Appendix — FPC v. Florida Power & Light Co.

Supreme Court brief1972

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Text

\ " . o ast. eres: ORO ee Satay AR Te Mag tes Oo idly LOE

Gu the Supreme Cour of the United States

cromas TERM, 1970

No. 958

FepreraL Power CoMMISSION, PETITIONER

FLoripa Power & LigHT COMPANY, RESPONDENT

ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF

APPEAIS FOB THE FIFTH CIRCUIT 7

(1)

419-404—71——1

aod LAE a MLO BIOL LEI APIA Ris AS:

. TABLE .OF CONTENTS _

yy Page

"Relevant Docket Entries._..........-___--_-_- eeueue een eeeene Vv

Excerpts From Transcript of Proceadings.... - é4 eee en eee een 2

Witnesses: a

Ernest L. Bivans_-_._.....__.- eee eae eae eee ne teee ee 65

155

Dan McCarthy-.-.....---.---.------- eee eee 124 : =

Ot Was FOGUR ioc ce ndees ogee rosa Le im pewee ese eee oe 59

“oe . 98

- Cleve R. Jacobsen_-..-.-..---------------------------- 2

52

92

119

Joseph J, A. JOG ben ndedwterewenencensceceeteneseocens 25

‘. . 130

. , 163

A secon cckawweasecaeeeaaseencanawenrcececasaeatence anes 177

Erhibit

No. Description

1 : Map entitled ‘Territory Served by Florida One & Light

Company” .......2...-.-.-. 2-25 n ese cee bi cec eee lee 177

3 Florida Operating Committee Minutes_2_.__.____._-.____- 178

Electric Energy Transfers Between Florida Power & Light

. Company and Other Electric Utility nems in Florida

During Calendar Year 1964..__._.____._-_._-__.--____- 185

8B ’ Map entitled “State of Florida Electric System Map of

a Major Transmission Lines’”’____.__...-.--------------- 186

12 Map entitled ‘Major Interconnected Power Systems—

North American Power Systems Interconnection Com- _

mittee—(NAPSIC)”____.__-_____,_-____-------------- 187

13 Diagram entitled ‘Interconnected Systems Group—

Schematic Diagram of Interconnections Between Systems ,

Including Regional Boundaries’, dated April 27, 1961__ 188

15 Diagram entitled ‘‘The Interconnections Within the Florida

. Pool and- Also Between the Southern Company and

-Florida Power Corporation and the Energy Transfers

Over These Interconnections’__...._...2.-..1-__------- 189

. _ (1) "oy

Exhibit

No.

19

32

33

40

49

50

51

PE LORS COB LIT tI SHAY ie EEE,

a

mM ‘

, na "+ Description

Diagram entitled “Route of Interstate Electric Power Flow

in 1964 frorn.Georgia Power Company to Florida Power &

Light Company System Over the Florida Power Corpora--

tion Transmission Lines” and 6-page Tabulation entitled

“Hourly Interstate Power Flow on Selected Days in 1964

From Georgia Power Company to Flotida Power &

* Light Company * * *”_____-. eee

Exhibit entitled ‘Hourly Interstate Power Flow on Selected

Days in 1964 from Georgia Power Company to Florida

Power & Light Company over Florida Power Corporation

Transmission Lines Shown on Load Diagram on Page | of

Staff Exhibit Bae 18” consisting of 5 pages of tabulated

' power flow data..0..__-------------------------------

Copies of Florida Power & Light Company’s “System Dis-

patchers Interchange Log” for Certain Days in 1964_____-

Diagram entitled ‘‘Route of Electric Power Flow in 1964

from Florida Power & Liglt Company to Georgia Power

Company System Over the Florida Power Corporation

Transmission Liges’” and Accompanying *Tabulated

Copies of Turner Plant-Daily Operation Report, Jaspér Sub-

station-Daily Operating Report, Silver Springs Substation-

Daily Operating Report, and Fort White Substation-Daily

' Operating Report (Florida Power Corporation) for

July 8, August 12 and August 17, 1964_____--_.---.----

Estimated Initial Cost of Making Minute Projiérty onlin:

tions and Setting Up New Accounting Techniques Under _

Federal, Power Commission Jurisdiction____...---------

Estimated Annual Cost of Maintaining Accounting Records

Under FPC Regulation. __..__..-_-_.----_-_---------

Substation and Transmission System “Map of Florida Power

& Light Company, dated April 21,.1965______-__-_-___-

Florida Power & Light Company, Comparison of Generating

Capability and Peak Loads, 1960- 1969 bee eee

Single Conductor Diagram___-----.--------- -----------

Florida Power Corporation System One-Line Switching

Diagram, Flow Diagram, Rurnee Plant, Re Staff Exhibit

Letter, dated August 10, 1965, from Mr. C. J. Baldwin,

Westinghouse Electric Corporation to Mr. Harty V.

Street, Florida Power & Ligth Comp4ny, attaching two-

page. document entitled, ‘Digital Load Flow Customers,

NOG oe en eee anaes aneee

Letter, dated August 16, 1965, from J. C. Hartley of

General Electric Company to Mr. H. V. Street,. Florida

Power & Light Company________________-------------

Florida Power Corporation System One-Line Switching

DIAM RING. 22. 66 ee ee wo eee ee eee yen manee

Single Conductor Diagram_-.-_---..---------- Ve eeeeee -

Page

191

203

211

213

252

mn

Exhibit °

- No. - Description

58 Document entitled “‘Curves Showing Instantaneous Voltage,

Current and Power for Single Phase Operation at Lagging: Page

Power Factor Through Two CP oo eee sae 240 °

.59 . Document entitled ‘Single Phase Power Curves’”’_,_______- 241

- 60 Document entitled, “Curves Showing Instantaneous Power

for Three-Phase\ Operation at Lagging Power Factor

Through Two Cycles” opie e eee ewer ue ace 242

61 Document entitled Comparison of 100 Percent and 80 Per-

cent Power Factor Power Characteristics’’._..._________- 243

* 69 Document containing an electrical diagram___________. -_.. 244

70 Diagram entitled “Comparison of Varidtions of Single and

Balanced Three-Phase Power________..-____-__-___2_- 245

Items by :

reference

C Florida Power Corporation, FPC Form No. 1, Annual Re- ‘

port, for the Year 1964, p. 424_____________________»_- 246

D Florida Power Corporation, FPC Farm 12, Power System

; Statement, for the Year 1964, pp. 21, 26, 27________- femee 247

J Southern Services, Inc., Rate Schedule FPC No. 27, ade

. ment 1, p. 1.__-------,2-----------1------ ene eee 250

Pleadings...........____. poh eee eae ewe noes conn cae ee neue 251

Ordering Initiating Investigation and Hearing.-___:-___._--_______- 251

Presiding Examiner’s Initial Decision fe tdeeweesene ee eodeeeeeenees 254

Opinion No. 517________--_-_-_------------------ eee leseoe ee * 283

Application for Rehearing- ices sates eeee eee useweseeeeeweues 307

Order Denying Application for Rehearing. -_____-___-_____-____-_- 327

Order Providing for Extension of Time____._-_-_- Seance secasceueet 329

- Supplemental Testimony and Exhibits:

