ML19308A423
| ML19308A423 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 08/01/1979 |
| From: | Rogers O DETROIT EDISON CO. |
| To: | |
| Shared Package | |
| ML19208C305 | List:
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| References | |
| E-9294, NUDOCS 7909260341 | |
| Download: ML19308A423 (5) | |
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THE DETROIT EDISON COMPAhT
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FPC DOCKET NO. E-9294 DIRECT TESTIM 0hT OF 0. FRANKLIN ROGERS V
1Q PLEASE STATE YOUR NAMS AND ADDRESS.
2 3A My name is O. Franklin Rogers. My business address is 1000 Crescent 4 Avenue, N.E., Atlanta, Georgia 30309.
5 6Q BY WHOM ARE YOU EMPIDYED?
7 8 A I am a member of the firm of Southern Engineering Company of Georgia.
9 10 Q PLEASE STATE YOUR EDUCATIONAL BACKGROUND.
11 12 A I attended Emory University in Atlanta for two years and Georgia 13 Institute of Technology for two years, receiving a degree of Bachelor 14 of Industrial Engineering from Georgia Institute of Technology in 1955.
15 I also attended Emory University Law School.
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, 17 Q PLEASE STATE YOUR PROFESSIONAL EXPERIENCE.
18 19 A Upon graduation from Georgia Tech, I served three years as an officer 20 in the United States Navy, after which I began working for Southern -
21 Engineering Company in 1958. I have, during that time, headed the 22 Retail and Wholesale Rate Departments in my Company. I have performed 23 rate studies for over seventy-five rural electric cooperative and 24 municipal systems in thirteen states during this period of' time. I (jj 25 have participated in' wholesale rate and contract negotiations with 26 thirty-six privately owned investor utilities in n.ineteen states.
27 During this period of time, I have prepared or participated in pre-28 paring numerous cost of service studies of investor-owned utilities, 29 rural electric cooperatives and municipal systems.
30 31 Q MR. ROGERS, WITH RESPECT TO ELECTRIC RATE CASE MATTERS, EAVE YOU EVER 32 GIVEN TESTIE0hT BEFORE THIS COMMISSION OR ANY STATE UTILITY REGULAIORY 33 COMMISSION?
34 35 A Yes, I have.
36 37 Q WILL YOU PLEASE IDENTIFY THOSE PROCEEDINGS AND THE COMMISSIONS BEFORE 38 WHICH YOU HAVE TESTIFIED.
39 40 A I have testified before several State Commissions including North 41 Carolina, South Carolina, Kentucky and Indiana. I have previously testified before the Federal Power Commission in the following pro-42 43 ccedures: Mississippi Power & Light Company, FPC Docket No. E-7577; 44 Carolina Power & Light Company, FPC Docket No. E-7564; Georgin Power 45 Company, FPC Docket No. E-7548; Public Service Company of Indiana, 46 FPC Docket No. E-7645; Alabama Power Company, FPC Docket No. E-7674; 47 Gulf P wer Company, FPC Docket No. E-7625; Florida Power Corporation; 48 FPC Docket No. E-7679; Duke Power Company, FPC Docket No. E-7720; 49 Pennsylvania Elcetric Comoany, FPC Docket No. E-7718; Public Service 50 Company of New Hampshire, FPC Docket No. E-7742; Indiana and Michigan
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U) 1 Electric Company, FPC Docket No. E-7740; Virginia Electric and Power 2 Company, FPC Docket No. E-8026, Carolina Power & Light Company, FPC 3 Docket No. E-8881; Consumers Power Comoany, FPC Docket No. E-7803; 4 Appalachian Power Company, FPC Docket No. E-7775; Toledo Edison Company, 5 FPC Docket No. E-7929; Mississioni Power Company, FPC Docket No. E-7625; 6 Carolina Power and Licht Comoany, FPC Docket No. E-8884; Alabama Power 7 Comoanv, FPC Docket No. E-8851; Gulf Power Company, FPC Docket No.
8 E-8911; and Delcarva Power & Licht Comoanv and Subsidiaries, FPC Docket 9 No. E-8947. I have also submitted prepared testimony in Mississinoi 10 Power Company, FPC Docket No. E-9135.
11 12 Q HAVE YOU NEGOTIATED WHOLESALE POWER SUPPLY CONTRACTS WITH POWER 13 COMPANIES ON BEHALF OF YOUR CLIENTS?
14 15 A Yes. The privately owned electric companies with which I have 16 personally negotiated on behalf of wholesale customers are:
17 18 Florida Power Corporation (two occasions), Gulf Power Company, 19 Georgia-Power Company (four occasions), Virginia Electric & Power 20 Company (three occasions), Carolina Power & Light Company, Delmarva 21 Power & Light Company of Virginia (three occasions), Delmarva Power 22 & Light Company of Maryland (three occasions), West Penn Power Company, 23 Pennsylvania Electric Company (three occasions), Metropolitan Edison 24 Company (three occasions), New Jersey Power & Light Company (two 25 occasions), Buckeye Power, Inc., Duke Power Company (four occasions),
.* 26 Public Service Company of Indiana, Northern Indiana Public Service 27 Company, Detroit Edison Company, Centrsl Illinois Public Service 28 Company, Illinois Power Compe 3, acu ucky Utilities Company, New York 29 State Electric & Gas Corporation, Alabara Power Company (two occasions),
30 Oklahoma Gas and Electric Company, Public Service Company of Oklahoma, 31 Public Service Company of New Hampshire, Central Illinois Light Company, 32 Mississippi Power Company, Central Vermont Public Service Corporation, 33 (two occasions), Florida Power & Light Company, Ind,iana and Michigan 34 Electric Company, Appalachian Power Company, and Consumers Power 35 Company. ~
36 37 Q HAVE YOU TESTIFIED BEFORE OTHER COMMISSIONS? '
38 39 A Yes. I have testified before the Atomic Safety and Licensing Board 40 of the United States Atomic Energy Commission (now the Nuclear 41 Regulatory Commission) in Consumers Power Company (Midland Plant, 42 Units 1 and 2), AEC Docket Nos. 50-329A and 50-33A, and Alabama Power Company (Joseph M. Farley Nuclear Plants, Units 1 and 2),
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43 44 NRC Docket Nos. 50-348A and 50-364A.
45 46 Q BY WHOM IS YOUR FIRM RETAINED IN THIS PROCEEDING?
