Electric Industry Structure (2024)

4. A. Georgia’s Electric Industry

Three types of electric utilities provide retail electric service inGeorgia. These include investor-owned utilities, customer-owned utilities (cooperatives)and government-owned utilities (municipals). There are two investor-owned utilities,Georgia Power Company (GPC) and Savannah Electric and Power Company (Savannah Electric).Both of these are operating subsidiaries of Southern Company. Southern Company Services,another Southern Company subsidiary, operates the Power Control Center in Birmingham,Alabama, which coordinates the integrated operations of the Southern electric system,including generation and transmission facilities in Georgia. There are 42 ElectricMembership Cooperatives, 39 of which distribute power received from Oglethorpe PowerCorporation (OPC) while the remaining three distribute power received from the TennesseeValley Authority (TVA). There are 47 cities and one county (Crisp County) that are membersof the Municipal Electric Authority of Georgia (MEAG). There are other municipals, notmembers of MEAG, that also provide service to customers at the retail level. These includethe City of Dalton, the City of Hampton, the City of Acworth and the City of Chickamauga.5 Georgia has an IntegratedTransmission System, jointly-owned by Georgia Power Company, Oglethorpe Power Corporation,MEAG, and the City of Dalton. Each of these organizations is discussed below.

Georgia Power Company

Georgia Power Company (GPC), the largest electric utility in Georgia,is an operating subsidiary of Southern Company. GPC has a total of 14,367 megawatts ofgenerating capacity. Its generation mix is comprised of approximately 74.3% coal, 22.4%nuclear, 2.7% hydro and 0.6% combustion turbines. GPC wholly owns numerous generatingfacilities and co-owns other generating facilities with OPC, MEAG, the City of Dalton, andSavannah Electric.6 GPChas wholesale contracts for capacity and energy with cogenerators and other providers bothwithin and outside the State of Georgia.7

As of December 1996 Georgia Power Company served 1.7 million customersand provided electric service in all but six of the state’s 159 counties. The overallaverage price paid by all customer classes in 1996 was 6.15 cents per kilowatt-hour.8 GPC’s December 31,1996 FERC Form No. 1 indicated operating revenue of $4,415,615,956 and total assets of$13,508,046,332.

Savannah Electric and Power Company

Savannah Electric, part of the Southern Company since 1988, is aninvestor-owned utility regulated by the Commission. Savannah Electric serves customers in fivecounties located in Southeast Georgia. These include Chatham, Effingham, Bryan, Bulloch,and Screven County. As of December 1996 Savannah Electric served 120,448 customers at anoverall average rate of 6.40 cents per kWh.9

Savannah Electric has a total generating capacity of 840 megawatts.Their generating mix consists of 74% coal and 26% combustion turbines.10 They also contract for capacity with the City of Savannah and purchaseenergy from a number of cogenerators. Savannah Electric’s December 31, 1996 FERC FormNo. 1 indicated operating revenue of $ 225,919,194 and total assets of $ 564,257,221.

Southern Electric System

Southern Company is a utility holding companywith five electric utility operating subsidiaries that provide electric service in foursoutheastern states: Georgia Power Company and Savannah Electric and Power Company inGeorgia; Alabama Power Company; Gulf Power Company in Florida; and, Mississippi PowerCompany. The geographic area served by these utilities constitutes the Southern ControlArea. Southern Company Services, Inc., an affiliated company, operates the Southernelectric system from Southern Company’s William R. Brownlee Power Control Center(PCC) in Birmingham, Alabama.

The PCC was established to provide integrated and coordinatedoperation of the generation and transmission systems of Southern’s operatingcompanies. Using the guidelines established by the Operating Committee in the IntercompanyInterchange Contract (IIC), the PCC is responsible for coordinating the operation of thebulk power supply resources. Its objectives are to supply the territorial powerrequirements of the respective service areas of the operating companies at the lowestpractical cost consistent with a high degree of reliability of the bulk power supply, andfulfill the interconnected contractual agreements with non-associated utilities.