(a) Rebuttal Testimony of Cleve R. Jacobsen_____--_-_-_-_--_- 331

(b) Testimony of Ernest L. Bivans______.-_-_---_--_----_-__ 332

(c) Cross Examination of Cleve R. Jacobsen_-_-_-_- suey nreTe 337

(d) Cross Examinatior of Joseph J. A. Jessel__.._________2___- 346

(e) Exhibit 8A—Florida Power & Light. Company, Wednesday,

February 17, 1965, System Frequency_-__---_-_-----_--- 347

(f) Exhibit 9—Florida Power & Light Company, Overhaul Sched-

ules—1964____.______- nee ee neenene ed eeeeweneeeues 348

(g) Exhibit 29—Definition of Terms—Electric Power Systems-. 349

Th) Pax EY oe Da ats wee eneeees * 353

Opinion and Judgment of the Court Below:

(a) Opinion of Court of Appeals__..___.-----.-------2-_--.-- 354

(b) Judgment of Court of Appeals________.___-_---_---.-_-_- 375

Order Granting Certiorari.-......_.....----_--_---------------- 376

CLOSER Le LET AE LES 8 Sa NEEDS (er ODE Bim BR PE REL AEE OLS ae Cte ALE PD

Jn the Supreme Court of the Gnited States

; Ocronsn Term, 1970

No, 958.

FEDERAL PowEeR COMMISSION, PETITIONER

° Vv. I

Fioripa .Power & LIGHT COMPANY, RESPONDENT

ON WRIT OF CERTIORARI TO THE UNITED STATES COURT

OF APPEALS FOR THE FIFTH CIRCUIT

RELEVANT DOCKET ENTRIES—FEDERAL POWER COMMISSION

1965 co

February 26____-_-------- Commission Order Initiating Investigation

and Hearing.

March 19. poe eeeeeoeee==ee Florida Public Utilities Gouiniseion’s Notice

of Intervention.

April 5 ---------------- -- Designation of Presiding Examiner.

ML ey, a eae meee Service of Commission Staff Testimony and

’ Exhibits.

July 2... -.._---------- Florida Power & Light’s Motion to Strike Pre-

; pared Direct Testimony and Exhibits.

July 9...-...-- eee Commission Staff Reply to Motion to Strike

Prepared Direct Testimony and Exhibits.

daly 21... 27 ces ecee Presiding Examiner’s Ruling on Florida Power -

& Light’s Motion to Strike.

August 24-_____---------- Service of Florida Power & Light’ s Testim ny

| and Exhibits. }

August 31__:------------- Commission Staff Motion to Strike Prepared

Direct Testimony and Exhibits.

September 7_____- oaaeeee Florida Power & Light’s Answer to Motion

‘to Strike Prepared minece Tesimony and

Exhibits.

September 7__-.--~__-_--- City of Clewiston, Florida Petition to Inter-

> vene.

September 18___------_--- Florida Power & Light’s Motion to Strike Re-

buttal Testimony and Exhibits.

(Vv)

VI

September. 10.__-_--_---~ Commission Staff Reply to Motion to Strike

Prepared Rebuttal’ Testimony and Exhibits.

September 17_.--------:-- Florida Power & Light's “Answer to Petition

to Intervene of City of Clewiston, Florida.

September 29___---------- Commission Order Authorizing Intervention

of the City of Clewiston, Florida an a Limited

Basis and Out of Time. . .

the tober +5

October 7-8

October 12

November 3

Hearitigs Before Presiding Examiner.

1966

July 12..-........------- Presiding Examiner’s Initial Decision and

Certification of the Record Accompanying

the Initial Decision.

August 5______----------- Commission Notice of Extension of Time for

Filing Exceptions.

August 25_--------------- Florida Power & Light’s Brief on Exceptions.

August 25_------ <n Florida Public Service Commission Adoption

. of Brief on Exceptions of Florida Power &

Light.

September 14__--------=-- Commission Staff Brief Opposing Exceptions.

September 14____--------- Florida Power & Light’s Motion for Oral

Argument.

OGtODED Bic oes Commitsaion Notice, Fixing Oral Argument.

November 28__---- a Oral Argument.

1967 .

MOPCN 202g e eke Commission Opinion No. 517, Opinion and

Order Detérmining Jurisdiction.

April 4 ----------------- Florida Power & Light’s Motion for Stay.

April 11_2--- een - Florida Power & Light’s Application for

Rehearing.

May 2.2.2 220-32 neck Commission Order Denying Application for

> Rehearing.

May 2..._--------------- Commission Order Providing for Extension of

Time.

COURT OF APPEALS ,

June 29-2 Florida Power & Light’s Petition for Review.

October 6___---_--------- Florida Public Service Commission’s Motion

for Leave to Intervene.

October 138_._._-_----_-_-. Commission Response to Motion of Florida

; Public Service Commission. -

October 26. ----------- - Court Order Granting Intervention of Florida

Public Service Commission.

val

November 24-_..-....____ City of Gainesville and Gainesville Utilities

‘ Department Petition to File Brief Amicus:

and Brief Amicus.

November 28 ____________ Commission Acquiescence in Petition of City

of Gainesville and Gainesville Utilities

‘Department.

December 11... _________ Florida Power & Light's Opposition to Petition

of City of Gainesville and Gainesville Utili-

* ss ties Department. — ;

December 21 ~~ _ - -Court Order Granting City of Gainesville and.

Gainesville Utilities Department to File

Brief Amicus Curiae and Denying Leaye to ‘

Present Oral Argument. |

May 7 __ ~~ ~~ ~_ Oral Argument before Fifth Circuit.

July 13. ------ Opinion and Judgment of Fifth Circuit.

.

oe et

IN THE

United States Court of Appeals

For THE Firrx Crrcuir

Docket No. 24,956

FLoripa Power & Licut Company, Petitioner,

v.

F’gpERAL Powrr Commission, Respondent

oe

4s TK

On Petition To Review: and Set Aside Opinion and Orders of

the Federal Power Commission

JOINT RECORD —

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40

_ Testimony of Cleve R. Jacobsen

Q. Would you state your name and address? A. My

name is Cleve R. Jaeobsen. I reside at 4800 Springbrook

Drive, Annandale, Virginia.