47 48 A By the Village of Sebewaing, the Village of Clinton, the City of 49 Croswell and Michigan Municipal Cooperative Power Pool, (hereinafter 50 referred to collectively as the " Cooperative-Municipal Intervenors").
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1Q WHAT WAS YOUR FIRM'S ASSIGNMETT IN THIS FROCEEDING?
2 3 A We were to review the filing for increased rates to the Cooperative-4 Municipal Intervenors by The Detroit Edison Company (Detroit Edison) 5 in this proceeding, its direct testimony and exhibits and any other 6 information we could obtain relating to Detroit Edison's system, 7 operations and sales to its customers. We were to determine whether 8 the cost of service filed by Detroit Edison accurately reflects the 9 cost of serving the Cooperative-Municipal Intervenors. In instances 10 where Detroit Edison's cost of service study was in error, we were 11 to Perform studies to determine the proper cost of service. Based 12 upon the properly adjusted cost of service study, we were also to 13 determine the overall rate of return Detroit Edison would realize 14 from the Cooperative-Municipal Intervenors under both its present 15 rates and its proposed rates.
16 17 In addition we were to determine a proper transmission rate to 18 be included in Detroit Edison's proposed tariff.
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20 Q WHO WILL BE THE WITNESSES FOR THE COOPERATIVE-MUNICIPAL INTERVENORS 21 AND TO WHAT WILL THEY TESTIFY?
22 23 A Witnesses testifying on behalf of the Cooperative-Municipal 24 Intervenors will be Dr. J. Leslie Livingstone, Dr. David C. Ewert,
. 25 Mr. Janjai Chayavadhanangkur and myself. In addition, testifying
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26 on behalf of the Village of Sebewaing, the Village of Clinton and 27 the City of Croswell will be Mr. Ralph E. Miller, and testifying 28 on behalf of Michigan Municipal Cooperative Power Pool (MMCPP) will 29 be Mr. John N. Keen. Witness Livingstone will testify to the proper 30 Allowance For Funds Used During Construction (AFUDC). He will also 31 testify to why Account 282 should be deducted from rate base and 32 why a portion of tax deductions related to construction work in 33 progress must be allocated to wholesale customers, rather than 34 allocating all of these tax deductions to the retail customers, as 35 Detroit Edison has done. Witness Ewert will testify concerning a 36 fair rate of return to be allowed to Detroit Edison. Witness 37 Chayavadhanangkur will testify to the proper interest expenses to 38 be used in calculating income taxes, the proper allocation of the 39 cost of service adjustments determined by witness Livingstone, the 40 Proper allocation factor to be used in allocating subtransmission 41 facilities and the proper transmission rate to be included in Detroit 42 Edison's proposed tariff. He will then take his own recommendations 43 and those of witnesses Livingstone, Evert, and me and apply them to 44 Detroit Edison's Period II Cost of Service Study to determine the 45 verall rate of return which would actually have been earned by 46 Detroit Edison from its sale to its Cooperative-Municipal Intervenors 47 in the test year under the present and proposed rates. Witness Miller 48 will testify concerning whether it is economically sound and in the 49 Public interest to include a stated rate for transmission service in Detroit Edison's proposed tariff, whether q,j 50 ,
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N) t 3 it is economically feasible for Croswell to purchase power from
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4 Sebewaing, whether there is a " price squee:c" in the relationship
- 5 between Detroit Edison's retail and wholesale rates and, if so, the 6 importance of such " price squeeze" in the determination of just and 7 reasonable wholesale rates, and whether the Period 11 projections 8 used by Detroit Edison to determine the proper revenue level re-9 ceived from its municipal customers are economically reasonable.
10 Witness Keen will testify concerning the organizational structure 11 and service area of Michigan Municipal Cooperative Power Pool.
12 13 Q WilAT WAS YOUR ASSIGNMENT IN THIS PROCEEDING?
14 1 15 A My assignment was to review the direct testimony and exhibits of 16 Detroit Edison filed in this proceeding and any other availabic, 17 relevant information available to determine whether any adjustments 18 were necessary to Detroit Edison's cost of rervice study in order 19 for it to reficct accurately the costs to Detroit Edison of serving 20 the Cooperative-Municipal Intervenors, other than to review possible 21 errors in the accounting procedures followed, in the allocation factors-22 used and in the determination of the proper interest expense to be 23 used in calculating income taxes. I was to furnish my determinations 24 to Witness Chayavadhanangkur who was to use them, along with his own
! 25 recommendations and those made by witness Livingstone to adjust
(,) Detroit Edison's cost of service study in order to calculate accurately 26 27 the ovetall rate of return earned by Detroit Edison from its sales to 28 Cooperative-Municipal Intervenors.
29 30 Q WilAT DATA HAVE YOU STUDIED IN ORDER TO PREPARE TilIS TESTIMONY AND 31 REIATED EX111 BITS?
32 f 33 A I have reviewed the filing made by Detroit Edison, including the 34 testimony and exhibits submitte,d by its witnesses and certain
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35 additional information concerning its operations which Detroit 36 Edison supplied at the request of FPC Staff and the Cooperative-37 Municipal Intervenors. In addition I have reviewed Detroit Edison's 38 1973 and 1974 FPC Forms 1. I have also studied the prepared testimony 39 and exhibits submitted by the FPC Staff in this proceeding.
40 41 Q WOULD YOU PLEASE StBDIARIZE Tile RESULTS OF Tile STUDIES MADE BY YOU.
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- 43 A Yes. The Cooperative-Municipal Intervenor's studies show the I 44 f 11 Wi"S "
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45 46 1 Detroit Edison's estimated beginning of year plant 47 balances for Period II do not conform with the actual 48 balances for the.cnd of year 1974 as reported by 49 Detroit Edison in its FPC Form No. 1.
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V 1 '2. Detroit Edison's estimated Period II 2 depreciation expenses should be adjusted 3 to reflect the above mentioned error in 4 estimated beginning of year plant balances.
5 6 3. Detroit Edison erred in including in its 7 rate base certain investments in the form 8 of advances made by Detroit Edison to 9 Consolidation Coal Company.
10 11 4. Detroit Edison erred in the inclusion of 12 investment for preliminary surveys in its
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13 rate base.
14 15 5. Detroit Edison erred in projecting its accu-16 mulated deferred income taxes associated with 17 liberalized' depreciation.
