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R78-25 07-24-78RESOLUTION NO. R78-25 A RESOLUTION OF THE CITY OF PEARLAND, TEXAS, SUSPENDING RATE CHANGES HERETOFORE FILED BY HOUSTON LIGHTING & POWER COMPANY; PURSUANT TO SECTION 43(d) OF THE PUBLIC UTILITY REGU- LATORY ACT, ARTICLE 1446C, TEXAS REVISED CIVIL STATUTES. WHEREAS, on July 14, 1978, the Houston Lighting & Power Company (HL&P) filed a Statement of Intent to change its rates for electric service within the City of Pearland, Texas and has requested that said changes become effective on August 21, 1978; and WHEREAS, HL&P has filed revised Tariff Schedules togethe with statements specifying in detail each proposed change, a rate filing package, and supporting testimony; and WHEREAS, Section 17(a) of the Public Utility Regulatory Act, Article 1446C, Texas Revised Civil Statutes, gives the governing body of each municipality exclusive original jurisdic- tion over electric rates within its municipal boundaries; and WHEREAS, Section 43(d) of the Public Utility Regulatory Act authorized the governing body of any municipality acting as a Regulatory Authority to suspend the operation of any proposed chang in rates for a period not to exceed 120 days beyond the date on which the scheduled rates would otherwise go into effect, which period may be further extended for an additional 30 days; and WHEREAS, HL&P's proposed rate changes and the detailed material supporting those changes require comprehensive evaluation and study; THEREFORE BE IT RESOLVED by the City Council of the City of Pearland, Texas: That the changes in rates for electric service within the City of Pearland, Texas proposed by Houston Lighting & Power Company to become effective on August 21, 1978 should be, and are, hereby suspended for a period of 120 days beyond said proposed effective date, until December 19, 1978, subject to an additional suspension of up to 30 days beyond said date upon furth er resolution of this Council. INTRODUCED, READ AND PASSED by the affirmative vote of the City Council of the City of Pearland, Texas, on this the Q/ day of July, 1978. ATTE City Clerk APPROVED: et:y CITY OF PEARLAND! TEXAS By. dY/Z MAYOR •• + (41116) • r-- DOCKET NO. 2001 RE: THE APPLICATION OF HOUSTON X PUBLIC UTILITY COMMISSION LIGHTING & POWER COMPANY FOR I AUTHORITY TO CHANGE RATES X OF TEXAS FINAL ORDER Procedural Statement On July 14, 1978, Houston Lighting & Power Company (HL&P) filed an application for authority to change rates in its unincorporated areas. The effect of this application and similar applications filed with municipalities exercising original jurisdiction over - HL&P would be an increase in systemwide base rates of .,$235,158,606,.calculated by adding the $174,528,039 stated by HL&P in its original application and $60,630,567 which represents its proposed bringing forward into. base rates of costs that would otherwise be recovered through its cost of service adjustment clause (TR 147-48). A prehearing conference was held on July 31, 1978, at which various preliminary matters relating to final hearing herein were resolved. At said conference and subsequent thereto, intervenor status was granted to the following entities: 1. The combined cities of Baytown, Houston, Lake Jackson, and the Texas Municipal League on behalf of those member cities served by HL&t, representing ratepayers in their respective cities; • 2. Chambers County, Texas; . 3. The Association of Community Organizations for Reform Now (ACORN); 4. Armco, Inc.; 5. Dow Chemical Company; 6. St. Regis Paper Company; 7. Stauffer Chemical Company; 8. United States Steel Corporation; - • 9. Coastal Industries Group composed of Monsanto Company; Air Products & Chemicals, Inc.; E. I. DuPont deNemours & Company; Anheuser- Busch, Inc.; Celanese Chemical Company; Crown Central Petroleum Corporation; ' Diamond Shamrock Corporation; Olin Corporation; Pennwalt Corporation; Reynolds Metals Company; Rohm & Haas Texas, Inc.; Shell Oil Company; Soltex Polymer Corporation; Union Carbide Corporation; and U. S. Industrial Chemicals Company; 10. Community Public Service Company. At the prehearing conference, the proposed effective date of the rate change was suspended for 120 days pursuant to art. 1446c, Section 43(d), V.A.C.S. The hearing on the merits was convened on September 18, 1978, and recessed until • October 3, 1978. The hearing was adjourned on October 16, 1978. After public hearing, the Commission, based upon the evidence, the law and matters officially noticed, makes the following conclusion, supported by the r, . . • reflect the cost of service and to produce the revenues required to eliminate such deficiency. The underlying Findings of Fact and Conclusions of Law supporting this conclusion are as follows: . • Findings of Fact • 1. Jurisdiction. HL&P is an investor-owned electric utility operating under a Certificate of Convenience and Necessity issued by the Commission. The Commission has jurisdiction to consider the matters presented in this docket. 