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6 . . absent congressional approval. The customers and Western have made repayment studies which show that the method advocated by the customers would reduce the proposed rate adjustment by about 19,8 percent. 3. Energy losses Several customers questioned using energy losses of 7 percent of the energy delivered at load and suggested that it should be about 3 to 5 percent instead. Western's average percent loss of energy delivered to load from 1972 through 1978 (excluding the drouth year of 1977) is 7.39 percent; therefore, the 7 percent as used in the rate study seems reasonable. 4. Diversity vs. capacity losses Some customers suggested that diversity may exceed capacity losses and that this should be analyzed. Western looked at the 1972-78 period (excluding the drouth year of 1977) and found that, in some of the years, the diversity exceeded losses and in other years the diversity was less than losses. On the average for the 6-year period, the diversity exceeded the losses by 22 MW in the summer and 2 MW in the winter. With the exclusion of the summer of 1976, during which there was an extraordinarily high diversity, the diversity varied between 35 MW higher and 30 MW lower than losses, and on the average the diversity exceeded the losses by 8 MW in the summer and 2 MW in the winter. In view of the foregoing, it appears that the assumption of diversity equaling capacity losses is reasonable. 5. D~1~ioos Questions were raised by the customers concerning depletions for future projects. As stated in above, Western believes that the study must include all authorized projects. Hence, the depletions for authorized future projects are included. 6. Replacements The customers suggested that, since replacement factors used in the rate study were developed in 1969, replace- ment should be re-eva1uated. It is true that the factors for replacements were developed in 1969. However, these factors are developed based on the