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'6. Detroit Edison erred in allocating its net 20 general plant, less its directly assigned 21 inves tment, pool center investment and remote 22 control investment, based on the ratio of net 23 plant. The proper method of allocating its l
24 general plant is on the same basis as. salary (j 25 and wages are assigned to production, trans-26 mission, distribution and customer accounts.
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28 29 7. Detroit Edison erred in allocating the deprecia-30 tion expenses associated with general plant, less 31 pool investment depreciation expenses and remote 32 control depreciation expenses based on the ratio 33 of net plant. .The proper method of allocating 34 general depreciation expenses is to base it on 35 salaries and wages assigned to production, trans-36 mission, distribution, customer accounts and sales.
37 38 8. Detroit Edison erred in including purchased power 39 in the computation of its cash working capital 40 allowance of forty-five days' of its operating 41 expenses. -
42 43 9. Detroit Edison has properly offset its working 4
44 capital requirements by its income tax accrual.
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46 10. Detroit Edison erred by failing to offset its 47 working capital requirements by its property tax 48 accruals.
49 50 11. Detroit Edison's method of accounting for fuel j
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%/ 1 expenses and method 'of co11ceting fuel 2 adjustment revenues as derived from appli-3 cation of the fuel adjustment clause is not 4 proper for cost of service purposes. It does 5 not properly reflect this Commission's. require-6 ment of matching the projected revenues and 7 expenses incurred during the test year.
8 9 12. Detroit Edison erred by including station 10 equipment in its plant held for future use.
11 12 Q MR. ROGERS, HOW HAS DETROIT EDISON DEVELOPED ITS ELECTRIC PLANT IN 13 SERVICE BALANCES FOR PERIOD II?
14 15 A Detroit Edison has used the average of the beginning and end of year 16 projected electric plant balances in developing its average electric 17 plant balances for the test year.
18 19 Q D0 YOU ' AGREE WITH DETROIT EDISON'S USE OF THE AVERAGE OF THE BEGINNING 20 AND END OF YEAR PROJECTED EIECTRIC PLANT IN SERVICE BALANCES IN 21 DEVELOPING ITS ELECTRIC PLANT IN SERVICE FOR THE TEST PERIOD?,
22 23 A No. The use of the average of the beginning and end of year electric 24 plant balances does result in an approximation of the electric plant (j 25 in service for the test year; however, this approximation is not 26 adequate for rate making purposes. The use of the average of the 27 thirteen month end balances of electric plant in service during the 28 test year does adequately reflect average electric plant in service 29 for rate making purposes.and should,. therefore, be used. This method 30 accurately teflects the important concept of matching revenues and 31 expenses with plant in service during the test period for purposes 32 of cost of service determination.
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34 Q MR. ROGERS, HOW DID YOU DEVELOP DETROIT EDISON'S AVERAGE ELECTRIC 35 PLANT IN SERVICE FOR PERIOD II?
36 37 A In attempting to develop the thirteen month average ciectric plant 38 in service for the test period, the Cooperative-Municipal Intervenors 39 in its data requests E-1 and E-2, requested Detroit Edison to provide 40 the projected Period II monthly balances of its original cost of 41 electric plant in service and reserves for depreciation for electric 42 plant. Detroit Edison responded that monthly balances or original 43 cost of electric plant in service are not projected and that monthly ,
44 balances of reserves for depreciation are not historically deter-45 utned or projected. In light of this lack of information, I was 46 unable to develop the thirteen month average balances and have used 47 the average of the beginning and end of year electric plant balances 48 in developing the average electric plant in service for the test ,
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s Nd# 1 Detroit Edison, in developing its average of the beginning and 2 end of year balances, has used projected beginning of year plant 3 balances for Period II. These projected plant balances do not 4 conform with the actual balances reported in Detroit Edison's 1974 5 FPC Form 1. I have, therefore, used these actual beginning of 6 year plant balances in developing Detroit Edison's average of the 7 beginning and end of year balances for Period II.
8 9 Q I HAND YOU A DOCUMENT MARKED FOR IDENTIFICATION EXHIBIT (OFR-1).
10 IRIS EXHIBIT PREPARED UNDER YOUR SUPERVISION?
11 12 A Yes.
13 14 Q WILL YOU PLEASE EXPLAIN THIS EXHIBIT.
15 16 A Yes. This Exhibit is entitled "The Detroit Edison Company --
17 Cooperative-Municipal Intervenors' Revised Average of the Beginning .
18 and End of Year Original Cost of Electric Plant in Service Balances 19 -- Period II." Column (c) of this Exhibit shows the actual beginning 20 of year plant balances. Column (f) shows that the end of year 21 balances were developed by adding to and subtracting from the actual i 22 beginning of year balances, projected plant additions and projected 23 plant retirements respectively. Column (g) shows the revised average 24 of the beginning and end of year original cost of electric plant
. 25 in service balances.
(3/ 26 27 Q I HAND YOU A DOCUMENT MARKED FOR IDENTIFICATION EXHIBIT (OFR-2).
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28 WAS THIS EXHIBIT PREPARED UNDER YOlR SUPERVISION?
29 30 A Yes.
31 4 32 Q WILL YOU PLEASE EXPLAIN THIS EXHIBIT.
33 34 A Yes. This Exhibit is entitled "The Detroit Edison Company --
35 Cooperative-Municipal Intervenors' Development of the Revised 36 Average of the Beginning and End of Year Depreciation Reserve
! 37 Balances -- Period II." It consists of two pages. Page one is 38 entitled "Ihe Detroit Edison Company -- Cooperative-Municipal 39 Intervenors' Revised Average of the Beginning and End of Year 1 40 Depreciation Reserve Balances -- Period II." Column (c) shows 41 the actual beginning of year depreciation, reserve balances. Column 42 (f) shows that the end of year balances were developed by adding 43 to and subtracting from the actual depreciation reserve balances, 44 revised projected depreciation expenses and net salvage values 45 respectively. Column (g) shows the revised average of the beginning 46 and end of year depreciation reserve balances.
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47 48 Page 2 of this Exhibit is entitled "The Detroit Edison Company --
49 Cooperative-Municipal Intervenors' Determination of Detroit Edison's 50 Projected Net Salvage Value for its Electric Plant Retirements --
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42/ 1 Period II." Column (g) shows that projected net salvage value 2 was developed by taking the not Period II increase in projected 3 depreciation reserves, as developed in Column (e), and subtracting 4 the projected Period II depreciation expenses, as shown in Column
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6 7 Q I Fld?D YOU A DOCUMENT MAP 2ED FOR IDENTIFICATION EXHIBIT (OFR-3).