2. Original Cost. The original cost of electric plant of HL&P, as of March 31, 1978, including plant construction completed but not classified, is $2,553,461,151 as claimed by the company and as shown on Staff Exhibit 16 (Exhibit B-2, p. 1), which amount the Commission finds to be reasonable. The corresponding- provision for accumulated depreciation, proposed by the company, $464,717,626, is increased by $10,478,371 to $475,195,997 to properly reflect the recovery of dollars attributable to increased depreciation by HL&P from its customers on a monthly basis. Staff Exhibit 17, pages 10-12 (as amended). 3. Invested Capital. The invested capital of HL&P is $2,175,513,603, which is calculated in the following manner: Net Electric Plant in Service (FOF#2) $2,078,265,154 Construction Work in Progress and Nuclear •Fuel in Process (FOFff4 & 5) 179,155,839 Plant Held for Future Use (FOF116) 4,228,089 Working Capital (FOFff7) 93,920,373 Deferred Federal Income Taxes (FOFtt8) (135,941,462) - Reserves for-Property Insurance i and Injuries (FOF#8) (8,481,655) Customer Deposits and Advances (FOFn8) (25,379,298) Unamortized Pre-Job Development Investment Tax Credits (FOF#8) (10,253,437) $2,175,513,603 4. Construction Work in Progress. The amount of $156,287,426 allowed for construction work in progress (CWIP) consists of forty (40%) percent of the cost of the projects set forth in Schedule C of the HL&P Rate Filing Package. The Commission finds that this amount should be allowed in invested capital in order that HL&P's financial integrity will be maintained due to the capital intensive nature of the electric industry and in order that it remain capable of attracting the large amounts of additional capital necessary to continue its program of construct-ion of new generation facilities capable of both meeting the future energy demands of its customers and utilizing more abundant fuels than natural gas or oil. Staff Exhibit 16, page 5. 5. • Nuclear Fuel in Process. Nuclear fuel in process represents forty (40%) percent of the amount claimed by FIL&P, excluding $8,919,321, which represents funds advanced by HL&P to Conoco in connection with a joint exploration project. Noting that Federal Power Commission Order No. 561 (February 2, 1977) allows electric utilities to accrue an allowance for funds used during construction (AFUDC) on nuclear fuel in process, this. Commission finds that the inclusion of nuclear fuel in process is subject to the same standards for inclusion in rate base as construction work in progress under the Public Utility Regulatory Act, Section 41(a). With respect thereto, it is determined that the inclusion of C99 PPR All .,f .,., l O.. , :- -- i t • (4116) 6. Plant Held for Future Use. In Southwestern Bell Telephone Company v. Public Utility Commission of Texas, S.W. 2nd (Tex. 1978), the Supreme Court mandated that this Commission specifically set forth criteria in evaluating plant held for future use as a potential component in rate base. The inclusion of such plant in rate base will therefore be limited to that plant which is not considered by HL&P to be "excess property to be sold," and which is currently scheduled to be - placed in service within ten (10) years from date hereof, which period of time the Commission finds to be reasonable in this case. Staff Exhibit 10. 7. Working Capital. Working capital in the amount of $93,920, 73 is - included in invested capital which represents an amount sufficient to • allow HL&P to meet its normal business needs. Said allowance includes $18,220,105 for materials and supplies, $51,492,308 for fuel stock, _$4,045,698 for prepayments, and $20,162,262 as cash working capital. The above levels of materials and supplies and prepayments constitute a thirteen month average of said items, while fuel stock is based upon year end levels, since fuel oil increased throughout the test period. Cash working capital is computed as one-eighth of adjusted operation and maintenance expenses excluding prepayments, fuel expense and materials and supplies as expensed during the test year. Rate Filing Package, Schedule G1 and Staff Exhibit 16 (Exhibit B-2, page 2 of 2). • 8. Deferred Federal Income Taxes, Reserves for Property Insurance and Injuries, Customer Deposits and Advances, and Unamortized Pre-Job Development Investment Tax Credits. Deferred federal income taxes in the amount of $135,941,462, reserves for property insurance and injuries in the amount of $8,481,655, customer deposits and advances in the amount of $25,379,298, and unamortized pre-job development investment tax credits in the amount of $10,253,437 are excluded from invested capital, since each such item represents funds either supplied by ratepayers or for which there are no related capital costs. Staff Exhibit No. 17B (Exhibit-B-2, page-1). 