The scope of the Power Coordination Center’s responsibilitiesconsists of the following:

1. Unit Commitment—Determine the appropriate set of generating units and other power supply resources required to economically meet projected integrated system demand on a daily basis.
2. Economic Dispatch—Determine the desired loading of the generating units and power supply sources connected to the integrated system.
3. Common Interchange—Implement the interchange of power with the non-associated companies that are interconnected with the Southern electric system.
4. Bulk Power Transmission Security—Evaluate the security (reliability) of the bulk power transmission system (500 kV, 230 kV and all interconnections) and concur on actions required to ensure its integrity under first contingency conditions.
5. Maintenance Outage Coordination—Coordinate the unit maintenance outage requirements of the operating companies, including any auxiliary equipment which could curtail unit capacity, in such a way as to minimize cost to the system.
6. Record Keeping – Maintain specified operating data and records.

All major utility systems in the eastern half of the United States andCanada (except in Texas) are interconnected and operated synchronously as part of theEastern Interconnection—an interconnected grid of roughly 700,000 MW capacity. Withinthe Southern electric system generation is economically dispatched to meet resourceswithout regard for operating company boundaries. Power flows are scheduled and controlledbetween the Southern electric system and non-associated companies. The Southern Companycomplies with FERC requirements and operational guidelines established by the NorthAmerican Electric Reliability Council (NERC).

Interchange between independent utilities is regulated by the FERC,which regulates pricing and contract administration pursuant to the Federal Power Act. AllSouthern Company contracts must be filed with FERC. Standard practices and operatingprocedures are set forth by NERC, a voluntary organization of utilities that sets standardand practices for the industry. NERC’s Operational Guidelines are observed by allutilities.

The Southern electric system acts as a tight pool with the PCC atSouthern Company Services, Inc. acting to provide integrated and coordinated operation ofthe system. A power pool is a group of interconnected utilities that act together in aclosely coordinated manner to enhance reliability and economics. Loose pools maycoordinate only a few operational functions—typically interchange, spinning reservesand system security—among independent utilities. Tight pools, such as the Southernelectric system, share common unit commitment, economic dispatch and interchange functionsto maximize reliability while minimizing production costs.

By operating as a pool the Southern electric system derives significanteconomic and operational efficiencies: (1) Reserve sharing: An independent utilitywould have to carry reserves equal to its largest unit. A pool also carries reserves equalto its largest single unit, but each pool member carries only a portion of such reserves;(2) Construction staging: Individual utilities must add generation in incrementstoo small to take advantage of the economies of scale. A pool may add generation in largerincrements to be shared among several utilities and take advantage of the economiesoffered by size; (3) Buying power: A pool generally has more clout in purchasingoff-system capacity and energy than individual companies; and, (4) Reliability isgenerally enhanced by pool operations.11

Oglethorpe Power Corporation and the Electric Membership Cooperatives

Oglethorpe Power Corporation (OPC), the nation’s largest electriccooperative, supplies power to 39 of the state’s 42 Electric Membership Cooperatives(EMCs). OPC was created in 1974 by the General Assembly. The EMCs were formed during the1930s and 1940s to supply electricity to rural customers. Each EMC is customer-owned andself-regulating with rates set by their decision-making entity, the EMC Board ofDirectors. The Commission’s limited regulatory jurisdiction over the EMCs includesresolution of territorial disputes and approval authority over financing applications.Although the Commission does not approve rates for the EMCs, the EMCs are required to filetheir rates with the Commission.

Earlier this year OPC reorganized into three separate companies:Oglethorpe Power Corporation, Georgia Transmission Corporation and Georgia SystemOperations Corporation. Oglethorpe Power Corporation continues to provide power to themember EMCs. The Georgia Transmission Corporation manages OPC’s transmission linesand substations. Georgia System Operations Corporation operates the generating facilities,control room and dispatch of electricity. This reorganization differs from the usualvertically-integrated utility in that it functionally unbundles the major electricservices. The three companies are collectively owned by the EMCs. However, each of thethree companies has its own separate decision-making board.

Oglethorpe Power supplies energy to the EMCs from 3,338 MW of owned orleased generating capacity. The generating mix includes 37.7% coal, 36.9% nuclear and 2.4%hydro. The remaining energy needs, approximately 23%, are met with purchased power fromother utilities. In total, the 39 EMC’s serve 2.6 million customers.

Municipal Electric Authority of Georgia (MEAG) And The Municipals

MEAG is a public generation and transmission corporation, created in1975 by the Georgia General Assembly. MEAG has assets of $4.7 billion and owns a total of1,558 MW of generating capacity from facilities co-owned with Georgia Power Company, OPCand the City of Dalton. MEAG supplies electricity to its 48 member municipal electricutilities for distribution to their approximately 635,000 customers. Retail rates for eachmunicipal are set by their respective governing body, e.g., the city council or mayor. TheCommission has limited jurisdiction over municipals. However, they are required to filetheir rates with the Commission.