8 WAS THIS ETHIBIT PREPARED UNDER YOUR SUPERVISION?
9 10 A Yes.
11 12 Q WILL YOU PLEASE EXPLAIN THIS EXHI3IT.
13 14 A Yes. This Exhibit is entitled "The Detroit Edison Company --
. 15 Cooperative-Municipal Intervenors' Comparison of Average Net Electric 16 Plant in Service Per Detroit Edison, Staff and Cooperative-Municipal 17 Intervenors -- Period II." Column (e) shows that Detroit Edison 18 developed its average net plant in service to be $2,469,050,000; 19 Column (h),shows that Staff devel oped Detroit Edison's average net 20 plant to be $2,454,788,000 and Column (k) shows that Cooperative-21 Municipal Intervenors developed Detroit Edison's average net plant 22 in service to be $2,454,761,727.
23 24 Q MR ROGERS, HOW UILL THE AB3VE MENTIONED ADJUSTMENT TO DETROIT 25 EDISON'S AVERAGE PLANT IN SERVICE AFFECT DETROIT EDISON'S PROJECTED tl 26 DEPRECIATION EXPENSES?
27 28 A Detroit Edison's projected depreciation expenses are based on its 29 projected verage of the beginning and end of year . depreciable 30 plant balances. Since I have revised Detroit Edison's average 31 plant balances, and therefore depreciable plant balances, by using 32 actual beginning of year balances in developing its avens ge of the
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33 begir".ng and end of year plant balances, Detroit Edison's projected 34 depret tion expenses must also be revised.
35 36 Q I HAND YOU A D3CUMENT MARKED FOR IDENTIFICATION EXHIBIT (OFR-4).
37 UAS THIS EXHIBIT PREPARED UNDER YOUR SUPERVISION?
38 39 A Yes.
40 41 Q WILL YOU PLEASE EXPLAIN THIS EXHIBIT. ,
42 43 A Yes. This Exhibit is entitled "The Det'roit Edison Company --
44 Cooperative-Municipal Intervenors' Development of Detroit Edison's-45 Depreciation Expenses -- Period II " I~t consists of two pages.
46 Page one is entitled "The Detroit Edison Company -- Cooperative-47 Municipal Intervenors' Revised Deprecietion Expenses -- Period II."
48 Column (c) shows that the average depreciable plant was developed 49 using the actual beginning of year depreciable plant balances 50 (original cost of electric plant less land) and the revised projected
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V 1 Period II depreciable plant balances. Column (g) shows that the 2 revised projected Period II depreciation expenses were calculated 3 by multiplying the average Period II revised depreciable plant by 4 the projected Period II depreciation rates.
5 6 Page two is entitled "The Detroit Edison Company -- Cooperative-7 Municipal Intervenors' Estimated Depreciation Rates by Function --
8 Period II." Column (g) shows that the projected Period II deprecia-9 tion rates by function were calculated by dividing Detroit Edison's 10 Proj ected Period II depreciation expenses, Column (f), by its 11 Projected Period II average depreciable plant balances, Column (e).
12 13 Q WHY ID YOU DISAGREE WITH DETROIT EDISON IN ITS INCLUSION OF COAL 14 PRODUCTION INVESTMENT IN ITS RATE BASE?
15 16 A Detroit Edison has included $7,230,000 of coal production investment 17 which represen ts a loan made by it to Consolidation Coal Company 18 (Consolidated) at 67. per annum. This identical issue has been ex-19 tensively reviewed in the initial decision in The Detroit Edison 20 Company, Docket No. E-7906, issued February 21, 1974, which is now 21 awaiting final Commission determination. Presiding Administrative 22 Law Judge Levant states on page 6 of his initial decision that under 23 the term of the Installment Loan Agreement, entered into July 30, 24 1968, the BTU value of coal deliveries is credited against the 25 Principal and interest due on the loan. The arrangement assures
, V 26 Detroit Edison of a coal supply forAminimum of 25 years for its 27 Monroe Power Plant at adiscounto(27c Judge Levant 28 then found: "It is concluded that ,thTre'pgr-tony is no reasonable basis for 29 including the loan to Consolidated in the rate base. The allocated ~
30 fuel cost in the cost of service'should be adjusted to exclude 31 therefrom the benefit attributable to the 6 percent interest earned 32 on the loan. Thus, Applicants stockholders will carn a 6 percent 33 return on the loan " g#qp1/-
34 I agree with Judge Levant anQLLa'
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gree with etroit Edison's inclu-35 36 sion of the coal production investment in its rate case because as 37 indicated by Judge Levant that Detroit Edison's arrangement for a 38 long-term coal supply is not unique in the country. Other electric 39 utilities have entered into similar agreements where both the 40 utility and the supplier are mutually benefited. Such an arrange- i 41 cent reficcts sound utility management which ultimately results 42 in a benefit to both the stockholder and the consumer. Also, if !
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43 such an investment was allowed to be included in the rate base -it l 44 w uld result in an excessive return from the Cooperative-Municipal )
45 Intervenors.
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47 Q I HAND YOU A DOCUMENT MARKED FOR IDENTIFICATION EXHIBIT (OFR-5).
48 UAS THIS EXHIBIT PREPARED UNDER YOUR SUPERVISION?
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50 A Yes.
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1 Q WILL YOU PLEASE EXPLAIN THIS EXHIBIT.
2 3 A Yes. This Exhibit is entitled "The Detreit Edison Company --
4 Cooperative-Municipal Intervenors' Exclusion of Detroit Edison's Ad-5 vance to consolidation Coal Company From Detroit Edison's Rate 6 Base -- Period II." It consists of one page and it shows that 7 Detroit Edison has allocated $4,000 of its advance under the loan to 8 Consolidation Coal Company to Sebewaing, $3,000 to Clinton, 9 $4,000 to Croswell and $30,000 to MMCPP. In this Exhibit the 10 Cooperative-Municipal Intervenors have excluded these amounts 11 of Detroit Edison's advance under the loan to Consolidation Coal 12 Company from the rate base assigned to these four customers in 13 the Cooperative-Municipal Intervenors' cost of service study.
14 15 Q I HAND YOU A DOCUMENT MARKED FOR IDENTIFICATION EXHIBIT (OFR-6).
16 UAS THIS EXHIBIT PREPARED UNDER YOUR SUPERVISION?
17 18 A Yes.