9. Affiliated Companies. Houston Lighting & Power Company, Utility Fuels, Inc. (UFI), and Primary Fuels,. Inc. (PFI) are wholly owned subsidiaries of Houston Industries, Inc. (HII) with HL&P accounting for - approximately 98% of HII consolidated assets and 99% of HII common . stock equity. Houston Industries, Inc. files a consolidated return for tax purposes. . - 10. Affiliate Transactions. There have been no transactions between HL&P and PFI. UFI was incorporated to acquire and deliver fuels to HL&P generation facilities. To date the only transactions between HL&P and UFI are: (1).UFI has contracted to sell and deliver coal to the W. A. Parish generation facilities, and (2) HL&P has provided UFI with uranium to be resold to a third party, which uranium will be returned in kind to l-IL&P and for which UFI is paying interest to HL&P based upon the value of the uranium sold. The Commission finds that the agreement for sale and delivery of coal to the W. A. Parish units is reasonable, and further that the uranium transfer by HL&P to UFI is equitable provided that said interest rate is not less than the prime rate charged by banks in Houston, Texas. 11. Net Current Cost. The net current cost of plant of HL&P is $3,070,100,000, as computed by the Staff and reflected in Staff Exhibit No. 12 (Lee Exhibit 31). The Handy-Whitman Index is used as the most appropriate method of trending utility plant to determine current cost. W. A. Parish Generating Unit No. 6 is included in the determination of (4-)• Commission finds to be $1,228,000,000, as-shown on Staff Exhibit No. 12 • (Lee Exhibit 3). The adjustment for age and condition and depreciation expense, including accumulated depreciation on original cost as proposed by the Staff, is consistent with each other inasmuch as each is calculated on a straight line basis and estimate a useful service life from the date the plant is placed in service. Accordingly, deduction of . the adjustment for age and condition from the current cost of plant in service results in a net current cost amount of $3,070,100,000. 12. Adjusted Value of Invested Capital. The adjusted value of invested capital used and useful in rendering service to the public is $2,500,339,515 which is composed of the following elements: Net Plant - Original Cost $2,078,265,154 (see FOF 1,712) Percentage Mix - 67.25% $1,397,633,316 Net Plant - Current Cost 3,070,100,000 (see FOF #11) 32.75% 1,005,457,750 • Construction Work in Progress and Nuclear Fuel in Process (FOF#4 & 5) 179,155,839 Plant Held for Future Use (FOF#6) . 4,228,089 Working Capital (FOF#7) 93,920,373 Deferred Federal Income Taxes (FOF#8) (135,941,462) Reserve for Property Insurance and - Injuries (FOF#8) (8,481,655) Customer Deposits and Advances (FOF#8) (25,379,298) Unamortized Pre-Job Development Investment Tax Credits (FOF#8) (10,253,437) Adjusted Value of Invested Capital $2,500,339,515 The percentage mixes applied to original and current cost of plant are as computed by the Staff in Staff Exhibit No. 13 (Exhibit WEA-12). These percentages adequately reflect inflation, quality of service, service area growth rate and the need to attract new capital-, as required by art. 1446c, Sec. 49(a), V.A.C.S. 13. Capitalization. The capitalization of HL&P at the end of the test year, adjusted to reflect all known and measurable changes, as shown on Staff Exhibit 13 (Exhibit WEA-11), is derived as follows: a. Long term debt of $1,233,000,000, representing 48.30 percent of total capital, with an embedded cost of 7.34 percent; b. Preferred stock of $213,945,340, representing 8.35 percent of total capital, with an embedded cost of 8.10 percent; c. Common stock equity of $988,700,4 7 4, representing 38.58 percent of total capital, upon which a reasonable rate of return is 13.80 percent. d. Job development investment tax credits of $122,344,443, representing 4.77 percent of total capital, upon which a reasonable rate of return of 10.02 percent is allowed. f4 • 7 (---) , . . . s . . • Component Percent Component Weighted • Source Amount of Total Cost . Average Cost Long Term Debt $1,238,000,000 48.30% 7.34% 3.54% Preferred Stock 213,945,340 8.35% 8.10% .68% ' • Common Stock 988,700,474 38.58% 13.80% 5.32% Job Development ' • Investment Tax Credit 122.344,443 4.77% 10.02% .48% Totals $2,562,990,257 100.0096 • 10.02% 15. Debt. The annual interest requirement on long term debt capital is $90,869,200 representing a cost of 7.34% on 48.3096 of HL&P's capitalization structure resulting in a weighted average cost of 3.54%. 