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Ordinance No. 4,49460710 -1 ORDINANCE NO. 4494 AN ORDINANCE SETTING RATES TO BE CHARGED BY HOUSTON LIGHTING AND POWER COMPANY FOR ELECTRIC UTILITY SERVICE WITHIN THE CORPORATE LIMITS OF THE CITY OF BAYTOWN, TEXAS; CONTAINING FINDINGS AND PROVISIONS RELATED TO THE SUBJECT; PROVIDING FOR THE REPEAL OF INCONSISTENT ORDINANCES; CONTAINING A SAVINGS CLAUSE; AND PROVIDING FOR THE EFFECTIVE DATE HEREOF. WHEREAS, on or about March 18, 1986, Houston Lighting and Power Company (the "Company "), filed with the City of Baytown a Statement of Intent and Petition for Authority to Change Rates relating to electric utility service, and proper notice thereof was duly given; and WHEREAS, by Ordinance No. 4424, the City Council suspended the effective date of such proposed rate increase until July 23, 1986; and WHEREAS, the City Council, having considered the Company's rate increase at a public hearing for which proper notice was duly given, finds that such request is excessive; and WHEREAS, the City Council having original jurisdiction over the matter finds that a lesser increase in rates should be prescribed for the Company; NOW THEREFORE, BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF BAYTOWN, TEXAS: Section 1: The City Council of the City of Baytown hereby finds the requested rates of the Company to be excessive and unreasonable. Section 2: The City Council hereby approves and adopts the rates, adjustments, determinations, and recommendations of the set out in Exhibit "A," attached hereto and incorporated herein for all purposes, and additionally finds and determines the following: I. Findings 1. Cost of Service The revenue requirement of the Company is $3,087,698,00U.00. Adjustments were made to operations and Maintenance, Fuel Expenses and Purchased Power, Depreciation expense, Other Taxes, Federal Income Taxes and the Return component. a. Operations and Maintenance Expenses 60710 -1a Adjustments to the Company's O & M expenses amounted to $45,097,000.00. the major adjustments include a reduction in Salaries and Wages expense of $4,618,000.00, a reduction of Limestone Operating Expenses of $1,889,000.00, a reduction in Municipal Street Use Fees of $7,696,000.00, a reduction in Rate Case Expenses of $1,059,000.00, elimination of EEI dues of $331,000.00, a reduction in Gas Operation and Maintenance Expense of $9,464,000.00, and a reduction for Non - Recurring Maintenance of $8,550,000.00. b. Fuel Expenses and Purchased Power The adjustment of Fuel Expenses is a reduction of $136,181,000.00. The adjustment to Purchased Power is a reduction of $40,961,000.00. The Overall Fixed Fuel Factor per KWH is $0.020386, the Distribution Level Fixed Fuel Factor per KWH is $0.020654, and the Transmission Level Fixed Fuel Factor per KWH is $0.019713. c. Depreciation The total adjustment to Depreciation Expense is a reduction of $13,835,000.00. d. [ether Taxes The total adjustment for all Taxes Other than Federal Income Taxes is a net reduction of $5,013,000.00. e. Federal Income Taxes The adjustment to the Cost of Service for Federal Income Taxes is a reduction of $65,507,000.00. f. Return The rate of return on equity is 14.75 percent. The rate of return on invested capital is 11.58 percent. 2. Invested Capital The invested capital is determined to be $4,764,986,000.00. 3. Adjustments to Invested Capital The adjustments to invested capital include a decrease of $5,496,000.00 in Plant in Service, an increase of $1,243,000.00 in Construction Work in Progress, a reduction of $2,713,000.00 in Fuel Oil Inventory, a reduction of $82,702,000.00 in Working Cash Allowance, a reduction of $64,625,000.00 in Deferred Limestone Cost, a reduction of $8,880,00.00 in Unrecovered Storm Loss, a reduction of $29,878,000.00 in Deferred Taxes, and a reduction of $5,280,000.00 in other Cost -Free Capital. 4. Revenue Deficiency The overall revenue deficiency is $159,759,000.00. 60710 -1b 5. Rate Structure a. Residential The rate structure for the residential customer class is: Summer: Customer Charge of $9.00 per month, which includes 250 kwh all kwh over 251 kwh at 6.2460 cents per kwh plus: fuel charge of 2.0854 cents per kwh for all kwh Winter: Customer Charge of $9.00 per month, which includes 250 kwh 251 -1,000 kwh at 6.2460 cents per kwh over 1,000 kwh at 2.9655 cents per kwh plus: fuel charge of 2.0854 cents per kwh for all kwh b. All Other Customer Classes The rate structure for all customer classes other than residential is that proposed in the Company's Statement of Intent and Petition for Authority to Change Rates. II. Related Issues 1. The City Council hereby authorizes the Company to utilize the following deferred accounting treatment for certain expenses related to Limestone Unit 2: Beginning on the commercial in- service date as defined by the Public Utility Commission of Texas ( "commercial in- service date ") for Limestone Unit 2 and continuing for a period of time ending eighteen (18) months after that in- service date or upon the effective date of rates set as a result of the Company's next filed statement of intent to change rates, whichever ending date is sooner, the Company may place into a deferred account all depreciation expense, tax expense, and operation and maintenance expense incurred during that time period by the Company related to Limestone Unit 2, and upon review, approval, and adjustment of such deferred expenses by the City in the proceeding considering the Company's next filed statement of intent to change rates, these deferred amounts shall be amortized over a period of ten years from the commercial in- service date of Limestone Unit "2. The City Council hereby orders the Company, upon the commercial in- service date for Limestone Unit 2, to transfer its total investment in Limestone Unit 2 from Construction Work in Progress to Plant in Service. The City reserves the right to exclude from rate base or other recovery any portion of the expenditures from the plant, AFUDC, capitalized expenses, capitalized depreciation or other capitalized costs related to Limestone Unit 2 that the City determines is not used and useful, has been imprudently spent or incurred, or is in any other way not lawfully 60710 -1c includable in rate base or other recovery. The City further reserves the right to determine the reasonableness and prudence of any deferred expenses in the rate order in which rate base treatment for Limestone Unit 2 is requested. The City Council finds that all of the Company's investment in Limestone Unit 2 as of December 31, 1985, is presently in rate base as Construction Work in Progress. The City Council hereby orders that the Company shall not, after the date of final passage of this ordinance, accrue any AFUDC on any Limestone Unit 2 investment. 