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20 Q WILL YOU PLEASE EXPLAIN THIS EXHIBIT.
21 22 A Yes. This Exhibit is entitled "The Detroit Edison Company --
23 Cooperative-Municipal Intervenors' Additional Fuel Expense Due To 24 the Exclusion of Detroit Edison's Advance to Consolidation Coal 25 Company from Detroit Edison's Rate Base -- Period II." It consists tM
' 26 of one page and it shows the additional fuel expenses to the four ,
27 Cooperative-Municipal Intervenors to be $2,640 based on 6% interest 28 per annum. I have done this in accordance with Judge Levant's 29 initial decision.
30 31 Q WHY DO YOU DISAGREE WITH DETROIT EDISON IN ITS INCLUSION OF PRELIMINARY 32 SURVEYS IN ITS RATE BASE?
33 34 A I disagree with Detroit Edison's inclusion of a $1,000,000 expendi-35 ture for preliminary surveys in its total electric rate base, 36 because such surveys are conducted for construction purposes and 37 are eventually charged to account 107, construction work in progress.
38 At the present time the Commission has not allowed any utility to 39 include construction work in progress in its rate base and, therefore, 40 it should be excluded from Detroit Edison's rate base.
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- 42 Q I HAND YOU A DOCUMENT MARKED FOR IDENTIFICATION EXHIBIT (OFR-7).
43 WAS THIS EXHIBIT PREPARED UNDER YOUR SUPERVISION?
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l 45 A Yes. .
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47 Q WILL YOU PLEASE EXPLAIN THIS EXHIBIT.
48 49 A This Exhibit is entitled "The Detroit Edison Company -- Cooperative-50 Municipal Intervenors' Elimination of Preliminary Surveys - from U-i
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Q 1 Detroit Edison's Rate Base -- Period II." It consists of one page j 2 and shows that the allocated preliminary surveys eliminated by the l 3 Cooperative-Municipal Intervenors decreases the allocated rate base
, 4 to the Cooperative-Municipal Interveni rs by $3,000.
5 6 Q MR. ROGERS, EAVE YOU ADJUSTED DETROIT EDISON'S AVERAGE BALANCE OF 1 7 ACCOUNT 232, ACCUMULATED DEFERRED INCOME TAXES--LIBERALIZED DEPRE-l 8 CIATION, WHICH IS CREDITED TO RATE BASE?
i 9 10 A Yes, Detroit Edison's projected beginning of year balance of Account 11 282, Accumulated Deferred Income Taxes - Liberalized Depreciation ,
12 does not conform with its actual balance as reported in its 1974 FPC l 13 Form 1. In agreement with my adjustments to Detro.it Edison's average i 14 plant in service balances, I have used the actual beginning of year 15 balance rather than Detroit Edison's projected balance in calculating 16 the average of the beginning and end of year balances of Account 282.
17 4 18 Q I HAND YOU A DOCUMENT MARKED FOR IDENTIFICATION EXHIBIT (OFR-8).
19 WAS THIS EXHIBIT PREPARED UNDER YOUR SUPERVISION? i
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l 20 I 21 A. Yes.
22 23 Q WILL YOU PLEASE EXPLAIN THIS EXHIBIT.
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24 i , , , 25 A This Exhibit is entitled "Ihe Detroit Edison Company -- Cooperative-1
'# 26 Municipal Intervenors' Comparison
- of the Average of the Beginning _
I 27 and End of Year Balances of Account 282, Accumulated Deferred
- 28 Income Taxes -- Liberaliced Depreciation, Per Detroit Edison,
! 29 Staff and the Cooperative-Municipal Intervenors -- Period II."
30 As shown in Column (c), Detroit Edison claims an average balance 31 of $203,500,000, as a reduction to rate base due to accumulated 32 deferred income taxes related to liberalized deprecia* ion, of 33 which they have allocated $672,000 to the Cooperative-Municipal 34 Intervenors' as shown in Column (d). Staff has developed an 35 updated average balance of $197,911,000, as shown in Column (e),
l 36 of which they have allocated $618,000 to the Cooperative-Municipal
, 37 customers, as shown in Column (f). Column (g) shows that the 38 Cooperative-Municipal -Intervenors developed an updated average 39 balance of $198,683,185 of which they have allocated $619,362 to l 40 the=selves. It can casily be determined that Detroit Edison's 41 Period II average of Account 282 is $5,589,0C0 greater than Staff's 42 average and $4,816,815 greater than Cooperative-Municipal Inter-43 venors' average.
! 44 45 Q IN YOUR
SUMMARY
YOU STATE THAT YOU DISAGREE WITH DETROIT EDISON'S i 46 METHOD OF ALLOCATING ITS NET GENERAL PLANT. WILL YOU PLEASE EXPLAIN 47 FM.
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. l 1 A Detroit Edison's method of allocating its joint use general plant is 3
2 improper and illogical because, accordhas to the FPC's Uniform 3 System of Accounts, the general plant is composed chiefly of 4 Detroit Edison's faciliities which are more related to the number 5 f its c=ployees than to the amount of its investments. FPC's 6 Unif re System of Accounts describe general plant to be: (1) land 7 and land rights, (2) Structure and improvements, (3) Office furniture g and equipment, (4) Transportation equipment, (5) Store equipment, 9 (6) Tools, shop and garage equipment, (9) Communication equipment, 10 (10) P.iscellaneous equipment, and (11) Other tangibic property.
11 I believe the facilities classified in general plant have a direct 19' relationship to the number of employees engaged in such work, and 13 should, therefore, be properly allocated according to salaries 14 and wages. I have assigned the balance of the general plant 15 accounts (other than the directly assigned, the pool center and 16 the remote control facilities) to production, transcission, dio-17 tribution, custo=er accounts and sales according to the ratio of 18 salaries and wages, and then allocate to the wholesale customers 19 based on the production, transmission, distribution, customer 20 accouhts and sales allocation factors.
21 3; Q I HAND YOU A D3CUMENT PARKED FOR IDENTIFICATION D3IEIT (OFR-9).
23 WAS THIS D*HIBIT PPl?AFID UNDEP. YOUR SUPERVISION?
24 25 A Yes.
(v) 26 27 Q WILL YOU P2ASE D2IAIN THIS DIIBIT. .
