Deleted ML20126D2731984-05-24024 May 1984 Transcript of 840524 Public Meeting in Washington,Dc Re Diesel Generator Insp Order.Pp 1-58.Supporting Documentation Encl ML20084S3251984-05-21021 May 1984 Motion for Reconsideration of ASLB 840423 Memorandum & Order Granting Jacksonians United for Livable Energy Policies Intervenor Status & Referral or Certification of Whether ASLB Properly Admitted Moot Contention.W/Certificate of Svc ML20084G1311984-05-0202 May 1984 Request for Extension of Time Until 840517 within Which to Appeal Assertion That Intervention Granted to Jacksonians United for Livable Energy Policies Should Have Been Wholly Denied.Certificate of Svc Encl ML20084E9811984-04-30030 April 1984 Answer Consenting to 840418 Order Restricting Conditions for Operation ML20084E0651984-04-30030 April 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20084B9601984-04-25025 April 1984 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20088A2021984-03-29029 March 1984 Petition to Show Cause on Revocation of Low Power License & Denial of Full Power License Re Transamerica Delaval, Inc Generators.Summary of Generator Operation Experience Encl ML20087G4351984-03-16016 March 1984 Response to First Order Following Prehearing Conference Modifying Briefing Schedule.Aslb Should Deny Admission of Paragraphs 6,7 & 8 as Well as Contentions 1,2 & 3 & Dismiss Proceeding.Certificate of Svc Encl ML20087N6501984-03-0202 March 1984 Response to Licensee Response to First Order Following Prehearing Conference (Modifying Brief Schedule).Contentions 1-6 Should Be Considered in Proceeding.Certificate of Svc Encl ML20087N5651984-02-22022 February 1984 Testimony of Jm Mcconaghy,Lr Barner,Jp Akers,Je Cavender, Lw Rudasill,Jc Shropshire,Rp Ruth & Dh Llewellyn Re in Camera Witness Allegations Concerning Laminations ML20080Q4331984-02-21021 February 1984 Answer Opposing Suppl to Jacksonians United for Livable Energy Policies 831211 Amended Petition for Leave to Intervene.Certificate of Svc Encl ML20080R5951984-02-21021 February 1984 Answer Opposing Jacksonians United for Livable Energy Policies 840213 Supplemental Request for Hearing & Petition for Leave to Intervene.Proposed Contentions Speculative, Vague & Unspecific.Certificate of Svc Encl ML20080J7351984-02-13013 February 1984 Suppl to 731117 Request for Hearing & Petition for Leave to Intervene.Jacksonians United for Livable Energy Policies Contentions 1,2 & 3 Submitted.Certificate of Svc Encl ML20080A5941984-02-0202 February 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20079N1951984-01-24024 January 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20079F2891984-01-12012 January 1984 Response to NRC & Licensee Answers to Jacksonians United for Livable Energy Policies 831117 Petition to Intervene & Request for Hearing & 831211 Amended Petition.Certificate of Svc Encl ML20083D9971983-12-22022 December 1983 Response Opposing Jacksonians United for Livable Energy Policies 831211 Amended Petition to Intervene & Request for Hearing.Petition Fails to Satisfy Commission Requirements. Notice of Appearance & Certificate of Svc Encl ML20083A4981983-12-14014 December 1983 Answer Opposing K Lawrence & Jacksonians United 831117 Petition to Intervene & Request for Hearing on Liveable Energy Policies Re Amend 10 to License NPF-13.Petition Failed Requirements for Standing.W/Notice of Appearance ML20082T7031983-12-11011 December 1983 Amend to Jacksonians United for Livable Energy Policies Request for Adjudicatory Hearing on Amend 10 to License NPF-13 & Petition to Intervene.Procedural & Standing Requirements Met.Certificate of Svc Encl ML20082E4651983-11-17017 November 1983 Petition of Jacksonians United for Livable Energy Policies for Leave to Intervene & Request for Hearing on Licensee Application for Amend 10 to License NPF-13 ML20028A7371982-11-19019 November 1982 Brief Opposing State of La 821104 Appeal of ASLB 821020 Memorandum & Order Denying La 820726 late-filed Petition to Intervene.Aslb Correct in Deciding Petitioner Failed to Satisfy Requirements.Certificate of Svc Encl ML20027D8411982-11-0404 November 1982 Appeal of ASLB 821020 Order Denying State of La 820726 Petition to Participate as Interested State.Burden Re Untimeliness of Filing Met.Certificate of Svc Encl 1997-06-05
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* - . ATTACHfTNT A
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UNITED STATES OF AMERICA BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION Mississippi Power & Light Company ) Docket No. ER80-261 PETITION TO INTERVENE I.
