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<br />, <br />( <br /> <br />.- <br /> <br />eo <br />(~ <br />~ <br /> <br />DAVID MAsTBAUM <br />Attorney at Law <br /> <br />- <br /> <br />14 May 1982 <br /> <br />( <br /> <br />Robert Cackowski, Acting Director <br />Office of Electric Power Regulation <br />Federal Energy Regulatory Commission <br />Washington, DC 20426 <br /> <br />Re: Project No. 2757, Juniper-cross Mountain <br /> <br />Dear Mr. Cackowski: <br /> <br />~ <br />I <br /> <br />In response to your letter of March 29, 1982, Intervenors <br />National Wildlife Federation, et al., submit the enclosed analysis <br />of the need for the Colorado-Ute Electric Association to partici- <br />pate in the proposed Juniper-Cross Mountain Project. On May 4, <br />1982, FERC staff counsel Don Garber stated that this analysis <br />could be mailed on or before May 14, 1982, and would be accepted <br />for filing. <br /> <br />The report entitled "The Juniper-Cross Mountain Project: A <br />Preliminary Technical Review of Needs and Alternatives" was prepared <br />by David Marcus. Mr. Marcus, a private energy consultant, received <br />a Master's degree in Energy and Resources from the University of <br />California at Berkeley in 1977. Until 1981, he worked as a senior <br />staff member for the California Energy Commission. <br /> <br />The central conclusion of the report is that licensing of <br />Juniper-Cross Mountain would not be in the public interest because <br />environmentally and economically preferable alternatives are avail- <br />able in the same time frame. Data that were not available to <br />Mr. Marcus at the time he prepared the report provide additional <br />and persuasive support for this conclusion. For example, while <br />Mr. Marcus only delays Colorado-ute's load growth associated with <br />oil shale development for a few years, recent events suggest that <br />oil shale development will be delayed for substantially longer and <br />should not be included in Colorado-Ute's load forecast. Indeed, <br />this is precisely what Colorado-Ute has done in its most recent <br />forecast. Colorado-Ute Electric Association, Inc., Revised Power <br />and Energy Requirements Forecast (Feb. 1982). <br /> <br />Moreover, Colorado-Ute's new peak power forecast is now very <br />close to that of Mr. Marcus. Attached is a table which compares <br /> <br />1720 R^CE STREET <br /> <br />. <br /> <br />DENVER, COLORM)Q80206 <br /> <br />. <br /> <br />(lOl)J88-S71l <br />