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<br />. <br /> <br />. <br /> <br />Item <br /> <br />Decrease in Proposed <br />Rate Adjustment <br /> <br />Eliminate escalation of future <br />wheeling expense. <br /> <br />Apply CUP & Seedskadee Power Revenues to <br />Utah and Wyoming as in Repayment Studies <br />Prior to 1973 <br /> <br />3.5% <br /> <br />7.3% <br /> <br />Defer unidentified future transmission <br />investments from 1981-84 period until <br />1990-2020 period <br /> <br />3.4% <br />14.2% <br /> <br />TOTAL DECREASE <br /> <br />The result of the above at 58.2 percent load factor is to <br />increase the existing rate by 23.8 percent instead of 38 <br />percent, as stated in the April 1979 brochure. <br /> <br />The customers, as a further challenge, have raised general <br />issues of fairness. Western is of the opinion that the <br />repayment procedure mandated by Congress was considered fair <br />by Congress. Western cannot deviate Congress' concept of <br />fairness in handling power revenues absent congressional <br />approval. <br /> <br />v. Discussion of Other Public Comments <br /> <br />Other public comments were received which were critical of a <br />number of assumptions which were made by the Western Area Power <br />Administration with regard to its repayment study. The areas of <br />comment will be discussed below. <br /> <br />A. Comments Related to Study Methodology <br /> <br />1. Inclusion of future projects in repayment study <br /> <br />The primary thrust of a number of the public comments <br />relating to the repayment study revolved around whether <br />or not all participating projects which have been <br />authorized by Congress should be included in the repay- <br />ment study. This concern has apparently emerged due to <br />the amount of time which has elapsed between authoriza- <br />tion and construction. It does not appear that Western <br />has discretion to exclude any authorized projects, <br />regardless of the scheduled in-service dates. It is <br /> <br />4 <br /> <br />