Pursuant to the Notice of Filing issued in this docket by the Commission on March 6, 1980, the Cities of Clarksdale and Greenwood, Mississippi, herewith file this petition for intervention, in accordance with Section 1.8 and 1.10 of the Commission's Rules of Practice.
II.
Clarksdale and Greenwood (" Cities"), through the Municipal Energy Agency of Mississippi, arranged well
- s. over a year ago for the delivery of power and energy to Gulf States Utilities for redelivery to MP&L and further delivery to Cities. It is the interface arrangement between Gulf States and MP&L which the instant filing is designed to cover. As we shall note, there seems to be considerable question as to what types of transactions can be carried out over that interconnection between Gulf States and MP&L under this contract, and considerable question as to whether the terms of the contract ~ as filed are just and reasonable. No other party can represent Cities' interests here and Cities may be bound by the Commission's action in this proceeding.
Consequently, Cities are entitled to intervention herein._
Since this petition is filed on behalf of two entities, rather than separate petitions being filed for each, Cities v.equest, in the interest of reducing proliferation of filed documents, tha t the following names and addresses be placed upon the official service list:
Mr. Marvin Carraway Assistant Superintendent :
Clarksdale Water & Light Department l P.O. Box 940 l Clarksdale, Mississippi 38614 l Mr. Charles M. Matthews !
( Manager '
Greenwood Utilities Commission ;
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P.O. Box 866 Greenwood, Mississippi 38930
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David R. Hunt, Esq.
Sullivan, Hunt, Spell, Henson,
& Chapman P.O. Box 1196 123 Court Street Clarksdale, Missisippi 38614 Robert C. McDiarmid, Esq.
Spiegel & McDiarmid 2600 Virginia Avenue , N.W.
Washington, D.C. 20037 III.
Cities have engaged in litigation with MP&L before this Commission (FERC Docket Nos. ER78-583 and ER78-584),
which forms a backdrop to this filing. In the Settlement Agreement reached in those dockets, MP&L entered into certain commitments with Cities and with the Municipal Energy Agency of Mississippi ("MEAM"). While there is apparently some argument yet remaining as to MP&L's obligation to transmit
.. f rom the Gulf States interconnection, absent an interconnec-tion agreement with Gulf States, MP&L undertook expeditiously to conclude an agreement with Gulf States that would moot the question of its obligation.
We understand that negotiations between MP&L and Gulf States proceeded upon a very erratic basis. Cities have been given quite different representations as to the course of these negotiations from information received from the two sides. Compare, e.g., the filing letter here with Attachment A hereto. Cities have also been in receipt of letters from MP&L's corporate sibling, Louisiana Power & Light ("LP&L"),
which first appeared as though LP&L might be threatening suit if MP&L in fact transmitted power or energy over its inter-connection with Gulf States. If that communication was intended as a threat, Cities believe it has been withdrawn by a subsequent communication from LP&L. ,
i Cities are not privy to the reasons behind this ,
filing of an unconsented to interconnection " agreement". ,
From an operating point of view, Cities find it difficult to l understand how an interconnection " agreement" could be '
expected to operate without provisions for accounting for ;
payments for the transactions which take place under the ,
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f agreement. If no service schedules are necessary, it would
'seem to bear out Cities' contention all along tha t no inter-connection agreement was in fact necessary for transmission f rom the Gulf States point of interconnection with MP&L, a contention which MP&L has heretofor vigorously disputed.