16.- -Preferred Stock: - The annual dividend requirement on preferred stock is $17,329,573 representing a cost of 8.10% on 8.35% of HL&P's capitalization structure resulting in a weighted average cost of .6896. 17. Return on Equity Capital. The annual return allowed on equity capital of 13.896 on 38.58% of HL&P's capitalization structure is fair and reasonable and is sufficient to assure confidence in the financial • integrity of HL&P so as to maintain its credit and to attract additional capital and is comparable to those returns of similar companies having • • comparable risk and results in a weighted average cost of 5.32%. 18. Investment Tax Credit. HL&P is allowed to earn the composite cost of capital of 10.02% on the unamortized job development investment tax credit in the amount of $122,344,443. No reduction in rate base has been made by this amount or for any portion of said unamortized investment tax credit. 19. Bond Rating. The return on common equity permitted herein will result in a pre-tax times interest coverage of 3.78 which would support the bond rating of HL&P, thus indicating that the company will continue its ability to attract capital at the lowest ultimate cost to •the ratepayer. The amount of allowance for funds used during construction as a percentage of earnings for common equity is 13.73%, which is reasonable under the circumstances of this case. 20. Return on Adjusted Value of Invested Capital. A reasonable return on the adjusted value of invested capital is 8.718%. Such a rate will not yield more than a fair return on the adjusted value of invested capital, as required by art. 1446c, Sec. 45(a), V.A.C.S. 21. Cost of Service. The adjusted cost of service and revenue requirement of HL&P for the test period is $1,435,345,489 and is composed of the following elements: Fuel $ 751,191,669 Depreciation 87,229,379 Operation and Maintenance Expenses • 184,959,877 Taxes other than Federal Income Taxes 67,619,017 Federal Income Taxes 125,763,255 • • Amortization of Cancellation Charges 278,424 Interest on Customer Deposits 317,405 Return 217,986I 463 Total Cost of_Service $1,435,345,489 • �1 risk) $751,191,669 to properly recognize an increase of $2,381,794 in total kwh sales as of the end of the test period, and a decrease of $6,972,211 in kwh sales due to the weather normalization adjustment by the Commission herein. Rate Filing Package, Schedule N-3.1, page 2. 23. 'Depreciation. HL&P's current composite depreciation rate is 3.20 • percent and is composed of the following elements: Gas/Oil 2.61% Coal 2.63% Other - 5.0% • Production Composite 2.96% • • Transmission 2.77% Distribution 3.28% General 5.56% System Composite 3.20% The company has proposed that the gas/oil production depreciation rate be increased from 2.61 percent to 4.10 percent in order to reflect the anticipated early retirement of various gas/oil generation units in 1996, which is the termination date of HL&P's Exxon gas contract. The Commission finds that there is insufficient evidence at this time to conclude that oil, as a boiler fuel, will be unavailable after 1996 either because of scarcity or prohibition by law. The Commission further finds • that service lives of thirty (30) years proposed by Staff witness Lee for accounts 355 (poles and fixtures), 365 (overhead conductors and devices),-and 368 (line transformers) are reasonable and proper. Staff Exhibit 12, page 7. The above adjustments, hereby adopted by the Commission, produce the following functional depreciation rates: Gas/Oil 3.266% Coal . ' 2.857% Other 5.00096 Production Composite 3.460% • Transmission 2.892% ' Distribution 3.737% General 5.453% System Composite 3.605% 24. Operation and Maintenance Expenses. A reduction in the amount of $8,311,255 to HL&P's proposed operation and maintenance expenses of $193,271,132 is reasonable, as set out below, and results in an allowable total of $184,959,877. The specific adjustments are as follows: • a. A reduction in the company's proposed level of wages in the amount of $513,044 to reflect: (1) HL&P's initial overstatement of that portion of wages attributable to the monthly payment of supplemental retirement checks (Staff Exhibit 16, page 7); and (2) an overage in the utility's projected level of overtime expense. • The Commission finds that the use of a five year average of overtime as a percentage of base wages is reasonable, however, the exclusion of any year from said average because