Q. By ‘whom are you employed and in-what capacity?

A. I am employed by the Federal Power Commission

(FPC) as an Electrical Engineer in the Bureau of Power.

~ Q. What position do you oceupy in the Bureau of Power?

A. Iam a Staff Electrical Engineer in the Interconnection

and Coordination Section of the Division of Electric Re-

sources and Requirements.

Q. What are your duties in your present positjen? A.

‘My duties are to review and evaluate technical reports and

conduct studies and research to determine the economic

-and technical adv antages of intereonnection and coordina-

tion of electric system operations for the purpose of en-

couraging voluntary interconnections among various cleec-

tric systems to realize maximum economy, increased effi-

cieney, and proper utilization and conservation of natural

resources.

I assisted the FPC Staff counsel in the preparation of the

stipulation of facts which was received in evidence in the

matter of the Arkansas Power & Light Company, FPC

Docket No. E- 7090, and I was ‘available to’ testify for the

Staff in that proceeding if the need arose.

41

I prepared written testimony in the matter of Alabamu

Electric Cooperative, Inc. y. Alabama Power Company,

FPC Docket No. E-7183, and am scheduled to appear as a

witness before a FPC Hearne Examiner in this proceeding

during the summer.

I also act as a consultant and I give expert advice on

electric transmission and coordination matters to the FPC

2

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and its Staff and to other Governmental bodies and defense

agencies.

In addition, I prepare and am responsible for power flow

studies for existing and proposed electric networks for use

in performance evaluation of such networks.

As a principal FPC Staff expert on electric transmission |

and coordination matters and electric system operations, I

am available to testify at FPC hearings and to render tech-

nical assistance to Staff Attorneys in connection with such

hearings.

Q. In connection with your duties_at the FPC have you

ever visited and examined the facilities of any electrie utili-

ties? ‘ A. Yes.

_ Q. Which electric facilities have vou visited and exam-

ined? A. The electric facilities which I haye visited and

examined include the following: ae

Virginia Electric Power Company—A 500 kv substation and

transmission line in the vicinity of Harrisonburg, Vir-

ginia and the automatic dispatch center in Richmond,

Virginia.

Pennsylvania-New Jersey- Maryland Interconnection — The

automatic dispatch center located on premises of Phila-

delphia | Hilectric Company in Philadelphia, Pennsv1-

vania.

42

Philadelphia Electric Company—The automatic aispatch

center in Philadelphia, Pennsylvania.

General Public Utilities Corporation—The automatic dis-

patch center in Reading, Pennsylvania.

Metropolitan Edison Company—The dispatch center in

Reading, Pennsylvania.

(42)

Middle South Utilities, Ine-—The automatic dispatch center

in Pine Bluff, Arkansas.

Louisiana Power & Light Company—The Sterlington gen-

erating plant and associated substation and transmis-

sion lines. a

Arkansas Power & Light Company—The Couch generating

plant and the Cecil Lynch generating plant and their

associated substations and transmission, lines. The

Woodward , substation and associated -transmission

lines. 7. .

Florida Power & Light Company—The. Port Kverglades

generating plant and the Lauderdale generating plant

and their associated substations and transmission lines.

The eutomatic dispatch center in Miami.

Potomae Electric Power Company—The Chalk Point gen-

erating plant and associated substation and transmis-

sion lines.

The Southern Company System—The automatic dispatch

center in Birmingham, Alabama.

Alabama Power Company—The Gorgas No. 2 and Gorgas

No. 3 steam generating plants. The Lewis Smith hydro

plant. The transmission lines in the vicinity of Kver-

green and Clio substations. The Phenix City 110°kv

substation and its associated 110 kv transmission tie

line to Georgia Power Company. The system. dispatch

‘\ .

center at Magella substation.

a

Q. Did you participate in the National Power Survey

conducted by the Federal Power Commission during the

years 1962, 1963, and 1964? ‘

43

A. Yes.

Q. What was the nature of your participation in the Na-

tional Power Survey? <A. I contributed to the National

4 . :

rr re (44)

Power Survey by performing technical engineering work in

accumultiag and analyzing, as well as preparing, studies

and reports embracing both electric transmission and co-

ordination and electric distribution. This work included sys-

tem planning for new high voltage, large capacity transmis-

sion lines and determination of the costs related to these |

facilities. The work also included studies of the economic

and technical advantages of interconnecting electric facili-

ties and alternative plans for such-interconnections. I helped

to maintain liaison with the various teehnical advisory com-

mittees composed of representatives of the public and pri-

vate segments of the electric power industry who assisted

the Commission in making the survey. Certain technical

segments of the Commission’s report on the survey were

drafted by me. The National Power Survey Report was is-

sued by the FPC in December 1964.

~Q. How long have you been employed in vour present

position? A. Since November o, 1962.

_ Q. Please give a brief outline of Your engineering train-

ing and experience prior to entering your present position.

A. I was employed for about two years (1939-1940) as an

assistant desig engineer and substation operator with the

Memphis Light, Gas and Water Diviston, an agency of the

City of Memphis, Tennessee. As assistant design engineer,

my duties consisted of the preparation of contract plans

for the construction of electriéa] underground distribution

system in the City of Memphis.

44

I was an officer in the Corps of Engineers, U.S. Army, for

six, years (1940-1946). Some of my principal engineering

assignments included assisting in the Alean Jfighway con-

struction project; serving as Post Engineer of the Port and

Post of Skagway,eAiaska, where I was responsible for the

supervision, One Wen and maintenance of a combined

| ‘e te ,

4)

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Army and Skagway municipal electrie utility system; and

. assisting in miscellaneous construction projects in the Kuro-

pean and Pacific Theatres of Operations. | ,

I was employed for about 16 years (1946-1962) with Com-.

monwealth Associates, Ine. (formerly Commonwealth &

Southern Corp. a New York Corporation) in Jackson, Michi-

gan. Commonwealth Associates, Ine. is a long established

organization of consulting and. design engineers, whose

major background is in the field of generation, transmission

and distribution of electric power for electrie utilities. The

clients of Commonwealth Associates, Ine. included many

electricsutilities operating in the mid western section of the

United States.

My sixteen years of diversified consulting and design ex-

perience with Commonwealth Associates, Ine. inelnded thir-

teen years as a registered engineer in progressive engineer-

ing work, and over ten vears involved responsible charge

of advance work as job engineer with supervision of the’

work of other professional engineers. [ planned; directed,

and supervised the work of a section requiring a general

background of electric utility operations, including bulk

power supply, distribution systems, and overhead line de-

sign. The work included both the desian of electric facilities

and studies of electric systems.