28 29 A Yes. This Exhibit is entitled "Ihe Detroit Edison Company --
30 Cooperative-Municipal Intervenors' Functionalization of Net 31 General, Plant -- Period II" and it consists of two pages. Page 32 one of this Exhibit is entitled "The Detroit Edison Co=pany --
33 Cooperative-Municipal Intervenors' Functionalization of Net 34 General Plant -- Period II". It uses the proper method of allo-35 cating net joint use general plant facilities to production, trans-30 mission, distribution, custo=er accounts and sales by using the 37 salaries and wages assigned to production, transmission, distri-3S bution, customer accounts and sales. Page 2 of this Exhibit is entitled "The Detroit Edison Company -- Cooperative-Municipal
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39 40 Intervenors' Distribution of Salaries and Wages -- Period II,"
41 It shows the salaries and wages per books assigned to production, 42 transmission, dist.ribution, customer accounts and sales.
43 44 Q WILL YOU PLEASE D21AIN WHY YOU DISAGREE WITH DETROIT EDISON'S 45 METHOD OF ALLOCATING GENEPAL DEPRECIATION EXPENSES AND WHAT YOU 46 WOULD CONSIDER IO BE THE PROPER METHOD.
47 I 48 A Yes. I disagree with Detroit Edison's method for the same reasons 49 that I disagree with its method of allocating its net general plant
_j 50 as I previously explained.
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- (c/ 1 The proper method of allocating Detroit Edison's general deprecia-2 tion expenses is to assign such expenses to production plant, 3 transmission plant, distribution plant, customer accounts and 4 sales on the basis of salaries and wages.
5 6 Q I HAND YOU A DOCUMENT MARKED FOR IDENTIFICATION EXHIBIT (OFR-10).
7 WAS THIS EXHIBIT PREPARED UNDER YOUR SUPERVISION?
8 9 A Yes.
10 11 Q WILL YOU PLEASE EXPLAIN THIS EXHIBIT.
12 13 A This Exhibit is entitled "The Detroit Edison Company -- Cooperative-14 Municipal Intervenors' Functionalization of General Depreciation 15 Expenses -- Period II." It functionalizes general depreciation 16 expenses amounting to $2,713,635 to production plant, transmission 17 plant, distribution plant, customer accounts and sales based on 18 distribution of salaries and wages in those five functionalized 19 groups. .
20 21 Q YR. ROGERS, WHY DO YOU DISAGREE WITH DETROIT EDISON'S CALCUATION OF 22 ITS CASH WRKING CAPITAL REQUIRE'4ENTS?
23 24 A In calculating its cash working capital requirements, Detroit Edison 25 has taken one eighth of its total operation and maintenance expenses.
\#/ 26 This Commission, in determinin'g the proper cash working capital 27 requbc ements, has consistently used the formula of 45 days (1/8th 28 of the annual amount) of its electric operation and maintenance i 29 expenses less the cost of. purchased power. Detroit Edison has in-3 30 cluded as a component of its cash working capital requirements 1/8th 1
31 of its purchased power expenses of $9,416,000. Not only has Detroit 32 Edison failed to justify such an adjustment, it has failed to 33 ccmment in any way whatsoever as to why this increase in cash 34 working capital requirements is necessary. I have followed long-35 standing Cocmission precedent of calculating the cash working capital 36 requirements as 1/8th of the operat. ion ani maintenance expenses 37 less purchased power expenses, as did Staff.
38 39 Q I HAND YOU AN EXHIBIT MARKED FOR IDENTIFICATION EXHIBIT (OFR-ll).
40 WAS THIS EXHIBIT PREPARED UNDER YOUR SUPERVISION?
41 .
42 A Yes.
43 44 Q PLEASE EXPLAIN THIS EXHIBIT.
45 1 46 A This Exhibit is entitled "The Detroit Edison Company -- Cooperative-
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47 Municipal Intervenors Elimination of 1/8th Purchased Power Expense 48 From Cash Working Capital Requirements -- Period II." As shown in 49 Column (c) of this Exhibit, Detroit Edison has increased its cast 1 50 working capital requirements by $1,177,000,1/8th of its purchased
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9 kw/ 1 power expense, of which $6,625 has been allocated to the Cooperative-2 Municipal Intervenors as shown in Column (d). Both Staff and 3 Cooperative-Municipal Intervenors have eliminated this adjustment 4 as shown in Columns (e) and (f).
5 6 Q MR. ROGERS, DO YOU AGREE WITH DETROIT EDISON IN CREDITING WORKING 7 CAPITAL REQUIREMENTS WITH ACCRUED INCOME TAXES?
8 9 A Yes. In developing its working capital requirements, Detroit Edison 10 has credited its requirements by $9,613,000 in accrued Michigan 11 and Federal income taxes. Although Detroit Edison does not show 12 the development of this $9,613,000 in income tax accruals for 13 Period II, it does show its development of the comparable figure 14 for Period I in Statement F. Detroit Edison has used the average 15 of thirteen monthly balances of the Michigan and Federal income 16 taxes accrued in Account 236. These balances are the result of 17 the lag between the time Detroit Edison collects revenues for 18 inceme taxes from its customers and the thee Detroit Edison actually 19 has to pay,its income taxes. The $9,613,000 is therefore the average 20 amount of accrued income taxes on hand for Period II that are avail-21 abic as working capital as Detroit Edison has shown. ,
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23 Staff did not credit Detroit Edison's working capital requirements 24 by income tax accruals citing this Commission's order in Florida 25 Gas Transmission Company, Opinion No. 611, dated February 16, 1972.
\e/ 26 Staff has quoted this Opinion as stating that income ' tax accruals 27 "are no longer of such substr ce, proportion and continuity that they 28 may be relied upon as a source of working capital." I would like 29 to note that this Opinion was based upon one particular company's 30 situation and upon a test period ending July 31, 1967. Florida 31 Gas Transmission Company's income tax accruals may not have been 32 of substance in July, 1967, but I believe that Detroit Edison's 33 estimated income tax accruals for 1975 of $9,613,000 are of sub-34 stance. Also, based upon Detroit Edison's increase in average in-35 come tax accruals from Period I to Period II, an increase from 36 $2,792,000 to $9,613,000 respectively or a 345% increase,,I believe 37 that not only will these accruals continue to be of substance that 38 can be relied upon as a source of working capital, but that these 39 cecruals will be of increasing substance that can be increasingly 40 relied upon as a source of working capital. I have therefore 41 agreed with Detroit Edison in crediting i,ts working capital require-42 ments by $9,613,000 of average accrued income taxes.
