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<br />. <br /> <br />. <br /> <br />Discussion: A number of commentators raised the issue of whether DOE Order <br />R.A. 6120.2 (formerly Department of the Interior 730 DM4) should be interpreted <br />to limit the period of analysis for all investments to a maximum of 5 years <br />into the future. This approach would have the effect of limiting the congres- <br />sionally authorized projects which could be included in the rate base to only <br />those in service by the end of the 5-year cost evaluation period. Certain <br />investment costs of authorized future storage project and participating <br />project features which have historically been included in the rate base would <br />be excluded, which would result in a lower rate increase than is now being <br />proposed. <br /> <br />This argument, however, is without merit as DOE Order R.A. 6120.2 by its <br />terms makes exceptions for both statutory requirements and for interpretations <br />by the Secretary. Both P.L. 84-485 and the interpretation of the Secretary <br />of the Interior, made contemporaneously with enactment of the statute, support <br />the conclusions that the sections of DOE Order R.A. 6120.2 relating to cost <br />evaluation periods do not apply to the CRSP. The purpose of DOE Order R.A. <br />6120.2 is to establish financial reporting policies, procedures, and method- <br />ology for all DOE power marketing administrations except where deviations are <br />specifically approved by the Secretary, authorized by statute, or identified <br />and explaifled in a transmittal memorandum or in the footnotes to reports. <br />The proposed rate is clearly within the DOE Order R.A. 6120.2 exceptions. <br />Special legislation by Congress may be required in order to implement this <br />alternative. <br /> <br />For further information or copies of the environmental assessment contact: <br /> <br />Gary W. Frey, A1600 <br />Environmental Manager <br />Western Area Power Administration <br />P.O. Box 3402 <br />Golden" CO 80401 <br />(303) 231-1527 <br /> <br />Albert M. Gabiola <br />Area Manager <br />Salt Lake City Area Office <br />P.O. Box 11606 <br />Salt Lake City, UT 84147 <br />(801) 524-5493 <br /> <br />Date Issued <br /> <br />Ruth C. Clusen <br />Assistant Secretary for <br />Environment <br />