45

Q. Have you ever attended any engineering school? A.

Yes. I atended the University of Tennessee at Knoxville

from 1932 to 1936.

Q. Did you receive a degree from the Tate ersity of Ten-

nessee?. A. Yes. I received the Degree of Bachelor of

Science in Electrical Engineering.

Q. Do you belong to any engineering societies? A. I do.

Q. Would you state what engineering societies vou belong

to and what grade of membership vou hold? A. I am a

6

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Senior Member of the Institute of Electrical and Kleetronic

Engineers, formerly known as the American Imstitufe of

Electrical Engineers; a member of the Washington Society

of Engineers; a member of the District of Columbia Qgciety

of Professional Kingineers; a member of the National So-

ciety of Professional Iingineers; and past member of tha

Edison Electric Institute — American Gas Association -

Transportation Committee. -_

Q. Have you ever participated on any Institute of Elee-

trical and Eléctronie Enginecrs (Iki) Committees? A.

Yes. From 1953 to 1962.1 served on the following Commit-

tees in the Michigan Section of TREE (formerly AIEE ):

Chairman, Public Relations’ Committee, Chairman, Program

Committee, Chairman, Student Guidance Committee, and a

member of the Section Meetings Group. From 1959 to 1964,

I served on the National IRE Substations Committee,

Transmission Substation Subcommittee, Working G roup on

Project 59.1—“Recommended Minimum Clearance in Sub-

stations”, and I was Chairman of Working Group on Project

03.1—*‘ Extra-High Voltage Substations.” .

46

Q. Are you a registered professional engineer? <A. Iam.

Q. Where are you registered? A. Iam registered in the

_ States of Michigan (by examination) ; Ohio, and Pennsyl-

vania..

Q. Have vou visited the offices and properties of Florida

Power & Light Company (FPL) in preparation for your

participation in this proceeding?, A. I have.

Q. When did you make your visit? A. In March 1965. °

Q. Before your visit to Florida Power & Light Company,

did you make any preparations for this field trip? A. Yes:

I made an office study of the generating and transmission

parts of the electric system of the Florida Power & Light

Company and its affiliates of the Florida Operating Com-

mittee.

—

(46) | . . ,

Q. What do you mean by the term “electric system?” A.

By the term “electric system” I mean the physically con-

nected generation, transmission, distribution, and other fa-

cilities operated as an integral unit under one control, man-

agement, or operating supervision.

Q. What are the affiliates of Florida Power & Light Com-

pany to which you refer? A. Florida Power & Light Com-

*pany (FPL) is one of five electric systems that comprise

The Florida Operating Committee (Florida Pool). The -

47

other operating companies in the Florida Pool inelude

Florida Power Corporation (F.P. Corp.) and Tampa Elec-

trie Company (THC). Orlando Utilities Commission (Or- °

Jando) and the City of Jacksonville (Jacksonville) have

heen invited to attend ineetings for the last year or so and

. are considered as assoicate members of the Committee.

Q. Would vou state what information you used in your

office study? A. The information that I used in that study

is that reported by FPL and its affiliated companies in the

Florida Pool, to the Federal Power Commission on forms

prescribed by the Commission. | :

Q. Would you please identify the reports filed with FPC

which have information on IPL that you used in your office

study? A.- The reports which I used include the following:

~FPC Form No. 1, Annual Report, filed by FPL forgthe vear

1963; FPC Form No. 12, Power System Statement, filed by

FPL for the year 1963; FPC Form No. 1; Annual Report,

filed by F.P. Corp. for the year 1963; FPC Form No. 12,

Power System Statement, filed by F.P. Corp. for the year

1963; FPC Form No. 1, ‘Annual Report, filed by TEC for

the year 1963; FPC Form No. 12, Power System Statement,

filed by TEC for the vear 1963; FPC Form No. 12, Power

System Statement, filed: by Orlando for the year 1963; and

8

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IPC Form No. 12, Power System Statement, filed by Jack-

sonville for the year 1963.

* * * . * * * * *e# ° #* * * *

50

—Q. Referring to Staff Exhibit No. 1 for identification, |

what territory does FPL supply electrie service? A. FPL

supplies electric service in most of the territory along the.

greater part of the east coast of Florida (except the Jack-

sonville area and five other municipalities which have

municipal systems), including the Cape Kennedy area, the

- agricultural area around southern and eastern Lake Okee-

chobee,.the lower, west coast area, and portions of-central

and north central Florida.

51

It supplies electric service to abont 931,400 customers

located in over 500 cities; rural communities and adjacent .

areas, including the cities of Miami, Miami Beach, Coral

| Gables, Hialeah, Hollywood, Fort Lauderdale, Palm Beach,

West Palm Beach, Daytona Beach, Ormond Beach, Mel-

bourne, Cocoa, Titusville and St. Augustine on the east

coast; Fort Myers, Punta Gorda, Sarasota and Bradenton

in the western part; and Okeechobee, Pahokee, Belle Glade,

Palatka, Lake City and Live Oak in central and northern

parts of the State. .

Generally the peak demand occurs in the period December

to March.

Q. Will you briefly describe FPL and its operations?

_ A. FPLis a corporation engaged in the generation, trans-

mission, distribution, and-sale, at wholesale and retail, of

electric energy. FPL also interchanges electric energy with -

certain other Florida utilities. It is organized nnder the laws

of the State of Florida and maintains its principal business.

9

Bec BPD Ae ES AE POTN POD NDE EIR OEE AR AERC SS

Y

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office at 4200 W. Flagler Street, Miami, Florida. The Sys-

tem’s Load Dispatching Office and General Engineering

Office is located in the Rvan Building, 400 S. W. 2nd Avenue,

Miami, Florida.

FPL owns and operates an electric generating and trans-

mission system in the State of Florida, which is intereon-

nected with electric generating and transmission systems

owned and operated by F.P. Corp., TEC, Jacksonville and

Orlando. |

52

IPL has four dispatching divisions. The name and loca-

tion of division headquarters .are as follows:

(a) The Western Division—Punta Gorda

(b) The Eastern Division—Palm Beach ~

(ec) The Southern Division—Miami

(d) The Northern Division—Sanford

‘FPL delivered firm electrie energy during the year ended

December 31, 1964, to 6 rural cooperatives, namely: Florida

Keys Electric Cooperative, Glades Electric Cooperative, Lee

County Cooperative, Clay Electric Cooperative, Peace River

Electric Membership Cooperative and Okefenokee Electric

Membership Cooperative. FPL also delivered emergency

-power for 3 and 4 months to the municipal system of the

City of New Smyrna Beach and for-one day to the municipal

system of the City of Homestead.