Tennessee Valley Authority (TVA)

Parts of extreme northern Georgia are supplied electricity by TVA. TVAis a federally-owned electric power system supplying power through five separatedistribution systems in Georgia: Blue Ridge Mountain EMC; North Georgia EMC; Tri-StateEMC; the City of Chickamauga; and, the Electric Power Board of Chattanooga. Approximately117,000 customers in ten North Georgia counties are served by these distribution systemswhich have long-term, all-requirements wholesale power contracts with TVA. TVA also servesas the regulator of these distribution systems and has authority over rates and othermatters for these distributors.

Congress established the TVA electric service territory through theTennessee Valley Authority Act, as amended in 1959. In defining the service area, Congressincluded a prohibition on the sale of TVA generated power by either TVA or a TVAdistributor outside the TVA boundary. The Georgia Territorial Act of 1973 allows otherutilities in Georgia to compete for new loads above 900kW demand in the TVAdistributors’ service territory while TVA distributors are federally restricted fromcompeting for similar customers in other suppliers’ service areas.12

Other Suppliers

The cities of Acworth, Chickamauga, Dalton and Hampton are not membersof MEAG Power. These municipalities purchase electricity on the wholesale market fromMEAG, TVA, Georgia Power and others. Other suppliers exist in Georgia who currently sell,or will soon sell, energy and capacity in the wholesale electric market. These includeIndependent Power Producers (IPPs), such as Hartwell Energy and U.S. Generating, andnumerous Qualifying Facilities (QFs), such as cogenerators and small power producers.These facilities are capable of producing in excess of 1000MW of capacity and may providein-state competition in a future competitive retail market.13

Integrated Transmission System

Currently, Georgia Power Company, Oglethorpe Power Corporation, MEAGand the City of Dalton jointly own the majority of Georgia’s transmission system.Savannah Electric is connected to the Integrated Transmission System through an interfacebut does not have any financial investment in the system. In January 1975 Georgia PowerCompany entered into separate contracts with each of the other utilities, selling themownership interests and equal access to the transmission facilities.

Several factors led to the creation of the Integrated TransmissionSystem (ITS). During the early 70’s OPC, MEAG and the City of Dalton purchasedgenerating capacity from Georgia Power Company. These companies also purchased ownershipinterest in the transmission system. This made it possible to receive energy from thegenerating plants in which they had purchased an ownership interest. The creation of theITS avoided the duplication of transmission facilities that otherwise would have occurredamong the Georgia utilities transmitting power to serve their respective customers. With ajointly-owned integrated facility, Georgia utilities have access to over 16,000 miles oftransmission line.

The ITS is a $3.4 billion investment that is used primarily to serveGeorgia load. It is interconnected with neighboring utilities through transmission tielines. These ties allow utilities to transfer power from one system to another. The tiesalso allow Georgia utilities to purchase power from neighboring utilities when it is lessexpensive than operating their own units. It also allows the utilities to sell andtransmit any excess power they may have available.

At the local level, the ITS is operated by Georgia Power Companythrough two Transmission Control Centers (TCC). The TCCs are the system operations agentsfor all of the owners of the ITS. One TCC is located in the northern region of the state,while the other is located in the southern region. The Transmission Control Centermonitors bus voltage, transmission line loading and network status throughout the ITS. TheTCC also reviews maintenance outage requests from the ITS owners to see if thetransmission system can withstand any single contingency during scheduled maintenanceactivities. The ITS is located within the Southern Company Control Area and SouthernCompany Services is responsible for operating the control area in compliance with NERC andSERC guidelines.14

A Joint Committee, comprised of two members from each of the owners ofthe ITS, was established in August 1976. The Joint Committee, along with threesubcommittees, make up the decision-making body for the ITS and are responsible forchanges, additions and improvements to the transmission facilities. This body ensures thatthe system can handle current and future loads of the co-owners and that tie lines withneighboring utilities are adequate. The Joint Committee also ensures adherence by allparties to the ITS Agreements.

