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<br />i <br />the systemwide4ltrate proceeding would fO. on a rate year, <br />I <br />which is defined as "the period in which the factor will be in <br />effect." Given the breadth of South Texas Project issues to be <br />addressed in the next HL&P general rate case, o.ne may <br />reasonably assume that the relevant period of focus for fuel <br />reconciliation purposes would be calendar year 1990. As recent <br />history has shown, it has been extremely difficult to <br />accurately project natural gas prices, even in the near term <br />due to their VOlatility. Therefore, to base findings of fact <br />in any fuel reconciliation proceeding on estimates of natural <br />gas prices that will take effect from thirteen to twenty-five <br />months from now would be highly speculative at best. All <br />parties can offer much better gas price estimates if the period <br />of review is limited to 1989 rather than 1990. <br />Furthermore, HL&P in this ~roceeding is not requesting any <br />change in 'the Company's present fixed fuel factors. Only a <br />reconciliation of the fuel cost underrecovery balance through <br />September 30, 1988 is sought. Thus, ratepayers will see no <br />change of rates as a result of this proceeding if the Company's <br />recommendation herein is adopted. If over the . next twelve <br />months, circumstances indicate that the present fuel factor <br />should be changed, either higher or lower, then certainly all <br />parties would be free to make such a request in either the <br />systemwide rate case or a separate proceeding. [Substantive <br />Rul e 23. 23 (b) (2) (H) . ] <br />GWS005SG - 5 - <br />