2. The City Council hereby orders the Company, after the date of final passage of this ordinance, to include in reconcilable fuel expense for any fuel purchased from an affiliate only fuel prices at cost, and to exclude any returns on or of equity. 3. The City has incurred expenses for the purpose of conducting investigations, presenting evidence, advising and representing the governing body, and assisting with litigation in connection with the request of the Company to change its rates. The Company shall reimburse the City for the reasonable costs of such services pursuant to Section 24(2) of the Public Utility Regulatory Act, TEX.REV.CIV.STAT.ANN., art. 1446c (Vernon Supp. 1986). The Mayor shall forward to the Company an invoice or invoices for such costs together with a request for reimbursement. The Company shall reimburse the City for such costs incurred within thirty days after having received each such request. III. Conclusions 1. The City has original jurisdiction over this case pursuant to Section 43 of the Public Utility Regulatory Act, TEX. REV. CIV. STAT. ANN., art. 1446c (Vernon Supp. 1984). 2. The Company has the burden of establishing its revenue deficiency under its present rates and of establishing the amount of such deficiency that will be collected under its proposed rates pursuant to Section 40 of the Public Utility Regulatory Act. 3. The rates prescribed herein will allow the Company to recover its operating expenses together with a reasonable return on its invested capital, pursuant to provisions of Section 39 of the Public Utility Regulatory Act. 60710 -1d 4. The rates prescribed herein will permit the Company a reasonable opportunity to earn a reasonable return upon the invested capital used and useful in rendering service to the public over and above its reasonably necessary operating expenses as provided by Section 39 (a) of the Public Utility Regulatory Act. 5. The rates for electric service set forth herein provide just and reasonable and not unreasonably preferential, prejudicial, or discriminatory rates, and are sufficient, equitable, and consistent in application to each class of consumer, as provided by Section 38 of the Public Utility Regulatory Act. Section 3: The City Council hereby determines prescribes, establishes and authorizes the increased rates for sale or supply of electric service by the Company within the corporate limits of the City of Baytown as set out in this ordinance. Such increased rates shall become effective as to each customer on or no later than the thirtieth day after the date of final passage of this ordinance. The Company shall be authorized to collect such rates until such time as they may be changed, modified, amended or withdrawn in accordance with applicable statutes and ordinances. Section 4: The City Council hereby authorizes and directs the City Clerk to serve the company with a certified copy of this ordinance which is the final determination and order of the City. Section 5: The Company shall, within ten days following the final passage and approval of this ordinance and thereafter whenever required by applicable statutes and ordinances and whenever requested by the City, file a complete schedule of rates and tariffs with the City setting forth all of the Company's rates and charges for utility service then in effect. The Mayor is authorized to review, approve and require revisions to the tariff if he determines it not to be in accordance with this ordinance. Section 6: Nothing contained in this ordinance shall be construed now or hereafter as limiting or modifying, in any manner, the right and power of the city under the law to regulate the rates and charges of the Company. Section 7: All ordinances or parts of ordinances in conflict herewith are repealed to the extent of the conflict only. Section 8: In the event that the Company appeals from this order setting electric rates for the Company, the City hereby waives written notice of the hearing before the Public Utility Commission of Texas ("PUC ") on such appeal. 60710 —].e With respect to any such appeal, the City Council hereby authorizes the City Attorney or his designees to represent the City and its citizens in any and all matters in connection with such appeal and to take any and all actions necessary and incidental thereto and to the resolution of the matters subject to such appeal, all as may be in the best interests of the City. Section 9: if any provision, section, exception, subsection, paragraph, sentence, clause or phrase of this ordinance or the application of same to any person or set of circumstances, shall for any reason be held unconstitutional, void or invalid, the validity of the remaining portions of this ordinance or their application to other persons or sets of circumstances shall not be affected thereby, it being the intent of the City Council in adopting this ordinance that no portion hereof or provision or regulation contained herein shall become inoperative or fail by reason of any unconstitutionally, voidness or invalidity of any other portion hereof, and all provisions of this ordinance are declared to be severable for that purpose. Section 10: The City Council officially finds, determines, recites and declares that a sufficient written notice of the date, hour, place and subject of this meeting of the City Council was posted at a place convenient to the public at the City Hall of the City for the time required by law preceding this meeting, as required by the Open Meetings Law, TEX. REV. C1V. STAT. ANN., Article 6252 -17, (Vernon Supp. 1986 ); and that this meeting has been open to the public as required by law at all times during which this ordinance and the subject matter thereof has been discussed, considered and formally acted upon. The City Council further ratifies, approves and confirms such written notice and the contents and posting thereof. Section 11: This ordinance shall take effect immediately from and after its passage by the City Council of the City of Baytown. INTRODUCED, READ, and PASSED by the affirmative vote of the City Council of the City of Baytown, this the 10th day of July, 1986. ATTEST: r1LEEN P. HALL, City Clerk APPROVED: /Attorney 60710 -1f PETITION OF HOUSTON LIGHTING & POWER COMPANY FOR AUTHORITY TO CHANGE RATES RECOMMENDATION OF THE DIRECTOR OF REVENUE & REGULATORY AFFAIRS 60710 -1g TABLE OF CONTENTS Page I. Executive Summary ............ ..............................1 II. Cost of Service ............ .......................•••••••• .3 A. Operations and Maintenance Expenses .............0.0...03 1. Salaries and Wages .. ..............................3 2. Employee Benefits ... ..............................3 3. Limestone Operating Expenses ......................4 4. Municipal Street Use Fee .......................... 4 5. Rate Case Expenses .. ..............................5 6. Edison Electric Institute Dues ....................5 7. Management Audit .... ..............................6 8. Leases and Rental ... ..............................6 9. Uncollectible Accounts ............................ 6 10. Advertising, Contributions & Donations ............ 7 11. Wheeling Expenses .............. 0.0............... .7 12. Limestone Amortization ............................ 8 13. Other Operations & Maintenance Expenses ........... 8 B. Fuel Expenses ............................. ... ... ......11 C. Purchased Power Expense .. ............••••••••••••••••.11 D. Depreciation Expense ..... .............................11 E. Taxes other than Federal Income Taxes .................12 F. Federal Income Taxes ..... .............................12 G. Return on Investment ..... .............................12 III. Rate Base .................... .............................14 A. Electric Plant in Service ............................. 14 B. Construction Work in Progress .........................14 60710 -1h Page C. Property Held for Future Use ..........................14 D. Nuclear Fuel in Progress . .............................15 E. Fuel Oil Inventory ....... .............................15 F. Working Cash Allowance ... .............................16 G. Prepayments .............. .............................16 H. Deferred Limestone Expenses ...........................17 I. Unrecovered Storm Losses . .............................17 J. Deferred Taxes ........... .............................17 K. Other Cost -Free Capital .. .............................18 IV. Revenue Requirement .......... .............................19 V. Cost Allocations ............. .............................19 VI. Rate Design .................. .............................20 VII. Schedules 1. Revenue Requirement 2. Calculation of Rate Adjustments 3. Operations and Maintenance Expense Adjustments 4. Summary of Fuel and Purchased Power Costs 5. Rate Base 6. Summary of Cash Working Capital 7. Cost of Capital 8. Graph of Residential Rates 9. Weighted Average Cost of Gas, 1969 - 1986 60710 -1i I. EXECUTIVE SUMMARY On March 18, 1986, Houston Lighting & Power Company ( "HL &P ") filed a rate change application with the City of Houston, other municipal regulatory authorities and the Public Utility Commis- sion of Texas ( "PUC "). The application proposes to increase the non -fuel component of rates by $345,289,000, or 18.7 %, and to decrease the fuel component of rates by $520,461,000, or 32.4 %.1 The net effect of the request would be to reduce overall revenues by $175,172,000, or 5.1 %, as compared to adjusted re- venues for the test year ended December 31, 1985. On April 15, 1986, City Council authorized execution of con- tracts with three public utility consulting firms. These con- sultants, together with the staff members of the Revenue & Regu- latory Affairs Division, have conducted a thorough review of the rate adjustment application and the books and records of the utility. Based upon this analysis, it is recommended that City Coun- cil authorize an increase in the non -fuel component of rates in the amount of $149,962,000, or 8.11 %, and a decrease in the fuel - related component of rates by $562,519,000,2 or 34.07 %, on an 1 The proposed decrease in fuel revenues includes a fuel cost overrecovery through December 1985 in the amount of $180,897,000 for which customers received a bill credit in May 1986. On a fully normalized basis, the amount of over - recovery should not be included in the calculation of the proposed rate change. Excluding this amount, HL &P's pro- posal would result in a $340,757,000, or 21.2 %, reduction in the fuel - related component of rates, and a $4,532,000, or .13 %, increase in overall revenues. 2 This amount does not reflect fuel cost overcollections which were refunded in May 1986, nor fuel cost overrecoveries which have occurred since the end of the May refund per- iod. The most recent overrecoveries will be refunded or credited pursuant to the PUC's Substantive Rules upon approval by the PUC. -1- 60710 -1j annual basis. The net effect of the recommended rate adjustments would be an annual decrease in revenues in the amount of $412,558,000, or 11.79 %, as compared to fully adjusted test period revenues. The primary reason for the recommended increase in base rates is the addition of HL &P's new Limestone Unit 1 electric generating station which began commercial operation in December 1985. The total cost of the lignite- fired, 720 mW unit was $893 million. With the completion of Limestone Unit 1, HL &P's fuel mix is further diversified, reducing its dependence on natural gas from 75% to 66% of the fuel mix3. Lignite is projected to be less costly than the natural gas burned in the gas fired units displaced by Limestone Unit 1. The current cost of lignite is $1.12 per million btu's ("mmbtu "), while HL &P's current cost of natural gas ranges between $1.425 and $2.26 per mmbtu. The reduction in fuel cost attributed to the first year of operation of Limestone Unit 1 is projected at $23,351,000. HL &P's weighted average cost of gas for the period 1969 through 1986 is shown on Schedule 9. The specific adjustments made to HL &P's request are summa- rized below and are explained more fully in the testimony of the staff experts and consultants. Copies of the testimony are available for review in the City Secretary's office and may be obtained upon request from Jane Cater, 864 -5840. 3 Includes cogeneration purchases which are fueled by natural gas. -2- 60710 -1k II. COST OF SERVICE A. OPERATIONS AND MAINTENANCE EXPENSES 1 . Salaries and Wages ($4,618,000) Salaries and wages have been adjusted to reflect the annualization of HL &P's payroll for the period ended April 30, 1986. Additional adjustments were made to re- flect a 3.5% union wage increase effective May 22, 1986, and to apply a 2% attrition factor to give effect the HL &P hiring freeze currently in effect. The number of employees as of April 30, 1986, 11,605, was determined to be representative of the aver- age number generally employed by the utility. Tests were made to determine the reasonableness of the percentage of overtime paid during the test year and the percentage of labor costs capitalized during the test year as compared to previous years. HL &P's use of these test year percentages was found to be reasonable. 