43 44 Q MR. ROGERS, DO YOU HAVE ANY OTHER ADJUSTMENTS 70 MAKE TO DETROIT 45 EDISON'S CIAIMED WORKING CAPITAL REQUIREMENTS?
46 47 A Yes. I have further credited Detroit Edison's claimed working capital
, 48 requirements with average accrued property taxes of $108,851,704.
49 The Michigan Public Service Commission in determining Detroit Edison's 50 proper working capital requirements in retail proceedings has V
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Eu/ 1 consistently credited these requirements with accrued property 2 taxes. Since I am unfamiliar with Detroit Edison's timetabic of 3 collecting revenues for and its actual payment of local property 4 taxes, I have based my adjustment on the apparent fact that, as has 5 been previo'u sly determined by the Michigan Public Service Commission, 6 Detroit Edison does have these property tax accruals available as 7 a source of working capital. Detroit Edison apparently agrees with 8 this treatment of property tax accruals as a credit to working 9 capital requirements, since in its last application to the Michigan 10 Public Service Commission for an increase in revenue from its 11 retail customers it did, in its filing, make such an adjustment to 12 its working capital requirements. Based on a 1974 test year, Detroit 13 Edison credited its working capital requirements by $SS,562,000 in 14 accrued property taxes of which it allocated $36,473,000 to its 15 retail customers. I am therefore agreeing with Detroit Edison's 16 treatment of property tax accruals in developing its working cap-17 ital requirements as filed before the Michigan Public Service Com-18 mission. I would like to add that consistant with my previous 19 discussion of crediting working capital requirements with income 20 tax accruals, the Michigan Public Service Commission also agrees 21 with such an adjustment.
22 23 Q I HAND YOU A DOCUMENT MAR 12D FOR IDENTIFICATION EXHIBIT (OFR-12).
24 WAS THIS EXHIBIT PREPARED UNDER YOUR SUPERVISION?
25 (e) 26 A Yes.
27 28 Q WILL YOU PLEASE EXPLAIN THIS EXHIBIT.
29 30 A This Exhibit is entitled "The Detroit Edison Company -- Cooperative-31 Municip.t1 Intervenors' Inclusion of Accrued Property Taxes as a 32 Credit to Detroit Edison's Working Capital Requirements -- Period 33 II." As shown in Column (c), the Cooperative 7 Municipal Intervenors 34 have reduced Detroit Edison's working capital requirements by 35 $10S,851,740, of which they have allocated $334,157 to the Cooperative-36 Municipal Intervenors, as shown in Column (d).
37 38 Q I HAND YOU A DOCUMENT MARKED FOR IDENTIFICATION EXHIBIT (OFR-13),
39 WAS THIS EYHIBIT PREPARED UNDER YOUR SUPERVISIM?
40 41 A Yes.
42 - i 43 Q WILL YOU PLEASE EXPLAIN THIS EXHIBIT.
44 l 45 A This Exhibit is entitled "The Detroit Edison Company -- Comparison i 46 of Working capital Requirements Per Detroit Edison, Staff and the 47 Cooperative-Municipal Intervenors -- Period II." As shown in Column l
48 (c), Detroit Edison has developed its working capital requirements 49 to be $207,311,000. As shown in Column (d), Staff has developed 1
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50 Detroit Edison's working capital requirements to be $215,747,000 or )
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(a/ 1 $8,436,000 more than the amount Detroit Edison claims, as shown in 2 Column (f) . As shown in Column (e), the Cooperative-Municipal 3 Intervenors have developed Detroit Edison's working capital require-4 ments to be $97,282,000 or $110,029,000 less than the amount Detroit 5 Edison claims, as shown in Column (g), and $118,465,000 less than 6 the amount developed by Staff, as shown in Column (h).
7 8 Q MR. ROGERS, WOULD YOU PLEASE COFMENT ON DETROIT EDISOE'S DEFERRED 9 FUEL ACCOUNTING PRACTICES.
10 11 A Yes. Prior to 1974 Detroit Edison charged all of its fuel costs to 12 operations as they were incurred. Due to rapidly increasing fuel 13 costs and to the lag between the time in which these costs were .
14 incurred and the thne in which they were recovered under the appli-15 cable fuel adjustment clauses, Detroit Edison was experiencing an 16 increasing mismatch between its fuel expenses and its fuel revenues
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17 collected under the various fuel adjustment clauses. Detroit Edison 18 experienced a one-month lag in its fuel adjustment revenue collec-19 tions.on.i,ts wholesale business and ut to a two-month lag on its 20 retail business.
21 i 22 However, with the authorization of the Michigan Public Service Com-23 mission, Detroit Edison changediits method of accounting for changes
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24 in fuel expenses recoverable under its customers' various fuel ad-25 justment clauses. Effective January 1, 1974, Detroit Edison has L) 26 been deferring all increases in fuel expenses to the period in which 27 these increased expenses are recovered through the various fuel ad-28 justment clauses.
29 30 As stated by Detroit Edison in its response to Staff's data request, '
31 Power-8, " Deferred Fuel Accounting was adopted at Detroit Edison 32 in 1974 to accomplish a better matching of fuel cost and the 33 resultant revenues."
34 35 Q MR. ROGERS, HOW DOES DETROIT EDISON'S TREATMENT OF DEFERRED FUEL 36 ACCOUNTING AND ITS APPLICATION OF THE VARIOUS FUEL ADJUSEENT CLAUSES 37 AFFECT ITS COST OF SERVICE FOR PATE MAKING PURPOSES?
38 39 A Under Detroit Edison's current practices in regard to recording 40 fuel expenses and fuel revenues, both Detroit Edison's book expenses 41 and book revenues projected for the test period do not properly re-42 ficct, for cost of service purposes, their actual experience in the 43 test period. As shown in Statement M, Detroit Edison has deferred 44 $8,573,000 in fuel expenses on its books for the test period.
45 However, for cost of service purposes, Detroit Edison has added 46 back this amount to its test period operating expenses. Detroit 47 Edison explains this adjustment in response to Staff's data request, 48 Power-8. Detroit Edison states that, "In order to properly show 49 the O&M expenses to be incurred in 1975, the cost of service includes 50 both the fuel expense forecasted to be booked and the fuel expense
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(a) 1 deferred.