Cities are aware of one very salient point to them; no energy has in fact been transmitted over the interconnection. While Cities may have their own views as to which of the parties to the interconnection " agreement" might be at fault in this regard, it seems clear that the interconnection " agreement" will not operate without at least acquiescence on both sides.
As a consequence, Cities urge tha t the " agreement" be accepted for filing, suspended for one day, and set for rapid hearing. Cities also urge an investigation of this arrange-ment by Staff so that the efficiencies available to the Cities, and the parties to the " agreement" available from transactions over this interconnection be permitted to take place. Since Cities are by no means sure of the reasons of Gulf States or MP&L for their positions, we urge that a expeditious conference of the parties be convened, so that it can be determined whether the problems apparent here are real for anyone other than Cities and, if real, resolved.
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IV.
CONCLUSION For the foregoing reasons, Cities urge that the Commission accept this " interconnection agreement" for filing, suspend its operation for one day, and set the issue of its justness and reasonableness for immediate. conference and hearing.
Respectfully submitted, r~s ,
Robert C. McDiarmid l Counsel for Cities of Clarksdale and Greenwood, Mississippi March 28, 1980 C Law offices of:
' Spiegel & McDiarmid 2600 Virginia Avenue, N.W.
Washington, D.C. 20037
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December 14, 1979
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Mr. ft. L. Stampley, Vice President g Mississippi Power & Light Ccmpany P. O. Box 1640 . .. g (v b Jackson, Mississippi 39205 0
Dear Norris:
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As you are aware, we have been negotiating for months upon an appropriate interconnection agreement between our companies.
Early in the year we exchanged drafts. In May we submitted to you a revised draft which we thought contained the significant changes
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you had requested. At that time we thought the agreement was substantially in final form for execution.
In mid-October you submitted to us a totally new draft of C a proposed interconnection agreement, stating that it was adapted frem one you had recently executed. Since your recent draft is ,
significantly different in important respects frca the previous drafts, we have tried to reconcile the differences, hopefully so as to permit each sf us to be consistent with respect to the services we respectively offer.
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?m.- - With this in mind, we have taken your draft and made a few
-M. proposed revisions to it. Attached is a copy of your draft con-q.;7/ . taining our proposed revisions. In the areas in which our respec-
- f. n - . tive positions differ materially or which are not covered in your
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proposed form of agreement, we suggest that each company incorporate
-- its provisions into its service schedules.
For instance, we have provisions in our interconnection agreements regarding continuity of service and billing and settle-ment which are either not covered by or differ from the provisions in your proposed agreement. We suggest that our standard provisions be incorporated in the GSU service schedules attached to the inter-connection agreement, and you incorporate your standard provisions in your service schedule. This would hopefully allow each of us to be consistent in, imposing the same provisions with respect to services offered by each of us within our own service areas. If this sounds like an acceptable alternative, please let me know and Q we will promptly submit to yeu. a proposed GSU transmission service
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schedule with our conditions included in'it. We will also make the m appropriate modifications, as outlined above, to our other service
'- schedules which were included in the May draft. lie would expect you to add the bill'ing and settlement provisions which were contained in
. your interconnection agreement to your service schedules.
We have discussed'with you our need for transmission service -
on your system. This letter constitutes our formal request that transmission service be nade available to us on substantially the same basis as that we understand you are now offering to others. For this reason, we expect the interconnection agreement at least to include initially a service schedule providing such transmission service. -
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Please let us have your cocuents as soon as possible.
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Sincerely,
/[[ lelay
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- A. E. Naylor Manager-Power Interconnections
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AEN:am Attachment
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cc:id(r. C. M. Mathews *
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Mr. Charles Burchfield
. Cccmissioner - MEAM C Mr. Jack Davey 24:j.{ Vice President & Chief Engineer - LP&L
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' ' ' ' Mr. John F. Vogt, Jr.