2. Employee Benefits ($816,000) The amount of Life Insurance cost requested by HL &P included amounts related to affiliates of HL &P. These were removed. In addition, the life insurance premium was reduced to reflect interest which will be earned on the balance HL &P has on deposit with its insurance com- pany. A third adjustment to Life Insurance cost was made to include $579,000 of test year expense inadver- tently excluded in the Company's calculation of the ad- justment. Expenses associated with all other Employee Bene- fits including Medical and Dental Insurance, Workers' Compensation Insurance, and the Retirement and Savings -3- 60710 -1L Plans, were reviewed and found to be reasonable. These expenses have therefore been included in the Cost of Service. 3. Limestone Operating Expenses ($1,889,000) HL &P's 720 mW Limestone Unit 1 began commercial operation in December 1985. Operations and Maintenance (0 &M) expenses associated with the power plant have been estimated based on actual O &M expenses incurred during the first three months of 1986. Certain adjustments were made prior to annualizing the expenses incurred during the first quarter of operation to: 1) give effect to property insurance premiums which are paid monthly but were not actually included in O &M expenses until March 1986; 2) remove non - recurring moving expen- ses incurred during the month of March 1986; and 3) exclude vacation and holiday pay incurred in the first quarter of 1986, because these amounts have been inclu- ded in the recommended amount of Salaries & Wages expense. 4. Municipal Street Use Fee $(7,696,000) In March 1985, the City of Houston and HL &P entered into an Agreement to settle all issues of a lawsuit brought against HL &P by the City concerning the method of calculating and paying franchise fees for the years 1980 through 1985. The Settlement involved use of a surcharge to HL &P customers for City Franchise Fees not received for the period 1980 through 1985. Because this Settlement is non - recurring in nature, the factor used to compute Municipal Street Use Fees in the current rate case has been adjusted to remove all effects of the settlement. -4- 60710 -1m Municipal Street Use Fees were subtracted from the Revenue Requirement prior to designing base rates be- cause these fees are recovered through a line item on the bills of customers residing within municipalities. 5. Rate Case Expenses ($1,059,000) Rate Case Expenses associated with the current case have been adjusted to reflect all known and measurable changes to the test year amount. Rate Case Expenses incurred in prior cases which were associated with the South Texas Nuclear Project have been amortized over a two year period. Finally, an adjustment was made to include only 50% of the adjusted balance of Rate Case Expenses in the Cost of Service. The remaining fifty percent of all costs associated with rate case activity will therefore be borne by HL &P's shareholders. This adjustment recog- nizes that shareholders receive benefits from the Com- pany's rate cases. Such benefits include the opportun- ity to increase profitability and to more closely align costs and revenues. 6. Edison Blectric Institute Dues ($331,000) HL &P has requested the inclusion of EEI support in the amount of $331,000 in the Cost of Service. Section 41(c)(3) of the Public Utility Regulatory Act ( "PURA "), provides that "regulatory authorities shall not consider for ratemaking purposes ... legis- lative advocacy expenses." Because there is reason to believe that EEI dues are used to support the lobbying and advocacy functions of EEI, and because HL &P has not proved that its EEI expenditures were not used for leg- -5- 60710 -1n islative advocacy, all EEI dues paid by HL &P during the test year have been excluded from the Cost of Service. 7. Management Audit In 1984, H a new state law of Texas ( "PUC" fated utilities Young & Company audit of HL &P. ($652,000) L &P was the first utility examined under requiring the Public Utility Commission to conduct management audits of regu- at least once every ten years. Arthur was selected to perform the management In a recent case before the PUC, the Commission ordered the amortization over a three year period of the cost of a management audit of El Paso Electric Com- pany. Because of this precedent, and because the HL &P management audit conducted by Arthur Young & Company should prove of benefit for a number of years, the $978,000 cost of the audit has been amortized over a three year period. I 8. Leases and Rental ($3181000) Several adjustments have been made to Lease and Rental expenses to remove: 1) claimed operating cost adjustments, not supported by HL &P, associated with two leases; 2) a rounding adjustment of $39,572 made by HL &P in the calculation of the cost of a Greenway Plaza lease; and 3) the cost of three leases in Austin, Texas, which are not necessary to the provision of electric service in the Houston area. 9. Uncollectible Accounts ($947,000) A factor was determined for use in projecting uncollectible accounts expenses by dividing the test OM 60710 -10 year amount of uncollectible account write -offs by asso- ciated revenues "lagged" 140 days. One- hundred forty days was determined to be the average length of time between revenue recognition and the write -off of an uncollectible account. When compared to the uncollect- ible account factor determined in the previous rate case, the test year factor indicated improvement in the percentage of accounts written -off by HL &P. 10. Advertising, Contributions & Donations ($13,000) Section 23.21(b)(2) of the PUC's Substantive Rules requires exclusion of certain types of donations from the Cost of Service. All donations made by HL &P during the test year were reviewed and several donations which totaled $12,500, were excluded from the Cost of Service in accordance with the Substantive Rule. Section 23.21(b)(1)(E) of the Substantive Rules provides that the total of all advertising, contribu- tions and donations included in the Cost of Service shall not exceed 3/10 of 1% (0.3 %) of the gross receipts of the utility. A test was made of HL &P's compliance with the "3 /10's of 1V rule, and it was found that the utility was in compliance, spending 1/10 of 1% of gross receipts on advertising, contributions and