of abnormal results must be based upon known events or occurrences in said year which skewed those results. b. A reduction of $497,889 of employee benefit expense, since increases in the administrative portion of such expense is more • properly a function,of increases in the number of employees than • c. A reduction of $92,033 in legal fees from cost of service, since • such fees were expended for legislative advocacy. Staff Exhibits 9 and 9A. d. A reduction of $283,663 for nonrecurring legal expenses associated with litigation between HL&P and Westinghouse Electric Corporation involving the delivery of uranium for use at the South Texas Nuclear Project. The Commission finds that given the nature of this litigation and the magnitude of said fees, the most appropriate means of recovery is the amortization of such fees over a five-year period. e. A reduction in rate case expense of $32,338 which constitutes the amount expended by HL&P for an observed depreciation study. The Commission finds that the cost of the observed depreciation study in this docket is excessive in comparison with other _ . ,.... _ .reasonably accurate methodologies for determining an adjustment - for age and condition of plant. Staff Exhibit 16, pages 8 and 9. f. A reduction of $951,226 in "other" operation and maintenance expenses, since there is insufficient evidence in the record to conclude that HL&P's proposed increase in the test year level of expenses is reasonable (TR 1284-85.). g. A- reduction of $400,000 in the amount of HL&P's proposed • property insurance reserve accrual. Noting that HL&P has not charged_any losses against said reserve for seventeen (17) years and that the current level of said reserve will effectively provide more than $15,000,000 of loss protection, the Commission finds that annual increases of $100,000 to the current level of the reserve are reasonable and proper. h. A reduction in uncollectibles of $93,155, in city franchise fees of $2,938,323, and in the Public Utility Commission- assessment of . $2,509,584 to reflect a reclassification of the Public Utility Commission assessment from Operation and Maintenance expenses to other taxes, and the reduced cost of service for HL&P as set forth in this Order. ' 25. Taxes other than Federal Income Taxes. The Commission finds that an adjustment to HL&P's proposed-expense for taxes other than federal income taxes of $66,316,662 in -the amount of $1,302,355 should be made, resulting in an allowable expense of $67,619,017. The adjustment made reflects a reclassification of the Public Utility Commission Assessment to taxes other than federal income taxes. Additional differences from the company's proposal result from the lower revenue requirement determined herein. • 26. Federal Income Taxes. An adjustment of $49,835,364 to the company's claimed federal income tax expense of $175,598,619 is found to be proper, resulting in an allowable expense of $125,763,255. The- adjustment generally reflects the tax effects of changes in the cost of service of HL&P as set forth herein. 27. Amortization of Cancellation Charges. The Commission finds that HL&P's proposed amortization of cancellation charges associated with the discontinuance of the Allen's Creek No. 2 Nuclear Unit is unreasonable, in that no return should be earned on the unamortized portion of such charges. The Commission therefore finds that HL&P is permitted to recover said $1,392,120 in charges over five years at the rate of $278,424 per annum. tam, weather experienced within the utility's service area during the test year ended March 31, 1978. Said amount is equal to one-half of the adjustment proposed by HL&P and is determined to be reasonable in this proceeding, since the normalization procedure used by the company herein is not as fully developed as alternative methodologies adopted in other Commission proceedings. • 30. Revenue Deficiency. The Commission finds the test year cost of . service or revenue requirement of $1,435,345,489 will permit HL&P to • .recover its operating expenses together with a reasonable return on its invested capital, as required by art. 1446c, Sec. 39, V.A.C.S. HL&P's _recovery of revenues from the fuel adjustment clause and sources other than base rates is $7 60,126,816. The base rate revenue requirement of HL&P is $675,218,6 7 3. Adjusted test period base rate revenues for HL&P are $545,743,252. This amount also reflects an adjustment for kilowatt hour sales due to the weather normalization adjustment _discussed above.-- The revenue deficiency of HL&P for the test period is $129,475,421. 