The existence of a fully integrated transmission system in Georgiaallows the owners of this system to compete for customer choice loads provided by theGeorgia Territorial Act. The ITS has made it economically feasible for limited competitionto exist in Georgia for the past 20 years.

Although the transmission system is defined as jointly-owned, eachtransmission facility has a single owner. Each utility is responsible for maintaining itsown facilities and develops separate maintenance standards for its respective facilities.These standards make no distinction between the facilities that serve the owner and thefacilities that serve the other ITS participants. The cost of maintenance is theresponsibility of the owner of the facility.

As of December 1996 the ownership investment percentages in theIntegrated Transmission System were Georgia Power Company 66.48%, Oglethorpe Power Corp.23.43%, MEAG 8.68%, and the City of Dalton 1.41%. The utility’s percentage investmentin the system is equal to its peak load ratio. If the utility’s investment is notequal to its load ratio, it can consider the purchase or sale of transmission facilitiesfrom or to another co-owner.

In the event that a utility has more invested in the system than isrequired, then the under-invested utility is required to pay the over-invested utility theamount of the over-investment multiplied by the higher of the two utilities’ carryingcharge. However, paying this amount does not confer any ownership interest in thefacilities.

The ITS arrangement, which has existed for more than 20 years, isunique to Georgia. The ITS allows Georgia utilities access to power delivery systems forbuying and selling available wholesale electric energy both within and outside of Georgia.This helps reduce energy prices in Georgia while minimizing the impact on the physicalenvironment. The ITS enabled joint transmission services to be offered in Georgia yearsahead of the recent federal initiative, creating transmission open access at the wholesaleutility business level on a regional and national basis.

It remains to be seen what impact a federal retail access mandate mayhave on the ITS. If competition is not federally mandated, but increased competition isbrought about through amendments to the Georgia Territorial Act, it may be advantageous tokeep the ITS, or some variation of the ITS, in place.

4. B. Regulatory Entities and Statutes Affecting theElectric industry

The Georgia Public Service Commission

Duties and powers of the Georgia Public Service Commission(Commission) extend to electric light and power companies, or persons owning, leasing oroperating public electric light and power plants furnishing service to the public.15 The Commission hasexclusive power to determine just and reasonable rates and charges to be made by anyperson, firm or corporation subject to its jurisdiction. Georgia Power Company andSavannah Electric are the two investor-owned electric companies under full Commissionrate-making jurisdiction. The Commission has limited authority with respect tocooperatives or municipals, who must file their rate with the Commission. The Commissionapproves the issuance of certain EMC bonds and notes and enforces rules and regulations toprovide electric service to an EMC’s members. Where EMCs receive financial supportfrom the federal Rural Utilities Service (RUS) agency, RUS guidelines and Commissionapprovals exist to help assure that all financial requirements are met. The Commissionalso has certain authority granted under the Georgia Territorial Electric Service Act.16

Currently, the Commission’s authority over investor-ownedutilities includes regulation of bundled rates for generation, transmission, distributionand other costs necessary to serve the retail customer. If retail generation is opened tocompetition, it is expected that the Commission would no longer set the rates for thecommodity portion of electric service; however, the Commission would continue to set ratesfor distribution and other customer services currently bundled with the commodity charge.In addition, other regulatory responsibilities, such as ensuring the quality of serviceand fair treatment of customers, would remain.

The Integrated Resource Planning Act

The Commission has responsibility pursuant to the Integrated ResourcePlanning Act to review and approve supply-side and demand-side resource options filed bythe utility companies. The purpose of this certification process is to ensure that energyrequirements are met and customers receive safe and reliable electric service. TheIntegrated Resource Planning Act (IRP Act) was established by the state legislature in1991.17 The IRP Actresulted from the Commission’s ex post facto reviews of generating plants, such asthe Commission’s review of Georgia Power Company’s construction of Plant Vogtle.Prior to enactment of the IRP Act, the Commission did not review a utility’smanagement decisions pertaining to the need, planning and construction of expensiveelectric generating facilities until the company applied for financing approval or filedfor recovery of these costs in rate case proceedings after the plants were partially builtor completed. If planning or construction management decisions were found to be imprudentor if the facility was deemed unnecessary, the Commission could disallow recovery ofcertain costs.