donations during the test year. 11. Wheeling Expenses ($1971000) HL &P purchases power from the City of Austin and City Public Service Board of San Antonio pursuant to contracts with both. The expenses associated with "wheeling" power from Austin and San Antonio through the service areas of other utilities have been adjusted to reflect the projected cost of all wheeling contracts currently in effect. -7- 60710 -1p 12. Limestone Amortization ($7,056,000) HL &P has requested authorization to defer certain expenses associated with Limestone Unit 1 during the period December 1985 through September 1986, and to then amortize these expenses through rates over a ten year period. The request by the utility would effectively result in selective ratemaking. For this reason, expenses associated with Limestone Unit 1 during the requested period (prior to a final rate order in the current case) have not been deferred. On a prospective basis, it is recommended that the utility be authorized to defer operations and mainte- nance expenses, depreciation expenses and property taxes from the date of commercial operation of Limestone Unit 2 for a period of time not to exceed 18 months or until such time as rates set in HL &P's next general rate pro- ceeding become effective, whichever is sooner. An ad- justment will be made to reduce the deferred amount to reflect declining O &M expenses at power plants displaced by Limestone Unit 2. A review for reasonableness of expenses will be conducted at such time as HL &P proposes to amortize the deferred amounts through rates. 13. Other Operations & Maintenance Expenses a. Reduction in Gas O &M Expenses ($9,464,000) An adjustment has been made to reflect declining operating costs associated with certain gas gener- ating units, the production from which has been displaced by Limestone Unit 1 and cogeneration purchases. W-M C. M e. New Billing Procedures 60]10 -1q ($255,000) Effective April 1986, HL &P changed its billing format. The cost savings associated with the new format are projected at $255,000 annually. Additional Legislative Advocacy ($17, 000) Expenses associated with public image advertising and inaugural ball tickets have been excluded from the Cost of Service. Unsupported & Excessive Officer Expense ($85,000) Officers' expense vouchers were reviewed and all unsupported expenses were removed from the Cost of Service. Hotel charges in excess of $90 per day were determined to be excessive and the increment over $90 per day was removed from the Cost of Ser- vice. Lease and Rental Expenses ($51,000) The cost of HL &P's Greenspoint Employment office was reclassified from O &M to Lease Expenses and included in the Cost of Service. f. Fuel Refund Costs ($248,000) In July 1985, HL &P issued checks to its customers to refund an over - collection of fuel costs. All costs associated with the refund have been amor- tized over a two -year period as these costs are non - recurring in nature. am M h. i. Malakoff Expenses to CWIP 60710 -Ir ($16,000 Expenses incurred in connection with Docket 5755, before the PUC, Inquiry of the Public Utility into whether the Certificate of Convenience and Neces- sity granted Houston Lighting & Power Company for its Malakoff Generating Station should be Cancel- led, have been reclassified from Rate Case Expenses to Malakoff - related Construction Work in Progress. STP #2 Expense Reclassification ($1001000) Expenses related to the study of the economic via- bility of STP Unit 2 have been reclassified from Other O &M Expense to Rate Case Expense. Non - recurring Maintenance ($8, 550, 000) Major stator and rotor repairs, and blade replace- ments made during the test year at four generating stations have been reclassified to CWIP or amor- tized over a three year period, as appropriate. j. Affiliate Charges ($538,000) An adjustment was made to the amount of Houston Industries, Inc. ( "HII ") charges allocated to HL &P so that the Cost of Service includes 75% of HII charges. The remaining 25% is allocated to the other subsidiaries of HII. k. Employee Store Expenses ($181,000) All expenses incurred in the operation of a store which is used to sell electric appliances to HL &P -10- 60710 --1s employees have been removed from the Cost of Ser- vice. B. FUEL EXPENSE C. Q ($136,181,000) Fuel expenses have been projected by performing an econ- omic dispatch of HL &P's system and factoring into the analy- sis current fuel costs and contractual take -or -pay obliga- tions. Substantial fuel cost savings are projected due to the recent decline in natural gas prices and HL &P's renegoti- ations of fuel supply contracts. PURCHASED POWER EXPENSE ($40,961,000) Purchased power expenses have been computed by applying contractual rates for purchases from firm suppliers of cogen- erated capacity and from the City of Austin and City Public Service Board of San Antonio. Pursuant to HL &P's non -firm cogeneration tariff, non - firm cogeneration is purchased at the hourly marginal cost of energy to HL &P. These purchases have been factored into the Cost of Service analysis at the spot market price of natural gas. DEPRECIATION EXPENSE ($13,835,000) Depreciation Expense has been adjusted to reflect the useful lives and estimated salvage values of HL &P's property, plant and equipment as determined by the consulting firm of R.W. Beck and Company, which provided an analysis of HL &P's Depreciation Study for the City in this case. The adjust- ments are explained more fully in the testimony of Mr. Jack Pous of R. W. Beck and Company. _11- 60710 -1t E. TAXES OTHER THAN FEDERAL INCOME TAXES ($5,013,000) Social Security, Federal Unemployment and State Unem- ployment Taxes were calculated based on current tax rates and the recommended level of Salaries and Wage Expenses. Ad valorem taxes were calculated based on an effective rate applied to the recommended levels of Plant in Service and Plant Held for Future Use. No adjustments were made to the amount of State Fran- chise Tax or the PUC Gross Receipts Payment factor requested by HL &P. The amounts requested were determined to be reason- able. HL &P was audited by the State of Texas during the test year and as a result of the audit, HL &P paid the State $3.7 million in Use tax, interest and penalties for the period January 1, 1976, through June 30, 1983. The taxes paid during the test year which were related to prior years have been removed. Because HL &P does not recognize Use tax on a current basis, no provision has been made for Use tax in the Cost of Service. F. FEDERAL INCOME TAXES ($65,507,000) Federal Income Taxes have been