As of December 31, 1964, FPL owned and operated 10

steam-electric generating plants having 22 units with a total

combined manufacturer’s maximum generator nameplate

rating of 2,823,390 kw. FPL had under lease one internal’

combustion electric generating plant with a manufacturer’s

maximum generator nameplate rating of 700 kw. It owned

10 mobile internal combustion electric generating units with

a combined manufacturer’s maximum generator nameplate

10

A Ser eine 7 PRR nin

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‘ rating of 2,560 kw. The eombined 1964 FPL manufacturer’s

maximum generator nameplate rating was 2,826,650 kw,

which is based on

53 .

capabilities under cold weather conditions and applies only

to favorable conditions during the months of December,

January, Febrnary and March. During the remaining

monthswarying limitafions are imposed upon FPL generat-

ing equipment due to higher circulating water temperatures.

* * ‘* * * * * * * * * *

56

Q. Mr. Jacobsen. Is there anything further concerning

’ FPL or its.operations that vou would like to discuss? A.

Yes. On December 31, 1964, FPL had about 2,606 miles: of

transmission lines (pole line miles) at 69 kv or ahove, of

which about 447 miles were operating at 240 kv, about 565

miles were operating at 138 kv, about 393 miles were oper-

ating at 115 kv, and about 1,202 miles were operating at

69 kv.

2 * * e e es * s e J e 2

61

Q. Mr. Jacobsen. Does PI have an economy dispatch

computer in its System Dispatching Office? A. Yes.

Q. Please briefly describe the computer’s operation. A.

FPL has an Economy Dispatch Computer in its System Dis-

patching Office that started operation in 1959.

This computer assigns each load change on the System

as shown on the daily load eurve, Staff Exhibit No. 8, to a

combination of generating units such that the FPL Systein

will operate most economically. FPL’s computer control svs-

tem provides control of 10 steam-electric generating plants

with 21 units and the net flow of 6 tie-lines including 2 tie-

lines connected to Jacksonville, one tie-line connected to

11

sn EE comm

.

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Orlando, 2 tie-lines connected to F.P. Corp. and one tie-line:

connected to TEC.

The computer assigns each generating wnit a definite

megawatt output when it senses a load change. If for any

reason the generating unit eannot accommodate its assign-

ment, then generation changes are reallocated. The com-

puter considers cost of fuel at the various plants, generat-

ing unit efficiencies and transmission line losses. when as-

signing unit output.

62

The System Dispatchers can switch units in or ont of the

computer as desired. The computer works with the units

that are switehed into if. The Dispatchers’ concerns are to

keep generation and load in balanee. Units are brought on

the line as additional’ regulating range is required. The

computer automatically allocates the generation changes

among the units ona pe over-all cost basis.

FPL’s load is in a ®onstant state of change; therefore,

the computer must be provided information of these changes

constantly as they oecur. Such information is referred to as

computer input. Important input are the actual telemetered

generation of FPL units and tie-line power flow data with

neighboring systems. This telemetered data can be observed

on recorders mounted on the load control telemeter panels

in the System Dispatching Office. Other*inputs that the dis-

patcher feeds into the computer by digital setters are the

high and low limits of the generating units, and the type

and cost of fuel being used. The computer also takes into

consideration the input data for the generating unit. effi-

ciencies and System transmission line losses.

* * * * = * * * * * * *

69

Q. Mr. Jacobsen. Does FPL belong to a voluntary or-

ganization named Interconnected Systems Group (ISG)?

12

5

a

= AS PA TEE RESET ANI

(72)

A. Yes. FPL belongs to a voluntary organization named

Interconnected Systems Group (ISG) which is composed

of electric utilities operating in that section of the United

States whieh is bounded generally on the north by Canada

and Lake Superior, on the south by the Gulf of Mexico and

the Atlantic Ocean, and on the west by the eastern portions

of the States of Montana and Wyoming and tlte western

-boundaries of the States of Nebraska, Kansas; and Okla-

homa, and on the east by Lake Michigan and the western

‘ boundaries of the States of Pennsylvania and Maryland.

There are four regional units or division in. ISG, one unit

for the Northwest Region, the Southwest Region, the South-

east Region, and the Northeast Region, respectively.

FPL and the other operating companies of the Florida

Pool belong to the Southeast Region of ISG. ISG is one of

the major interconnections in North America. Its regions

are represented on the North American Power Systems

Interconnection Committee (NAPSIC), whieh is also a vol-

untary organization. NAPSTC was formed in 1963 of elee-

tric utility operating personnel representing major electric

utility operating areas or power pools in North America.

2 * * * * * * * * * * *

71

Q). Have vou anything further to say concerning ISG?

72

A. Yes, CANUSE, PJM and ISG representing about 140

electrit utilities, of which FPL is one, operate continuously

in parallel. Most of these systems operate on a form of au-

tomatie control called Tie-Line Bias which allows gam} sys-

tem to assist In maintaining the standard 60-c¥cle fre-

queney,

* * * * * * * * * * * *

13

(74)

“74

Q. Is there anything which you wish to add pertaining to

the system operation and service territory of FPL’s other

operating affiliates in the Florida Pool? A. Yes. F. P.

Corp. is engaged, within the State of Florida, in the genera-

tion, transmission, distribution and sale of electricity. It

renders electric service to about 325,000 electric customers

in its territory of about 20,600 square miles with a popula-

tion of about 1,800,000. Its generating stations have a manu-

facturer’s maximum generator nameplate rating of 1,169,113

kw and are interconnected by a network of 240: kv, 120 kv

and 69 kv transmission lines. The F. P. Corp. transmission

system is interconnected with transmission lines of Georgia

Power Company, Gulf Power Company, and three of the

Florida Pool electric utilities; FPL, TEC, and. Orlando.

These

75

points of interconnections are delineated on Staff Exhibit

No. 88. There are transfers of interstate energy across the

Florida-Georgia State boundary pursuant to Southern Serv-

ices, Inc., Rate Schedule, FPC No. 27, Item J by reference. .

The kwh interstate energy transfers for the vear ending

December 31, 1964, on the tie-lines shown on Staff Exhibit

No. 88 into the State of Florida (F.P. Corp.) from the State

of Georgia (Georgia Power Co.) totaled 99,720,000 kwh and’

the kwh energy transfer out of the State of Florida into

the State of Georgia totaled 82,182,000. >?

79

Q. Mr. Jacobsen. Have vou made a study and analysis of

the magnitude and direction of-power flow over anv of the

transmission line interconnections between Georgia Power

14

(85)

Company and F. P. Corp. shown on Staff Exhibit No. 15?