The IRP Act gave the Commission the authority to review, modify, rejector approve a plan for meeting future energy demands prior to any commitment regardingconstruction of the facility, contracting for purchase power or the expenditure of largesums of capital. This certification process helps to ensure the energy is needed, givesthe utility more certainty in recovery of expenditures and ensures that the source ofpower with the best value is selected after considering both cost and reliability.

The IRP Act provides for utilities to file a plan at least every threeyears. The plan must include a 20-year projection of energy requirements and consider theeconomics of all options available to meet these requirements including supply-sideresources, demand-side resources, purchased power and cogeneration. Long-term plans forthe type of facility needed, the size, and the required commercial operation date aredetermined and approved by the Commission. Before construction of a facility has begun ora purchased power agreement is finalized, the Commission must first certify the need forthe facility, contract or conservation program, and determine that it is the appropriatetype facility based on economic analysis. Once certified, the utility is guaranteedrecovery of the actual prudently incurred costs. The IRP Act also provides the Commissiona means to ensure that a reliable supply of low cost energy will be available for the longterm.

In the past, long range planning and the orderly addition of powerfacilities to supply a defined service territory have given consumers in Georgia a highlyreliable and efficient electric generation, transmission and distribution network. Thissystem has responded well to accidents, natural disasters and rapid growth in customerpower demands. The following questions illustrate some of the planning issues which mustbe resolved or considered prior to legislative alterations to the current regulatoryscheme.

• In the short term, if price becomes the driving force of competition, will the incentive remain to plan, maintain, and develop a reliable power system?18

• Some parties believe that the planning function will not be compromised by competition. It can only be enhanced. The traditional command-and-control type of planning that is the basis of the monopoly IRP approach aggregates system planning and market planning.19

• Competitive bidding has been used as a proxy for and transition vehicle to full competition. However, in many situations, the competitive bidding process has worked to delay entry into the electric marketplace. If any party is able to control market entrance through design of a bidding process, new market entrants will continue to find the door shut to the market. A fully competitive market will demand quick supplier response and will not tolerate the suppression of market function.20

• Will generators or suppliers be required to provide reserves to the distribution company? How will both spinning and planning reserves be provided and paid for? What will be the penalties for non-delivery?21

• What future role will the Commission retain in assuring reliability and cost-effective energy supplies for Georgia? Should the legislature amend the IRP Act in advance of overall restructuring of the industry, depending on the pace and direction of that overall change?22

• Will IRP or DSM programs have any role in the competitive retail electric environment?23

• How will requiring adequate power reserves protect the integrity of the system?24

This Commission should retain regulatory oversight concerningreliability to ensure that the supply of generation is adequate and system security is notcompromised. The manner and extent of this oversight would vary depending upon the marketstructure and actions of the market participants. Possible Commission roles could becoordinating a long-term planning forum or setting reliability and planning requirementsfor newly certificated suppliers and for existing suppliers in the generation market inGeorgia.

The Georgia Territorial Electric Service Act

Customer choice for new large commercial and industrial customers witha load of 900kW or more has been in place in Georgia for more than 20 years, long beforethe national debate on electric industry restructuring began. The Georgia TerritorialElectric Service Act of 1973 (Territorial Act or Act) established territories for servingresidential and small commercial customers as well as initiating the customer choiceprovisions for large customers.25 These legislative and regulatory provisions in Georgia have provided thefoundation for an effective electric utility structure.

The Territorial Act was enacted March 29, 1973 to assure the mostefficient, economical and orderly rendering of retail electric service within the state,avoid duplication of electric lines, foster the extension and location of electricsuppliers’ lines in a manner most compatible with the state’s preservation andenhancement of the physical environment, and to protect and conserve lines lawfullyconstructed by electric suppliers.

Electric suppliers under the jurisdiction of the Territorial Act areGeorgia Power Company, Georgia’s Electric Membership Cooperatives (42 EMCs),Municipal Electric Authority of Georgia (MEAG), Savannah Electric and Power Company, NorthCarolina’s Haywood EMC and Tennessee’s Electric Power Board of Chattanooga.

Under the Territorial Act, every geographic area within the state waseither assigned to an electric supplier or declared unassigned as to any electric supplierby the Commission. Customers with connected loads of less than 900kW (about the size of amodern grocery store) must take electricity from the franchised supplier. However,if any customer with a load of 900kW or more locates within the corridors of an electricsupplier’s lines, that customer may have a choice of suppliers. Once a customerchooses a supplier, the Territorial Act provides that the chosen electric supplier has theexclusive right to serve that customer for the life of the premises.26

Georgia Power Company estimates that since enactment of the TerritorialAct, approximately 2,800 large and small customers throughout the state have been able tochoose their electric supplier when locating new facilities in Georgia. Georgia electricsuppliers compete for about 500 MW of load each year.

