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<br />- 2 - <br /> <br />. <br /> <br />attendant cost increases that would result to current recipients of CRSP power, <br />and evaluates the effect that an allocation of CRSP power would have on UP&L's <br />rates. <br /> <br />An allocation of CRSP power to UP&L can only be accomplished by <br />reducing allocations to current recipients of CRSP power. CREDA members pre- <br />sently purchase about 65% of the marketable firm electric service from CRSP. <br />To evaluate the impacts on CREDA members, a range of scenarios was used: one <br />which assumed that UP&L and no other new electric utility system would receive <br />a 200 megawatt share of CRSP power, and two which assumed that if UP&L pre- <br />vailed, all other private power companies in the CRSP marketing area would be <br />able to purchase CRSP power. <br /> <br />Any of these three marketing scenarios would have a substantial im- <br />pact on CREDA members. The loss in available capacity would range from 110 to <br />over 650 megawatts; the loss in energy could be as much as 2,584 billion kilowatt- <br />hours per year. The rate impact would also be substantial. Replacing any losses <br />in CRSP service with new generation facilities or through contracts with other <br />utilities is estimated to cost CREDA members as much as $101,750,000 ~year. <br /> <br />In contrast to the enormous impact that a reduction in allocations <br />would have on current recipients of CRSP power, the cost savings to UP&L for a <br />corresponding allocation is estimated to result in average rate decreases of only <br />.06 to .24 cents per kWh. Even if these potential savings were to benefit only <br />residential and commercial customers, the projected rate decreases would be only <br />.23 to .95 cents per kWh. However, the rates for consumers served by CREDA <br />members would necessarily increase by up to 3.89 cents per kWh, or about 150%. <br />Thus, the absolute and relative increases in rates is estimated to be many times <br />greater for the retail utility systems within the CREDA membership than the <br />corresponding rate decreases that might be received by some of UP&L's consu- <br />mers. <br /> <br />The R. W. Beck report also contains an analysis relating to the his- <br />torical perspective of the reliance of CREDA members on CRSP power. This <br />analysis indicates that while CRSP electricity now seems inexpensive, the CRSP <br />electricity was originally a more expensive resource than alternative generation. <br />The extra cost paid by CREDA members for CRSP electricity was approximately <br />$7,000,000 from 1963 to 1968. By 1989, over half of the federal investment in <br />CRSP facilities will have been paid by its existing customers. Despite their <br />earlier investment in the CRSP facilities at a substantial premium, CREDA mem- <br />bers and other existing customers of CRSP will be forced to turn to more expen- <br />sive alternative sources of electricity if UP&L succeeds in obtaining an allocation <br />of CRSP power. <br /> <br />CREDA's Response To UP&L's Legal Claims <br /> <br />The members of CREDA believe that UP&L's constitutional claims <br />are completely without merit. Furthermore, they believe that UP&L cannot be <br />permitted to circumvent the preference laws. In the legal analysis prepared by <br />