A. Yes. I have.

Q. For what period of time did you make your study

and analysis? \A. Primarily for the year ending December

31, 1964, and a few specific days in 1965.

Q. Mr. Jacobsen. In your opinion, during the period of

your study did interstate electrie power flow over the inter-

connections from Georgia Power Company, located in the

State of Georgia, to the F. P. Corp. System, located in the

State of Florida? A. Yes. —

Q. What information did you study to reach this conelu-

sion? A.«FPC Form No. 12, Power System Statement,

filed by F. P. Corp. for the vear 1964 and F. P. Corp. Daily

Operating Reports, Staff Exhibits No. Cl and C2, and also

the way the Florida Pool, F. P. Corp. and FPL operate.

~ Q. Mr. Jacobsen. Does Southern Services, Inc. act-as an

agent for Georgia Power Cor pany, Alabama Power Com-

pany, Mississippi Power Company and Gulf Power Com-

pany in the execution of Southern Services, Inc., Rate:

Schedule, FPC No. 27? A. Yes.

* * * , * * * * * * * * *

85

Q. Mr. Jacobsen. Have you made a study of load eondi-

tions and power flow in Florida Pool Systems to determine

if commingled power flows into the FPL System over any

of the aforementioned interconnections? A. Yes. T made

a detailed study and analysis of power flow on 22 days in

1964 over the 115 ky F. P. Corp. Turner Plant-FPL Sanford

Plant tie-line, and power flow from Georgia Power Company

to the FPC Turner Plant over F. P. Corp. transmission

lines. I also examined the power flow over the other tie-lines

but not in as much detail.

Q. Mr. Jacobsen. Have you prepared or have you super-

vised the preparation of an exhibit, as a result of your study

15

copia

(85)

and analysis, that shows the route of flow of intéPstate

power from Georgia Power Company, over F.P. Corp.

transmission lines into the FPL System over the F.P. Corp.

Turner Plant-FPL Sanford Plant 115 kv transmission tie-

line? A. Yes.

86

Q. Mr. Jacobsen. I show you an exhibit consisting of 7

pages numbered consecutively from 1 thru 7. Page 1 is a_

diagram entitled “Route of Interstate Electric Power Flow

in 1964 from Georgia Power Company to Florida Power &

Light Company’s System Over the Florida Power Corpora-

tion Transmission Lines”, and 6 pages numbered 2 to 7

of tabulated data entitled “Hourly Interstate Power Flow

on Selected Days in 1964 From Georgia Power Company

to Florida Power & Light Company Over Florida Power

Corporation Transmission Lines Shown on Load Flow Dia-

gram on Page 1*.” I ask you if this is the exhibit to which

you refer? A. It is. |

Staff Counsel: Mr. Examiner. The staff requests that the

exhibit as identified by Mr. Jacobsen be marked for. identi-

fication as Staff Exhibit No. 18.

Q. Mr. Jacobsen. Please describe the diagram, page A,

of this exhibit. A. This is a simplified diagram that, among

other things, shows transmission lines, substation busses,

and direction of interstate power flow. The purpose of the

_ diagram is to show the transmission lines and substation

busses over which interstate power flows from Georgia

Power Company, over F.P. Corp. transmission lines, and

into the FPL System. The arrows adjacent to the trans-

mission lines indicate the direction of power flow for each

day and hour analyzed. The color of the arrow, as desig-

nated in the legend, indicates whether the power flow is

interstate, commingled or unidentified.

. Mr. Jacobsen. Please describe the 6 pages of tabulated

data, page number 2 to 7,In Staff Exhibit No. 18.

e

16

(88) ,

87

A. These pages of tabulated data indicate, among other

things, the 22 days and hours of these days, that power flow

was studied to show that commingled power flowed into

the FPL System. It also shows the direction and magnitude

of power flow over specific transmission lines in sections of

the F.P. Corp. and FPL Systems.

Q. Mr. Jacobsen. In your study and analy sis did you con-

sider the substation busses as a point. A. I considered

them as a point.

Q. Mr. Jacobsen. What information did you use in pre-

paring Staff Exhibit No. 18? A: The information that I

used was obtained from System maps in FPC Forms No. 12,

Power System Statements, filed by FPL and F.P. Corp.,

and’ F.P. Corp. Daily Operating Reports, Staff Exhibit

No. C 2.

Mr. Jacobsen. Do the arrows shown adjacent to the

transmission lines on Staff Exhibit No. 18 indicate the flow

of row.r for every day and hour that was studied and

ani lyzed .s indicated in Staff Exhibit No. 18? A. Yes.

©. Mr. Jacobsen. Referring to Staff Exhibits No. 18 and

No. C 2-will you describe your analysis of interstate power

flow? A. Yes. For the purpose of this analysis only the

two 115 kv transmission line interconnections between Geor-

gia Power Company and F.P. Corp.’s Jasper Substation

were considered. These tie-lines are the Kettle Creek-Jasper -

and Pine Grove- Jasper 115 kv transmission lines. On days

as shown on Staff Exhibit No. 18, the Jasper Substation

Daily Operating Reports, Staff Exhibit No. C 2, interstate

power flowed over these two interconnections into F.P.

Corp.’s Jasper Substation, reference Points (1) and (2).

The Jasper Substation Daily Operating Reports also show

that unidentified power flowed from Suwannee Plant over

17

(88)

the 115 kv Suwannee-Jasper transmission line into the Jas-

per Substation bus, reference Point (3). The Jasper Daily

Operating Reports for the same days and hours indicate

commingled power flowed toward White Springs Substation

over both the Fort White-East and Fort White-West 115

kv transmission lines, reference Points (4) and (5). The

Fort White Substation Daily Operating Reports, for the

same days and hours show that commingled power was

flowing into the Fort White Substation bus, reference Points

(6) and (7). The Fort White Substation Daily Operating

Reports show for these same hours that commingled power

flowed from Fort White Substation to the Turner Plant

Station bus over the Silver Springs 115 kv transmission line,

reference Point (8). The Turner Plant Daily Operation

Reports for the same days and hours show commingled

power flowing into the Turner Station bus over the Silver

Springs transmission line, reference Point (9). The Turner

Plant Daily Operation Reports show for the same days

and hours commingled power flowed from the Turner Sta-

‘tion bus to the FPC Sanford Plant bus over the Turner-

Sanford 115 kv transmission line, reference Point (10).

Q. Mr. Jacobsen. Where is the transfer point of F.P.

Corp.’s delivery of commingled power to the FPL System

over the Turner-Sanford 115 kv transmission tie-line? —

. , 89 |

A. The transfer point according to FPC Form No. 12, 1964,

Power System Statement, Schedule 8, page 19, filed by FPL

is at a point near Lake Monroe, Florida.