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Vice President - Middle South Services
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Mr.. Marvin L. Carraway Secretary-Treasurer - MEN 1
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VERIFICATION
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s DISTRICT OF COLUMBIA, SS:
Robert C. McDiarmid, being first duly placed upon affirmation, deposes and says that he is an attorney for the Cities of Clarksdale and Greenwood, Mississippi, and that as such he has signed the for~egoing PETITION TO INTERVENE for ,
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and on behalf of said parties; that he is authorized by the parties so to do; that he has read said Comments and is fami- -
liar with the contents thereof; and that the matters and things therein set forth are true and correct to the . best of his knowledge, information and belief.
Robert C. McDiarmid Subscribed and sworn to before me this ' 28th day of March, 1980.
Luh AC Notary 'Public_.
gy < , r..r tzpt.u Tan.3L U C m,
CERTIFICATE OF SERVICE I hereby certify that I have this day caused to be served the foregoing document upon each person designated on the official service list compiled by the Secretary in this proceeding in accordance with the requirements of Section 1.17 of the Rules of Practice and Procedure.
Dated at Washington, D.C. this 28th day of March, 1980.
A Robert C. McDiarmid
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ATTACHMEUT B Sity a Slarksdale mammawaaas]
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0$alcr aml big lst Separtmerl February 13, 1980 RECElVED FE8191980 Mr. Jack Davey SPIEC2! 0 .~.'S!.teU.!!D Vice President and Chief Engineer Louisiana Power & Light Company 142 Delaronde Street New Orleans, Louisiana 70174
Dear Mr. Davey:
Clarksdale is in receipt of your letter of February 5,1980, which apparently threatens some sort of suitif Mississippi Power G Light Company agrees with Culf States Utilities Company to transmit power from its' interconnection with Culf States to the City of Clarksdale, as we believe it has promised it would do in the course of a settlement reached and filed at the Federal Energy Regulatory Commission. As we understand it, LPSL seeks payment for transmission based upon a " load flow" rather than a " contract path" basis, a method heretofore unused in the Southwest Power Pool transacticns.
The Municipal Energy Agency of Mississippi and its Members, Clarksdale and Greenwood, would be pleased to consider the use of a true " load flow" transmission rate if it is to be proposed. As we understand it, that would result in a single
" postage stamp" rate for all of the Southwest Power Pool, and would be considerably less expensive than the double rate (for MPSL and Gulf States) which your corporate affiliate, MPSL, has insisted upon. If you are proposing a true load flow basis, I am sure that all of the people to whom you wrote will be pleased to negotiate with you within the context of the Southwest Power Pool. If, of course, you mean to state that LPSL seeks a third full transmission rate based upon its own costs, we believe you are incorrect conceptually, as well as incorrect legally. We would ,
appreciate clarification in this regard. l l
Yo very truly, l MW Richard M. Webster, Jr. ;
Mayor l cc: Mr. A. E. Naylor i M r . W . L . S tampicy l Hon. Kenneth F. Bowen i
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ATTACHMENT C c -- - -
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P O W E R & L I G H Tj p o. sox ecce N,w cattAus. tousANA 70174 . <504: 3682345 urut.d sistau JACK OAVEY February 25, 1980 "'#"
and Ch.et Engsneer R E.C EI V E D Hon. Richard M. Webster, Jr. MAR 4 1980 Mayor, City of Clarksdale Post Office Box 940 SP!EGEL & i,kOtARMID Clarksdale, Mississippi 38614
Dear Mayor Webster:
We have your letter dated February 13, 1980. '
We are unable to find any indication in our past correspondence of any threat of a suit or litigation of any kind, and we hope that nobody involved in this trans-action will go in that direction.
All that we were saying to the. interested parties was, and is, that Louisiana Power & Light- Company cannot. and will not transmit electricity over 'itsJfacilities without being paid for that transmission.
Respectfully yours,
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Jack Davey Vice President and Chief Engineer JD:cb cc: Mr. A. E. Naylor Mr. N. L. Stampley Hon. Kenneth F. Bowen Mr. C. M. Mathews .
Mr. Sylvan Richard
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Middle South Operating Committee
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