computed by applying statutory tax rates to the recommended Revenue Requirement. Tax savings resulting from the consolidation of affiliates' returns have been deducted in the calculation of Federal Income Taxes as required by Section 41(c)(2) of the Public Utility Regulatory Act. G. RETURN ON INVESTMENT ($66,209,000) The Return that HL &P should be allowed to earn on its investment has been calculated by multiplying its Weighted -12- 60710 -1u Average Cost of Capital by the value of its Rate Base. The cost of debt and preferred stock used in the deter- mination of the Weighted Average Cost of Capital reflect actual costs associated with outstanding debt and preferred stock issues. The cost of equity capital was determined using the Dis- counted Cash Flow and the Risk Premium methodologies. These methodologies are used by financial analysts to determine in- vestors' current expectations of a particular stock issue. The analyses indicate that the cost of equity capital to HL &P's parent company, Houston Industries, Inc., is currently 14.75 %. Because the financial performance of HII is domi- nated by that of HL &P, no adjustment was made to HII's cost of equity to project that of HL &P. The utility's capital structure has been determined by taking into consideration recent bond refundings and a requi- sition of pollution control bond proceeds which had been held in trust. The calculation of the Weighted Average Cost of Capital, in the amount of 11.58 %, is shown on Schedule 7. The Weighted Capital Cost of Capital was multiplied by the value of HL &P's Rate Base to determine the amount of "return" to allow the Company. -13- 60710 -1v III. RATE BASE A. ELECTRIC PLANT IN SERVICE ($5,496,000) HL &P capitalized Employee Benefits and Use Tax asso- ciated with Limestone Unit 2 as if they related to Limestone Unit 1. These amounts have been reclassified from Plant in Service to Construction Work in Progress because Unit 2 is still under construction. B. CONSTRUCTION WORK IN PROGRESS $1,243,000 Adjustments were made to the balance of Construction Work in Progress (CWIP) to reflect: 1) the reclassification of Rate Case Expenses associated with the Malakoff decertifi- cation proceedings from Rate Case Expenses to CWIP; 2) the capitalization of major stator and rotor repairs made during the test year to Robinson Unit 4, Parish Unit 5, and the Greens Bayou generating stations; 3) the reclassification from Plant in Service to CWIP of certain sales tax and Em- ployee Benefits expenses associated with Limestone Unit 2 which HL &P had classified as related to Limestone Unit 1; and 4) the removal of the cost of a Direct Current Interconnect line in Ft. Bend County, which, because of a change in plans, the utility will not build. None of the costs associated with the construction of the South Texas Nuclear Project have been included in Rate Base. C. PROPERTY HELD FOR FUTURE USE ($518,000) Due to changes in long range planning of the Electric Reliability Council of Texas (ERCOT), the Crosby Street Sub- station, which was formerly under construction by HL &P, will not be completed. Because the utility has no definitive plans for the substation, it is not "used and useful" as re- -14- 60710 -1w quired by §39(a) of the PURA for inclusion in Rate Base. Expenditures related to the Crosby Street Substation, in the amount of $517,859, have therefore been removed from the Rate Base. A. NUCLEAR FUEL IN PROGRESS ($60,370) An adjustment was made to the balance of Nuclear Fuel in Progress (NFIP) to reverse the compounded effect of an error made by the Company in its calculation of Allowance for Funds used During Construction (AFUDC) in the month of February 1985. AFUDC is accrued monthly on the balance of CWIP and Nuclear Fuel in Progress that is not included in Rate Base. Conversely, "return" dollars are earned on CWIP and NFIP included in the Rate Base. The accrual of AFUDC is similar to the compounding of interest during construction (IDC) on any major project, with the primary difference between the accrual of AFUDC and IDC being that AFUDC is accrued not only on construction costs financed by debt proceeds, but also on construction costs financed by equity funds. E. FUEL OIL INVENTORY ($2,713,000) The adjustment to the balance of Fuel Oil Inventory has been derived by calculating each fuel oil- burning generating station's maximum annual fuel oil burn over the period 1981 through 1985 and adding an "unuseable" component for each plant to account for oil in tank bottoms and in the pipeline system. -15- 60710-ix F. WORKING CASH ALLOWANCE ($$2,702,000) The amount of Working Cash required in the day -to -day operations of the utility was determined by using a Lead /Lag Study. The Lead /Lag Study is used to evaluate the timing of all sources and uses of cash by the utility. An example of a "Lead" item in this analysis is the Franchise Fee paid to the City of Houston by HL &P for the use of City streets and public rights -of -way. In accordance with the terms of HL &P's Franchise ordinance, the Company collects Franchise Fees from ratepayers each month of a calendar year, and then remits the fees to the City on February 15th of the next year. In the Lead /Lag Study, Franchise Fee Revenues are assumed to be collected mid -way through the calendar year (approximately June 30), and remitted to the City 228.5 days later (on February 15), resulting in a 228.54 "Lead" on Fran- chise Fee Revenues. Conversely, were the City to perform a Lead /Lag Study of its own, the receipt of Franchise Fees from HL &P would be assigned a 228.5 day "Lag ". G. PREPAYMENTS ($308,000) Unlike Municipal Franchise Fees, State Franchise Taxes and the PUC Gross Receipts Assessment are prepaid in accor- dance with State law. Adjustments have been made to accu- rately reflect the average monthly balance of these prepaid taxes for each month of the test year. 4 The 228.5 day "Lead" is calculated as follows: (065 days + 2) + (31 days in January) + (15 days in February)]. -16- 60710 -1y H. DEFERRED LIMESTONE EXPENSES ($64,625,000) As previously stated, Limestone Unit 1 became opera- tional on December 1, 1985. HL &P has requested that costs incurred during the month of December 1985, and projected operation and maintenance expenses, depreciation, ad valorem taxes and AFUDC for the period January 1, 1986, to October 1, 1986, be included in the rate base. Were the City to honor HL &P's request, the utility would be granted selective ratemaking treatment. The utility would defer expenses which were not included in the determination of rates now in effect. This is