Q. Mr. Jacobsen. Why did you refer in your above testi-

mony to the power flow from Suwannee Plant to Jasper

Substation as unidentified power flow?) A. I did not at-

tempt to show whether the flow of power from Suwannee

Plant to Jasper Substation was intrastate power or com-

mingled power so I identified or designated it arbitrarily

as unidentified power flow. Whether this power could be

18

CERN edb tres

(90)

proven to be either interstate or commingled power would

not change my opinion as to whether commingled power

flowed over the Turner-Sanford transmission tie-line.

Q. Mr. Jacobsen. Do you have anything further to say

about your study and analysis of interstate power flow

from Georgia Power Company, over the Jasper-Live Oak

69 kv tie-line or the Turner-Sanford 115 kv tie-line, through

the F.P. Corp. System transmission lines into the FPL

System? <A. Yes. I would like to amplify the results of my

study and analysis made of interstate power flow from

Georgia Power Company over F.P. Corp. transmission lines

into the FPL System over the Turner-Sanford 115 ky tie-

line as shown in Staff Mxhibits No. 18 and No. C2.

Jasper Substation Daily Operating Reports, Staff Exhibit

No. C 2 indicate power flow readings every hour in the

day for the Pine Grove-Jasper and Kettle Creek-Jasper -

115 kv interconnections, | _

90

reference Points (1) and (2) on Staff Exhibit No. 18. How- -

ever, for the power flow over the Fort White-Mast and Fort

White-West 115 kv transmission lines, reference Points (4)

and (5) on Staff exhibit No. 18, readings are recorded only

for the hours from 7 a.m. to 9 p.m., inclusive.

Fort White Substation Daily Operating Reports, part of

Staff Exhibit No. C 2, indicates power flow readings over

circuits connected to the Fort White substation bus were

retorded only from 7 a.m. to 9 p.m., inclusive, reference

Pojnts (6), (7) and (8) on Sto? Exhibit No. 18.

he Turner Plant Daily Operation Reports, part of Staff

Exhibit No. C 2 indicates that power readings on cir-

cuits connected to the Turner Plant Station bus, reference

Points (9) and (10) on Staff Exhibit No. 18, are recorded

every hour in the day.

After studying the Daily Onatne Reports, Staff Ex-

hibit No. C 2; the way the F.P. Corp. System operates, and

i 19

(OO RINNE ORE AAAI TEENS NEM WaT

(90)

the pattern of power flow over transmission lines during

the early morning hours of the F.P: Corp. System, it 1s my

opinion that interstate and commingled power flowed from

Georgia Power Company over the F.P. Corp. System trans-

mission lines through reference Points (1), (2), (4), (5),

(6), (7), (8), (9) and (10) into the FPL System over the

Turner-Sanford 115 kv tie-line, during earlier hours than

7 a.m. on 20 of the 22 days listed in Staff Ixhibit No. IS.

91

Q. Mr. Jacobsen. Have you prepared or have you super-

vised the preparation of an exhibit Showing the additional

hours of commingled power flow? A. Yes.

Q. Mr. Jacobsen. I show you an exhibit entitled “Hourly

; Interstate Power Flow On Selected Days In 1964 From

( Georgia Power Company to Florida Power Corporation

Transmission Lines Shown On Load Diagram On Page

1 of Staff Exhibit No. 18 consisting of 5 pages of tabulated

power flow data, and ask you if,this is the exhibit to which

vou refer? A. It is.

Staff Counsel: Mr. Examiner. The Staff requests’ that

— the exhibit as identified by Mr. Jacobsen be marked for

identification as Staff Exhibit No. 19.

Q. Mr. Jacobsen. Please describe Staff Exhibit No. 19.

A. This exhibit primarily shows evidence of interstate

power flow from Georgia Power Company to the FPL Sys-

tem routed ovér F.P. Corp. transmission lines, as shown

on the one-line diagram of Staff Exhibit No. 18. The power

‘flow tabulated is for hours earlier than 7 a.m. on days for

which the power flows are not completely recorded on the

Jasper and Fort White Substations-Daily Operating Re-

ports part of Staff Exhibit No. C 2.

Q. Mr. Jacobsen. What are the similarities and hasie dif-

ferences between the tabulated data shown in Staff Exhibit

No. 18 and Staff Exhibit No. 19?

20

<LES MAR SOON IEA Whe 8 SNGITY 0 Mesh

(99)

92

A. Both Staff Exhibit No. 18 and Staff Exhibit No. 10¥efer

to the one-line diagram shown in Staff Exhibit No. 18 to

show the route of power flow over transmission lines and

through designated reference Points at all hours listed in

these, two tabulations. However, the significant difference

is that Staff Exhibit No. 18 shows power flow at 7 a.m. or

after on 22 days, whereas Staff Exhibit No! 19 shows power

flow before 7 a.m. on 20 of the 22 days.

Q. Mr. Jacobsen. Do vou have any farther comments on

Staff Exhibit No. 192 A. Yes. The 5 pages of tabulated.

data indicate the hours on the 20 days that. power flow was

studied. It also shows the direction and magnitude of power

flow over specific transmission lines in portions of the F.P.

Corp. and FPL Systems as delineated on the one-line dia-

gram of Staff Exhibit No. 18.

Q). Mr. Jacobsen. Do the arrows shown adjacent to the

transmission lines on the one-line diagram, Staff Exhibit

No. 18, indicate the direetion of interstate and commingled

power flow for each day and hour analyzed that flows into

the FPL System? <A. Yes. The color of the arrow, as

designate ‘d in the legend, indicates whether the power flow,

is interstate, commingled or unidentified.

Q. Mr. Jacobsen. Did you consider the substation busses

as a point in your study of power flow shown in Staff Ex-

hibit No. 19. A. I considered the substation busses in-

volved as a point.

* * * * * * * ® * * * . *

Q. Mr. Jacobsen. Please describe how electric systems

react to a change in frequency. A.-Staff Exhibit No. SA

for identification is a reproduction of a FPL System fre-

quency recorder chart for February 17, 1965, between the

hours of 11 a.m. and 1 p.m. The loss of about 580 mw of

21

-

ma --

NN 7

(99)

generation by a midwestern electric utility system in the

Interconnected Systems Group (ISG) at about 11:40 a.m.,

__ February 17, 1965, is shown on the frequency recorder chart.

Member systems in the ISG, including FPL, responded

- automatically’ to make up the generation deficiency. As

shown on the frequency recorder chart, frequency returned

to normal, i.e., 60 eyeles, on all systems in a period of min-

utes. Reversal of this action will occur should FPL lose a

- generator unit of certain nameplate rating. Due to the

F.P. Corp. System limitations of power transfer at the

Fort White Substation, sudden outage of FPL generators

of capacity greater than about 130 mw may result in the

Florida peninsula being separated from the ISG. This con-

dition is discussed in minutes of the Florida Operating

Operating Committee, Staff Exhibit No. 3.