31. Cost of Service Allocation. To allocate production facilities for this proceeding, HL&P has proposed utilization of the Loss of Load Probability Method (LOLP), which is a variation of the peak responsibility allocation methodology. Noting that the allocation factors derived from said method are similar to the results obtained from other traditionally accepted methodologies, the Commission finds the LOLP method to be reasonable for use in this proceeding. . Staff Exhibit 15 (Exhibit GLG-2). The Commission likewise finds that the methodologies proposed by HL&P for allocating transmission, distribution, and general plant are fair and reasonable. • 32. Revenue Requirement by Customer Class. The Commission finds that the company shall file revised rates to reasonably reflect the following relative rates of return by customer class. - - Customer Class Target Relative Return Residential .70 Miscellaneous General Service 1.27 Large General Service 1.02 LOSA 1.47 'LOSB 1.23 Public Utility 1.00 • Contract Service 794 1.89 • • Street Lighting .16 33. Fuel Adjustment Clause. The Commission further finds that the volatility in the price of fuel requires that a cost of fuel adjustment be allowed HL&P in order to protect the financial integrity of the company. The fuel adjustment clause in the tariff shall provide for a fuel adjustment for the actual fuel consumed in generating each kilowatt hour of electricity sold and for the fuel component of each • kilowatt hour of purchased power bought and resold. The Commission additionally finds that said fuel adjustment clause shall recognize the line loss differentials between customer groups as recommended by the Staff, the company, and various intervenors herein. The use of such a clause is conditioned on the elimination of all handling, storage, and transportation costs directly incurred by HL&P. Further the clause shall include neither revenue related taxes nor gains or losses on the sale of fuel and must otherwise comply with the Commission's - Substantive Rules. The above notwithstanding, HL&P is hereby allowed • to recover through its fuel adjustment clause the full cost of economy • • . „. , „A,-) 34. Cost of Service Adjustment Clause. The proposed continuance by HL&P of a cost of service adjustment clause as previously authorized by the City of Houston and various other cities served by HL&P is found to be unreasonable by the Commission. _ Denial of said proposal is consistent with sound regulatory practice in various respects including: (1) Implementation of such an adjustment clause is contradictory to the Commission's intention to move toward a more cost-based rate design; _ (2) Full recovery of the expenses set forth in the clause would require- fourteen months from date of incurrence, while regulatory lag before the Commission has generally been less than five months; and (3) The record in this proceeding clearly reflects that investors do not expect the continuance of the cost of service adjustment clause. 35. Rate Structure. In general, the rate structures proposed by HL&P are based.on sound rate-making principles and are compatible with the rate . design philosophy adopted by the Commission in earlier cases, and such - • rate- structures are sufficient, equitable, consistent in application to each class of customers, are not unreasonably preferential, prejudicial or discriminatory, and will produce the proportionate part of the required revenues to eliminate HL&P's revenue deficit. As a result, the final rates filed in compliance with this Order shall be structured as proposed with the following exceptions: a. Customer charges as hereinafter set forth are found to be fair and equitable to those classes affected thereby: • (1) A $4.50 customer charge for both rural and urban residential - ratepayers which is to include 30 kwh of energy.• (2) A $9.30 customer charge for all miscellaneous general service customers which will provide no energy usage. (3) A $25.00 customer charge for all existing direct current .. service customers which likewise will provide no energy usage. b. The Commission further finds that the definition of peak months as proposed by HL&P'is improper, and that the peak months for ' billing purposes shall include June through October in order to reflect customer consumption from May through September. c. In accordance with the National Energy Act recently passed by Congress, the Commission finds that all off-peak usage by residential consumers be priced lower than the rate for peak usage, and that HL&P, as proposed, provide recognition of the difference in costs between high and low volume, off-peak, residential customers by implementing a two block off-peak residential rate. • d. With regard to the measurement of on-peak kva and off-peak kva for industrial customers, HL&P shall continue to measure such energy demand upon fifteen (15) minute periods of maximum use. e. The Commission finds that the rates charged by HL&P to Dow Chemical Company for interruptible service shall be equal to • eighty (80(,'6) percent of' the firm rates charged by the company under its amended tariff as filed herein. 