not recommended, in parti- cular because HL &P reported earnings during the test period in excess of that authorized in its last rate case. For this reason, deferred costs associated with Limestone Unit 1 have not been included in Rate Base. I. UNRECOVERED STORM LOSSES ($8,880,000) In Docket No. 5779, HL &P was authorized to recover all costs associated with Hurricane Alicia in excess of the amount available in the property insurance reserve through amortization over a seven year period. Consistent with the PVC's Final Order in that Docket, the unamortized balance of costs associated with Hurricane Alicia are not included in the Rate Base. J. DEFERRED TAXES ($29,878,000) The accumulated balance of Deferred Taxes has been esta- blished to recognize the difference in the amount of taxes included in the Cost of Service and the amount actually paid the Federal government. In the early years of the life of an asset, "per book" taxes generally exceed taxes actually paid, -17- 60%10 -1z and the difference between the two is flowed through to rate- payers over the life of the asset. The balance of Deferred Taxes yet to be amortized is credited to the Rate Base to prevent ratepayers from paying a return on cost -free funds provided by the Federal government. K. OTHER COST -FREE CAPITAL ($5,280,000) Cost -free Capital has been increased to reflect un- claimed fuel refund checks and unpaid incentive and deferred compensation costs as of the end of the test year. These expenses were included in the determination of rates in pre- vious years but as of yet have not been paid by the util- ity. Accordingly, the funds represent Cost -free Capital and have been deducted from the Rate Base. m 60710 -laa IV. REVENUE REQUIREMENT Based upon a Rate Base of $4,764,986,000, a Rate of Return of 11.58 %, and the Cost of Service adjustments discussed in Sec- tion II above, the Revenue Requirement for HL &P has been deter- mined to be $3,087,698,000. When compared to fully adjusted test year revenues in the amount of $3,500,255,000, a revenue reduc- tion in the amount of $412,557,000, or 11.79% is recommended. (See Schedule 2.) V. COST ALLOCATIONS Cost Allocation is the process by which the total revenue requirement is allocated to the customer classes served by HL &P. Capacity charges have been allocated using the Probability Peak Methodology proposed by HL &P. The Probility Peak method weights each hour of the year by the probability of being unable to supply the demand on the system in any given hour. The Cost of Service for each of HL &P's customer classes was determined, and Relative Rates of Return were computed. Proposed revenues for each class were established such that each class would move toward a Relative Rate of Return of 1.00. A Relative Rate of Return of 1.00 indicates a class is providing revenues equal to the cost of serving the class. -19- 60710 -1bb VI. RATE DESIGN As recommended, the residential class as a whole will re- ceive a 8.6% reduction in rates. Under the recommended rate structure, the average cost per kilowatt -hour increases with con- sumption during the on -peak summer season, thereby encouraging conservation by providing a rate incentive to conserve. On the other hand, the rate recommended for winter heating consumption in excess of 1,000 kilowatt- -hours per month, is low, recognizing the base load usage characteristics of such consumption. The present and proposed residential rate structures follow: Present Monthly Rate Structure_ Summer: Customer Charge of $9.00 per month, which includes 250 kwh all kwh over 251 kwh at 5.292U per kwh plus: fuel charge of 2.53130 per kwh for all kwh plus: PCRF charge of 0.309U per kwh for all kwh Winter: Customer Charge of $9.00 per month, which includes 250 kwh 251 -1,000 kwh at 5.2923 per kwh over 1,000 kwh at 2.4297 per kwh plus: fuel charge of 2.5313 per kwh for all kwh plus: PCRF charge of 0.3093 per kwh for all kwh Houston Lighting & Power Company Proposed Rate Structure Summer: Customer Charge of $10.60 per month, which includes 250 kwh* all kwh over 251 kwh at 6.6780 per kwh plus: fuel charge of 2.5098 per kwh for all kwh Winter: Customer Charge of $10.60 per month, which includes 250 kwh* 251 -1,000 kwh at 6.6780 per kwh over 1,000 kwh at 3.4500G per kwh plus: fuel charge of 2.50984 per kwh for all kwh Revenue & Regulatory Affairs Division Recommended Rate Structure Summer: Customer Charge of $9.00 per month, which includes 250 kwh* all kwh over 251 kwh at 6.24604 per kwh plus: fuel charge of 2.08544 per kwh for all kwh Winter: Customer Charge of $9.00 per month, which includes 250 kwh* 251 -1,000 kwh at 6.24604 per kwh over 1,000 kwh at 2.96554 per kwh plus: fuel charge of 2.08544 per kwh for all kwh -20- 60710 -1cc Under the recommended rates, the typical residential custo- mer averaging 1,700 kwh usage in the summer months and 800 kwh usage in the winter months, would realize a monthly average re- duction in electric bills of $8.10. The rate structure for all classes, with the exception of the residential class which is discussed above, shall be the same structure as that proposed by HL &P in Volume VII of its Rate Filing Package. In accordance with Section S of the Rate Ordi- nance submitted for City Council's approval, HL &P shall design rates and submit the tariff for approval within ten days of approval of the Rate Ordinance. B- 6118 -47 -21- LINE N0. DESCRIPTION 1 OPERATION AND MAINTENANCE 2 FUEL 3 PURCHASED POWER 4 DEPRECIATION 5 OTHER TAXES 6 INTER ON CUSTOMER DEPOSITS 7 FEDERAL INCOME TAXES 8 RETURN 9 REVENUE REQUIREMENT 60710 -ldd CITY OF HOUSTON HOUSTON LIGHTING C POWER COMPANY REVENUE REQUIREMENT TEST YEAR ENDED DECEMBER 31, 1985 (OOO's) SCHEDULE 1 HLCP CITY CITY PER BOOKS ADJUSTMENT REQUEST ADJUSTMENT RATE ORDER $594,576 $11,114 $605,690 ($45,097) $560,593 1,420,262 (432,108) 988,154 (136,181) 851,973 442,802 96,454 539,256 (40,961) 498,295 177,099 33,488 210,587 (13,835) 196,752 140,185 16,507 156,692 (51013) 151,679 0 0 2,302 (0) 2,302 262,557 77,439 339,996 (65,507) 274,489 495,883 121,940 617,823 (66,209) 551,614 ----- - - - - -- $3,533,364 -------- -- ($75,166) ----- - - - - -- $3,460,500 ---- - - - - -- ($372,802) ----- - - - - -- $3,087,698 CITY OF HOUSTON HOUSTON LIGHTING C POWER COMPANY CALCULATION OF INCREASE TEST YEAR ENDED DECEMBER 31, 1985 (000's) LI NE NO. DESCRIPTION i REVENUE REQUIREMENT 2 LESS: FUEL REVENUES 3 MUNICIPAL STREET USE REVENUES 4 OTHER REVENUES 5 BASE RATE REVENUE REQUIREMENT 5 INCREASE IN BASE RATE REVENUES 60710 -lee HLEP CITY CITY REQUEST ADJUSTMENT RATE ORDER --- - - - - -- $3,460,500 ----- - - - - -- ($372,802) ----- - - - - -- $3,087,698 (11265,810) 177.158 (1,088,652) (80,117) 9,069 (71,048) (25,090) (1,141) (26,331) --- - - - - -- $2,089,483 ----- - - - - -- ($187,816) _- -- - - ---- $1,901,657 SCHEDULE 2 TEST YEAR AS ADJUSTED $3,500,255 (1,651,171) (84,587) (22,589) $1,741,908 $159,759 60710 -1ff SCHEDULE 3 CITY OF HOUSTON HOUSTON LIGHTING E POWER COMPANY OPERATIONS E MAINTENANCE EXPENSE ADJUSTMENTS TEST YEAR ENDED DECEMBER 31, 1985 (000'5) LINE HLEP CITY CITY NO. DESCRIPTION PER BOOKS ADJUSTMENT REQUEST ADJUSTMENT RATE ORDER 1 SALARIES C WAGES $226,920 $14,104 $241,024 ($4,618) $236,406 2 EMPLOYEE BENEFITS 29,511 (488) 29,023 (815) 28,207 3 LIMESTONE OPERATING EXPENSES 152 12,330 12,482 (1,889) 10,593 4 STORM DAMAGES 2,076 (702) 1,374 0 1,374 5 STORM DAMAGES -5779 238 996 1,234 0 1,234 6 MUNCIPAL STREET USE FEES 98,711 (19,967) 78,744 (7,696) 71,048 7 RATE CASE EXPENSES 498 757 1,255 (1,059) 196 8 EEI DUES 414 (83) 331 (331) 0 9 R E 0 11,721 11058 12,779 0 12,779 10 AMORT. OF OTHER DEF. CHARGES 204 0 204 0 204 11 MANAGEMENT AUDIT 0 978 978 (652) 326 12 LEASE AND RENTAL 5,408 278 5,686 (318) 5,368 13 UNCOLLECTIBLE ACCOUNTS 14,419 902 15,321 (947) 14,374 14 ADVERT., CONTR. & DON. 2,803 784 3,587 (13) 3,574 15 LEGISLATIVE ADVOCACY 9 (9) 0 0 0 16 SOCIAL DUES 25 (25) 0 0 0 17 POWER WHEELING 8,FR7 (61855) 1,822 (197) 1,625 18 AMORT. OF LIMESTONE DEF. CHRGS 0 7,056 7,056 (7,056) 0 19 OTHER O&M EXPENSES 192,790 0 192,790 0 192,790 20 REDUCTION IN GAS O&M EXP. (9,464) (9,464) 21 NEW BILLING PROCEDURES (255) (255) 22 ADD'L. LEGISLATIVE ADVOCACY (17) (17) 23 UNSUPPORTED 6 EXCESSIVE OFFICER EXP. (85) (85) 24 LEASE E RENTAL EXPENSES (51) (51) 25 FUEL REFUND COSTS (248) (248) 26 MALAKOFF EXP. TO CWIP (16) (16) 27 STP #2 EXP. RECLASS. TO RATE CASE EXP. (100) (IGO) 28 NON - RECURRING MAINTENANCE (8,550) (8,550) 29 AFFILATE CHARGES (538) (538) 30 EMPLOYEE STORE EXPENSES (181) (181) TOTAL EXPENSES $594,576 ....... $11,114 ....... $605,690 ------- ($45,097) ....... $560,593 ....... 60710 -1gg SCHEDULE 4 CITY OF HOUSTON HOUSTON LIGHTING E POWER COMPANY SUMMARY OF FUEL COSTS TEST YEAR ENDED DECEMBER 31, 1985 LINE HLEP CITY CITY NO. DESCRIPTION REQUEST ADJUSTMENT RATE ORDER FUEL EXPENSE 1 RECOVERABLE COSTS $875,322 (=121,279) $754,043 2 BASE RATE FUEL 112,832 (14,902) 97,930 3 TOTAL FUEL 988,154 (136,18I) 851,973 PURCHASED POWER 4 RECOVERABLE COSTS 390,488 (55,879) 334,609 5 BASE RATE PURCHASED POWER 148,768 14,918 163,686 6 TOTAL PURCHASED POWER 539,256 (40,961) 498,295 7 TOTAL FUEL AND PURCHASED POWER $1,527,410 ($177,142) $1,350,268 8 BASE RATE FUEL ia. i :i iii X261,600 anYti iii a. X16 .i. i... ii X261,616 9 FUEL REVENUE X1,265,810 rasa :ii.. ($I77,158} ......... siiiii..i X1,088,652 ......... 60710 -lhh SCHEDULE 5 CITY OF HOUSTON HOUSTON LIGHTING E POWER COMPANY INVESTED CAPITAL AND RETURN TEST YEAR ENDED DECEMBER 31, 1985 (000,S) LINE HLEP CITY CITY NO. DESCRIPTION REQUEST ADJUSTMENT RATE ORDER - - -- 1 ----------------- - - - - -- PLANT IM SERVICE --- - - - - -- $5,915,823 ----- - - - - -- ($5,496) ---- - - - - -- $5,910,327 2 ACCUMULATED DEPRECIATION 1,201,576 0 1,201,576 3 NET PLANT 4,714,247 (5,496) 4,708,751 4 CONSTRUCTION IN PROGRESS 676,830 1,243 678,073 5 PROPERTY HELD FOR FUTURE USE 3,613 (518) 3,095 6 NUCLEAR FUEL 118,181 (60,370) 57,811 7 FUEL OIL INVENTORY 17,478 (2,713) 14,765 8 WORKING CASH ALLOWANCE 44,454 (82,702) (38,248) 9 MATERIALS AND SUPPLIES 56,662 0 56,662 10 PREPAYMENTS 15,058 (308) 14,750 11 DEFERRED LIMESTONE CHARGES 64,625 (64,625) 0 12 UNRECOVERED STORM LOSSES 8,880 (81880) 0 13 DEFERRED TAXES (601,625) (29,878) (631,503) 14 PRE -I971 INVESTMENT TAX CREDIT (6,302) 0 (6,302) I5 CUSTOMERS DEPOSITS (32,538) 0 (32,538) 16 CUSTOMER ADVANCES FOR CONSTR. (15,891) 0 (15,891) 17 RESERVE FOR INJURIES (5,597) 0 (5,597) 18 OTHER COST FREE CAPITAL (33,562) (5,280) (38,842) 19 INVESTED CAPITAL $5,024,513 ($259,527) $4,764,986 20 RATE OF RETURN :�asama..ax 12.30% axxsx...... R.yar.. -0.72% :..x 11.58% 21 RETURN $617,823 —mm .... nwa ($66,209) ms=xxxaxa.. . $551,614 =......W.. 60710 —iii SCHEDULE 6 CITY OF HOUSTON HOUSTON LIGHTING 6 POWER COMPANY DOCKET 6765 SUMMARY OF CASH WORKING CAPITAL MULTIPLIER CASH WORKING RECOMMENDED LEAD) /LAG (LEAD) /LAG DAYS CAPITAL WORKING CAPITAL USES AMOUNT DAYS /365 DAYS REQUIREMENT -------------------- ----------------------------------------------------------- Revenue Requirement $3,087,698 36.25 0.0993 $306,655 WORKING CAPITAL SOURCES Fuel $851,973 (29.47) (0.0807) ($68,784) Purchased Power 498,295 (37.50) (0.1027) (51,195) Other O&M 560,593 (17.54) (0.0481) (26,946) Federal Income Taxes 160,139 (99.91) (0.2737) (43,834) Other Taxes 99,407 (180.54) (0.4946) (49,169) Interest 247,571 (86.13) (0.2360) (58,418) Preferred Dividends 29,391 (46.13) (0.1264) (3,715) ESTIMATED CAPITAL TO FINANCE THE NET LEAD IN RECOVER OF COST OF SERVICE 4,594 Cash Componant 1,636 Municipal Franchise Fees 71,048 (228.50) (0.6260) --------------- (44,478) CASH WORKING CAPITAL REQUIREMENT as :axsx........ ($38,248) ct- li Ln 11 Cr !i o Erf 11 D it Ln El) li 0 < LrI, ti it cr- Il 170 � CD 11 rr- T -0 a lE ct f4l ro ro a, cr, 170 .D rD !T ID M T ro 1! -r- W CR 11 w fl -r- it 0i L-9 it C. W E OD 0) -r- 6- 11 ro m, ro ii m 2 1 Lo Rl it Q to it 11 (+ ; 4' 41 it D) 0 L9 L.) 11 1 ro N H CD Lr, w L", LR ct- li Ln 11 Cr !i o Erf 11 D it Ln El) li 0 < LrI, ti it cr- Il 170 � ct- 60710—ljj ro III C+ Q rt 0C+ 0 rl :5 LO L13 90 'a rF rt fi t7' tzi m li Ln 11 Cr II Erf 11 D li 0 < LrI, it cr- Il 170 � CD 11 60710—ljj ro III C+ Q rt 0C+ 0 rl :5 LO L13 90 'a rF rt fi t7' tzi m .; w a D Q W x U L JI 3 Q H W m Cn . C- a ¢ H o r z a c J a� c H �-- z a CL W W M M rr H D U W H v 1 60710 -lkk o a o 0 In Sold -1 -100 0 d E °o 0 0 0 O 0 .1 w a a w U ul rLJJ V d LO 0 Q Q cc w LLJ w 4•. 60710 -1LL 4 A A A a ti co oft ti ti Cb 0 60710 -1mm THE STATE OF TEXAS § COUNTY OF HARRIS § BEFORE ME, the undersigned authority, on this day personally appeared Jane Wilton Cater, who, having been placed under oath by me, did depose as follows: "My name is Jane Wilton Cater. I am of legal age and a resident of the State of Texas. The foregoing Recommendation and Schedules, offered by me on behalf of the City of Houston, were prepared by me or under my direction and supervision, and are true and correct, and the opinions stated therein are, to the best of my knowledge and belief, accurate, true, and correct." /kAz w) - Jane Wilton Cater SUBSCRIBED nd SWORN TO BEFORE ME by the said Jane Wilton Cater, this % day of June, 1986. Notary Public in and for Harris County, Texas Anita Slavkoff My Commission expires 03/06/88