2 3 Although Detroit Edison has properly adjusted its operating expenses 4 for the test period, it has failed to make a corresponding adjustment 5 to its revenues. For the same reason Detroit Edison adjusted its 6 operating expense, the revenues collected under the various fuel 7 adjustment clauses based on test period fuel expenses but not 8 recorded until af ter the test period, due to the lag in the appli-9 cntion of these fuel adjustment clauses, should be added back to 10 the test period revenues collected by Detroit Edison. This adjust-11 ment will properly match the fuel expenses incurred and the corres-12 ponding fuel adjustment revenues received.
13 14 Q MR. ROGERS, HOW WOULD YOU PROPOSE TO ADJUST FUEL ADJUSTMENT REVENUES 15 IN ORDER TO PROPERI.Y MATCH THE TEST PERIOD REVENUES WITH EyPENSES FOR 16 COST OF SERVICE PURPOSES?
17 18 A The fuel adjustment clause applicable to the Cooperative-Municipal 19 Intervenors results in a one-month lag in the collection of fuel 20 adjustment revenues. In other words, the current monthly fuel adjust-21 cent factor, calculated using the current month's fuel expenses, is 22 not applied to the Cooperative-Municipal Intervenors' kilowatt-hour 23 purchases until the following month. In order to match test period 24 expenses with test pe'riod revenues for cost of service purposes, I 25 have st= ply clininated this one month lag -- I have applied the
(,) 26 current mon th's fuel adjustment factor to the current month kilowatt-27 hour purchases of the Cooperative-Municipal customers. This adjust-28 ment will properly match test period revenues with expenses for cost 29 of service and rate making purposes.
30 31 Q I HAND YOU A DOCUMENT MARKED FOR IDENTIFICATION EXHIBIT (OFR-14).
32 WAS TFIS EXHIBIT PREPARED UNDER YOUR SUPERVISION?
33 34 A Yes.
35 36 Q WILL YOU PLEASE EXPLAIN THIS EXHIBIT.
37 38 A Yes. This Exhibit is entitled "The Detroit Edison Company -- Accrual 39 Analysis of the Cooperative-Municipal Intervenors' Fuel Adjustment 40 Revenues -- Period II." Column (c) of this Exhibit shows the kilowatt-41 hours purchased during the test period by the Cooperative-Municipal 42- customers. Column (d) shows the fuel. adjustment factor utilizing 43 the current month fuel expense per kilowatt-hour and Colu=n (c) shows
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44 the resulting dollars from such application. Column (f) shows the.
45 fuel adjustment factor as applied by Detroit Edison and Column (g)
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46 shows the resulting dollars derived therefrom as revenue received.
! 47 Column (h) shows the difference between Detroit Edison's lagging fuel l 48 cost recovery and the current fuel cost recovery, which results in
! 49 test period revenue differences of $54,283. I would like to note 50 that Detroit Edison has allocated $51,000 in deferred fuel expenses
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bal 1 to the Cooperative-Municipal Intervenors and that my adjustment will
,2 properly match revenues with expenses.
3 4 Q MR. ROGERS, WHY DO YOU DISAGREE WITH DETROIT EDISON'S INCLUSION OF S STATION EQUIFYENT IN PLANT HELD FOR FUTURE USE IN THE RATE BASE?
6 7 A Detroit Edison has estimated their average of the beginning und end 8 of year balance of electric plant held for future use to be 9 $24,000,000. I have two disagreements with this estimate. First, 10 I disagree with Detroit Edison's estbnated average balances. In 11 developing my average beginning and end of year balances of plant 12 held for future use, I have used actual data, taken from Detroit 13 Edison's 1974 FPC Form 1, as the beginning of year balances and I 14 have used the estimated end of year balances of plant held for future 15 use as supplied by Detroit Edison in response to the Cooperative-16 Municipal Intervenors' Data Request L-1.
17 18 Secondly, in agreement with Staff and the Presiding Administrative 19 Law Judge',s Initial Decision in The Detroit Edison Company, Docket 20 No. E-7906, issued February 21, 1974, I have excluded Detroit Edison's 21 investment in transmission station equipment and distribution station 22 equipment from plant held for future use. In the footnote to Account 23 105, Electric Plant Held for Future Use, the Uniform System of Accounts 24 states " materials and supplies, meters and transformers held in 25 reserve, and normal spare capacity of plant in service shall not ud 26 be included in this account."
27 28 In Detroit Edison's 1974 Form 1, Page 405-a, Electric Plant Held 29 for Future Use (Account 105), Detroit Edison has noted the inclu-30 sion of station equipment in this account by describin's such equip-31 ment as " numerous items purchased in advance of construction such.
32 as circuit breakers, relays, switchgear, panels, etc." The inclusion 33 of these items as plant held for future use obviously does not con-34 form with the Uniform System of Accounts and I have therefore deducted 35 such balances.
36 37 Q I HAND YOU A DOCUMENT MARKED FOR IDENTIFICATION EXHIBIT (OFR-15).
38 WAS THIS EXHIBIT PREPARED UNDER YOUR SUPERVISION?
39 40 A Yes.
41 '
42 Q WILL YOU PLEASE EXPLAIN THIS EXHIBIT.
43 44 A Yes. This Exhibit is entitled "The Detroit Edison Company --
45 Cooperative-Municipal. Intervenors' Development of Plant Held for 46 Future Use -- Period II." Column (c) shows the beginning of year 47 balances as reported by Detroit Edison in its 1974 FPC Form 1.
48 Column (d) shows Detroit Edison's estimated end of year balance.
49 Column (e) shqws the average of the beginning and end of year plant i 50 held for future use balances. Line 9 of Column (e) shows the total
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i l V 1 average to be-$26,749,734 and Line 10 of Column (c) shows the total i 2 average excluding station equipment to be $19,629,778.
3 4 Q I 11AND YOU A DOCUMENT MARKED FOR IDENTIFICATION EXIIIBIT (OFR-16),
5 UAS TilIS EXHIBIT PREPARED UNDER YOUR SUPERVISION?
6
. 7 A Yes.
8 9 Q WILL YOU PLEASE EXPLAIN TilIS EXHIBIT, ,
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, 11 A Yes, This Exhibit is entitled "Tne Detroit Edison Company --
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12 Cooperative-Municipal Intervenors' Comparison of Average Plant IIcid
- 13 for Future Use -- Period II." Column (c) shows that Detroit Edison
- 14 has projected the average plant held for future use for Period II to 15 be $24,000,000 or $4,370,222 more than the Cooperative-Municipal 16 Intervenors' have determined, as shown in Column (c).
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