36. Additional Rate Design Analyses. Given the relatively low reserve margin that llL&P has currently and expects to have through 1985 and further noting the large industrial load served by the utility, the • 1 � (0-• • • • b. The design of marginal cost based rates for such customers, and c. A cost/benefit analysis of interruptible rates. Conclusions of Law • • 1. The Commission has jurisdiction over the subject matter in this case • pursuant to art. 1446c, Secs. 16, 37, 43, V.A.C.S. •° 2. The intervenor cities have a justiciable interest as regulators, and all other intervenors have a justiciable interest in this proceeding, in that each represents a different class of customer and is concerned as to issues .of unreasonable discrimination, if any, of rates as between classes of customers. 3. HL&P has the burden of proof to establish its revenue deficiency under its present rates and the amount of such revenue deficiency which will be collected. under its proposed rates, pursuant to art. 1446c, Sec. 40(b), V.A.C.S. 4. HL&P has proven that it has a revenue deficiency of $129,475,421 in the test year. 5. The present rates for service in the 'unincorporated areas and in any cities served by HL&P over which this Commission has original jurisdiction are insufficient to provide HL&P with the revenues • approved in this Order and should be adjusted to conform to the rates established herein for each class of ratepayers. 6. The rates prescribed in this Order will allow HL&P to recover its operating expenses with a reasonable return on its invested capital pursuant to the requirements of art. 1446c, Sec. 39, V.A.C.S. 7. The rate of return granted herein is sufficient to assure confidence in the financial soundness of HL&P and is adequate, under efficient-and economical management, to maintain and support its credit and enable - it to raise the money necessary for the proper discharge of its public • duties; is comparable to those returns of other similar companies having comparable risk; and is sufficient to assure confidence in the financial integrity of HL&P so as to maintain its credit and to attract capital. (Federal Power Commission v. Hope Natural Gas Company, 320 U. S. 591, 88 L. Ed. 333; and Bluefield Water Works and Improvement Co. v. Public Commission of West Virginia, 262 U. S. 679, 67 L. Ed. 1176.) . 8. The Commission has the authority and duty to set proper rates in all instances whether such action requires increasing, decreasing, or changing the rate pattern with respect to any or all rates contained in the proposed tariff, regardless of whether the rates in the proposed tariff are different from old rates or not, and no prior' notice by the Commission to the applicant is required for such action. 9. The rate design as set out in the Findings of Fact is reasonable and non- discriminatory and shall be adopted in this Order. Order • NOW' THEREFORE, :it is hereby ORDERED that IHL&P shall file a revised tariff in accordance with the conclusion, findings of facts, and conclusions of law • • 'a. T C . raw) . • • • the revised tariff to review it for approval or rejection. The tariff shall be deemed • to be approved and shall become effective upon the expiration of twenty (20) days after filing or sooner upon notification by the Commission Secretary. In the event - of rejection, HL&P shall be notified and a copy sent to all groups of the intervening parties herein by the Commission Secretary, and IIL&P shall have fifteen (15) - additional days to file an amended tariff and the same procedure shall be repeated herein. The revised and approved rates shall be charged. by HL&P for electricity - consumed. after the tariff approval- date and may not be charged for electricity • consumed prior to such date. This Order is deemed to be final on the date of its effectiveness either by operation of this Order or by notification by the - -. . -Commission Secretary, whichever occurs first. All motions, requests, applications and requests for Findings of -Fact and Conclusions of Law not expressly granted herein are denied for want of merit. . RENDEERED.:AND.SIGNED--AT AUSTIN;,.TEXAS,- on this the- -. • day-of , 1978. . • PUBLIC UTILITY COMMISSION OF TEXAS • • • SIGNED: • - - - - GEORGE M. COWDEN SIGNED: GARRETT MORRIS SIGNED: ALAN R. ER WIN ATTEST: • • PHILIP F. RICKETTS COMMISSION SECRETARY AND DIRECTOR OF HEARINGS