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<br />The implication of the FERC statement, of course, is that the power repayment <br />study is too imprecise to be used as a basis for rate setting; and by averaging the <br /> <br />year-to-year variations in income and expense over a lengthy period, mistakes could <br /> <br /> <br />result which might cause a significant increase for future ratepayers. As FERC puts <br /> <br />it, erroneous forecasts which might cause missed principal or interest payments could: <br /> <br />. . . create . . . a possible crises when the amount (Ed. Of <br />remaining repayment) that is to be spread over a small <br />number of years becomes too large to impose on ratepayers <br />(Federal Register, Vol. 48, No. 207, October 25, 1983, p. <br />49303). <br /> <br />In its notice of proposed rulemaking, which seeks to establish procedures and <br /> <br />filing requirements for rates proposed by power marketing agencies, FERC sought <br /> <br />comments on how power repayment studies could be improved or whether there were <br /> <br />preferred alternatives to the PRS. Comments were to be filed with FERC by <br /> <br />December 20, 1983 (FERC Docket No. RM80-40-000). <br /> <br />The proponents of the use of the ultimate development concept in power <br /> <br />repayment studies by PMA's have a number of supporting arguments from the fiscal <br /> <br />perspective. One such argument states that, at least in the case of the Pick-Sloan <br /> <br />Missouri Basin Program and the Colorado River Storage Project, large multi-purpose <br /> <br />water projects were conceived and authorized by Congress as comprehensive <br /> <br /> <br />"packages," even though they may have been subsequently amended. The argument <br /> <br /> <br />continues that to consciously modify the power repayment studies by deleting <br /> <br /> <br />individual features of the project as FERC and others have proposed would be <br /> <br />contrary to congressional intent and would make it impossible to show repayment of <br />project costs as originally conceived (Weinberg, 1983). <br /> <br />Also in a fiscal context, supporters of the ultimate development concept point <br /> <br />-10- <br />