The Territorial Act was the result of a compromise negotiated by all ofthe electric suppliers doing business in the State of Georgia during the early 1970s. A900kW level was agreed upon as the load threshold for customer choice. This load level waschosen because a 900kW load was considered sufficient to justify the economics of theinvestment necessary to serve the load and foster competition for that load.

Some advantages of the current structure have been to produce extremelyreliable electric service and provide that service at prices that are reasonable whencompared to many other states and the nation as a whole. While some parties believe thatthe Territorial Act has worked well to foster competition, others believe the TerritorialAct should be repealed and the market should be allowed to develop as it will.

Still others believe that competition could be increased by modifyingthe Territorial Act. This could be accomplished by reducing the 900kW threshold exemptionand by allowing existing customers to renegotiate contracts after a specified period oftime. While increasing competition this would limit the competitive choices to thosesuppliers currently providing retail electric service within the State of Georgia. Ifretail access is mandated by the federal government, this scenario may or may not beacceptable since it could prohibit out-of-state suppliers from providing retail generationservice in Georgia. This scenario could also cause duplication of distribution facilitiesat levels that may or may not be cost-effective, which the Territorial Act had intended tomitigate. For these reasons competition at levels below the 900kW threshold exemptionshould be restricted to generation services and not for the extension of distributionfacilities. Changes to the Territorial Act that impact generation services may beappropriate, whereas changes that affect territorial assignments or exemptions fortransmission and distribution services may not.

The participants at the workshops and in the focus groups reached ageneral consensus for restructuring the electric industry. The consensus was that, ifgeneration was opened to competition, territorial assignments for distribution linesshould be kept and distribution service should remain as a state regulated service.Transmission services would be regulated by the FERC. For this consensus model to workaccess to the distribution system must be granted to all suppliers. Any access chargeshould be the same for all customers connected to that distributor.

5Memorandum of Municipal Electric Authority of Georgia, Docket No. 7313-U, March 20, 1997 and Written Comments of Georgia Power Company, Docket No. 7313-U, March 20, 1997.
Back to Text 6A list of generating facilities owned by GPC and a list of jointly-owned facilities are included in Appendix D, List of Generating Facilities, on page 98 of this report.
Back to Text 7Georgia Power Company, 1997 Facts and Figures.
Back to Text 8Georgia Power Company, 1996 Annual Report.
Back to Text 9Savannah Electric and Power Company, 1996 Annual Report.
Back to Text 10A list of Generating Facilities owned by Savannah Electric is included as Appendix D List of Generating Facilities, on page 98 of this report.
Back to Text 11"Power Pooling in the Southern Electric System," Raymond L. Vice, Bulk Power Operations, Southern Company Services, Inc.
Back to Text 12Comments submitted by the Tennessee Valley Public Power Association, Docket No. 7313-U, March 1997.
Back to Text 13Approximate Capacity Ratings: Hartwell Energy has 300MW; U.S. Generating has 475MW; and Mid Georgia Cogen. has 300MW.
Back to Text 14NERC is the North American Electric Reliability Council and SERC is the Southeastern Electric Reliability Council.
Back to Text 15O.C.G.A. § 46.
Back to Text 16See Georgia Territorial Electric Service Act on page 24 of this report.
Back to Text 17O.C.G.A. § 46-3A et seq.
Back to Text 18Comments submitted by the Tennessee Valley Public Power Association, Docket No. 7313-U, March 1997.
Back to Text 19"Retail Competition in the U. S. Electricity Industry," A Special Report by the Electricity Consumers Resource Council, June 1994.
Back to Text 20Comments submitted by U. S. Generating Company, April 1997.
Back to Text 21GPSC Electric Workshop "Presentation of Conclusions, and Development of Plan of Future Action" Statutory Changes Focus Group Report, July 1997.
Back to Text 22Ibid.
Back to Text 23Comments submitted by the Tennessee Valley Public Power Association, Docket No. 7313-U, March 1997.
Back to Text 24Ibid.
Back to Text