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Date Subject: - Ori inator's <br />8/18/82 HL&P RATE INCREASE 1~I~ 2 Poe 6 <br />r~{ials <br />• <br />a return on the unamortized balance of its investment less accumulated deferred taxes. However, 73% <br />would be recovered during the five-year period between 1983-1987. We recommend disallowance of <br />$388 million actually attributable to the Project, including $324 million for plant and $64 million for <br />nuclear fuel, whether categorized as an extraordinary loss or as an item in the rate base under <br />"Construction Work In Progress", as explained below. <br />The reason for disallowance as an extraordinary loss is that HL&P in testimony filed with the <br />City as a part of its application admits that no decision has been made by the Company as to whether <br />to cancel the plant. Such a decision is predicated on "appropriate action by the (Public Utility) <br />Commission which provides for recovery of the investment in the Project through rates " Jordan, Vol. <br />1, p.6. In other words, HLdcP is asking the City and ultimately the Public Utility Commission to <br />indicate the amount of recovery they will be granted before they will decide whether or not to build <br />the plant. <br />Our position is that until there has been a formal cancellation of HL&P's certificate to build <br />Allen's Creek Nuclear Project ("Allen's Creek"), it is untimely and inappropriate to recover any funds <br />for such cancellation. <br />Because the recover of Allen's Creek is disallowed under "Extraordinary Losses", the alternative <br />for recouping funds would be to include it in rate base or "Construction ti'Vork In Progress". <br />However, because the Company has stated that they have virtually ceased investing funds in the <br />Allen's Creek and do not consider it to be economically feasible, such item is not properly included in <br />rate base as Construction j'; ork In Progress. Eliminating Allen's Creek from the case reduces the <br />Company's $336 million rate increase request by more than $90 million. <br />South Texas Nuclear Project <br />Another major consideration for analysis and treatment is the South Texas Nuclear Project <br />("STNP"). HL&P recently filed with the City a report by Bechtel Power Corporation, the proposed new <br />architect/engineer for the STNP, which indicates an estimated cost of $5.5 billion to complete the <br />project. While blaming Nuclear Regulatory Commission changes in rules and requirements along with <br />management deficiencies of Brown Ec Root, the former architect/engineer and contractor for STNP, <br />the costs for the project have soared from estimates of $790 million to $5.5 billion. The PUC has <br />ignored the reasons for such cost escalations in the past, but our opinion is that the burden upon the <br />ratepayer to finance this project is rapidly becoming impermissible and it is extremely appropriate to <br />address the situation at this time. While the Public Service Department had neither the time nor <br />manpower to investigate all allegations of mismanagement in the operation of the Project, there likely <br />will be a full inquiry as a result of the suit filed by HLacP against Brown be Root. We are <br />recommending certain rate treatment based on the outcome of the court's findings. <br />C.H. Guernsey & Company has made the following reQOmmendations affecting both present and <br />future rate treatment, in which we concur (see Blumenthal testimony): <br />1) Eliminate the equity portion of Allowance for Funds Used During Construction ("AFUDC") when <br />there was no construction under way. This includes 12/1/79-10/31/80; 12/1/81-3/31/82 (end of <br />test year). For any future rate case, we recommend the exclusion of the period from 3/31/82 <br />until construction commences. The total dollars eliminated from the proposed rate base are <br />$16,312,480. <br />2) Disallow accrual of the equity portion of AFUDC or additional money invested for any <br />construction until there is Council review in a subsequent rate case. <br />t~-o~ <br />