100

In the event there is a sudden outage of generation on

Systems in the Florida Pool, the ISG would come to the

-assistance of FPL and other members of the Pool. There

is a reference in Staff Exhibit No. 3 which describes the

procedure of Florida Pool members to follow to prevent

over-generation after losses of units, plants, customer loads,

or major loads.

* * * * *. * * * # * * *

104

Q. Does any member of the Florida Pool exchange sea-

sonal capacity with anv of its neighbors? A. Yes. F.P.

Corp. exchanges seasonal capacity with the Southern Pool.

The Southern Pool receives 100;000 kilowatts from F.P.

Corp. during the Southern System’s summer peak load

period and delivers

9)

od et

MRNAS QU A aE a ae ae RR : PUES x

(114)

105

a like amount to F.P. Corp. during the latter’s winter peak

load period. However, a study of Staff Exhibst No. C 1 and

No. C 2 shows that for many days of the year including the

peak load periods there is flow of power in both directions

during a 24 hour day over the F.P. Corp.-Southern System

interconnection.

* * * * : * * A * * *

113

Q. Mr. Jacobsen. Do- you have anything to ‘add to vour

deseription of the operations of the Florida Pool? -A. Yes.

The five-system Florida Operating Committee provides

joint planning and operation of the Florida Pool. The pool-

ing arrangement of spinning reserves and emergency ca-

pacity increases the reliability of the Florida Pool.

114

The member companies of the Florida Pool gain svstem

security by Committee planning of maintenance work on

major generating equipment. Coordinated scheduling of

plant overhauls avojds having the biggest units out of serv-

ice at the same time.

The five systems of the Florida Pool:in September, 1963,

began exchanging information daily on the amount.of spin-

_ ning reserve each expected to carry during the System peak.

Fach operating company in the Florida Pool need not

rely solely on its own generating sources to meet emergen-

cies. Each operating company may call upon member com-

panies of the Florida Pool and its total resources for what.

ever the individual.operating company capacity and energy

requirements may be. By the same token, cach operating

company, as a pool member, assists other members in meet-

ing their requirements. This mutual assistance is made pos-

sible by among other things, advance coordinated planning

of the installation of generating facilities, maintenance of

23

(114)

facilities, and the availability of emergency capacity be-

tween Pool members and between F.P. Corp. -and the

Southern System.

Q. Mr. Jacobsen. Does FPL have, through interchange or

emergency agreement, spinning reserves instantly available

to it? A. Yes. FPL reports in FPC Form No. 12, Power

System Statement, for the vear 1964, that it has instantly

available for emergencies : 80,000 kw from F.P. Corp., 63,000 —

kw from TEC, 46,000 kw from Jacksonv ille and 43,000 kw

from Orlando.

115

Q Mr. Jacobsen. Do F.P. Corp. and the Southern Sys-

tem have a mutual emergency standby agreement? A. Yes.

Such an agreement is described in Article VITI of Southern

Services, Inc., Rate Schedule FPC No. 27, Item J by refer-_

ence.

Q. Mr. Jacobsen. Do F.P. Corp. and TEC have antomatic

dispatch svstem? A. Yes. Both have computers to auto-

- matically dispatch their major generating units. |

Q. Mr. Jacobsen. What is the tie-line bias for F.P. Corp.

and TEC? A. The tie-line bias for TEC is 15 mw and

22mw for F.P. Corp.

Q. Mr. Jacobsen. What observations did vou make in

studying the overhaul schedules, Staff Exhibit No. 9, of the

generating units of FPL? A. Generally, the scheduled

maintenance or inspection outages of generating plants

follow a planned program of outages to take advantage of

the summer season when less capacity on the system is re-

quired. However, forced outages will cause deviation from

the planned schedule. Forced outages occur in an unpredict-

able manner and they can and do occur du&ing times when

eapacity:is much needed during the season of peak loads.

The coordinated operation of the Florida Pool makes pos-

sible large gains in capacity availability by coordinating the

overhaw or maintenance of the units within the Pool.

24

Tle PERS eth nae aly Aon TEAS Ae Dade RR EOS

*%

(122)

Q. Mr. Jacobsen. Have you prepared an exhibit consist-

ing of 4 sheets entitled “Electric inergy Transfers Between

Florida Power & Light Company and Other Electric Utility

Systems During Calendar Years 1954-1964”, that show the

electric energy transfers between FPL and Jacksonville

and F’.P. Corp. over the transfer point near White Springs?

A. Yes.

fn

122 |

Testimony of Staff Witness, Joseph J. A. Jessel

Q. Would you state your name-and address? A. My

name is Joseph J. A. Jessel and I reside at 4911-35th Road,

North Arlington, Virginia. |

Q. By whom are you emploved and in what eapacity? <A.

I am employed by the Federal Power Commission as an

Electrical Engineer and I am Assistant Chief of the Bureau

of Power. : |

~ Q. What position did you formerly oceupy in the Bureau

of Power? <A. I was Chief of the Division of Electric Re-

sources and Requirements until April 25, 1965. .

Q. What is the Division of Electrie Resources and Re.

quirements? A. The Division of Electric Resources and

Requirements is one of the four Divisions of the Bureau

of Power, the others being the Division of Licensed Projects,

the Division of River Basins, and the Division of Rates and

Corporate Regulation. The Division of Electric Resources

and Requirements is the Division responsible for all elec-

trical work of the Bureau except on rates and corporate |

matter. _ |

Q. What is the organizational structure of the Division

of Electric Resources and Requirements? A. The Division

of Electric Resources and Requirements is comprised of

the Section of Transmission and Coordination, the Section

of Power Requirements and Supply and the Section of Cost

‘stimates.

25

(122)

Q. What are the functions of the Division of Electric Re-

sources and Requirements of which you were the Chief?

123

A. The Division of Eleetrie Resourees and Requirements

performs the headquarter’s office substantive work of the

Bureau of Power. It also gives technical guidance and su-

pervision to the regional offices.in matters pertaining to:

power requirements and supply, electric power markets, in-

terconnection and operational coordination of electric power

systems, electric system maps, power values, and power

system data. This Division also makes studies of, and ad-

vises the Division of Licensed Projects and the Division of

River Basins concerning markets for and value of power

from proposed non-Federal and Federal hydroelectrie proj-

ects, transmission facilities appropriate for inclusion under

license, and facilities required to market power from federal

projects. This Division also advises and assists the Division

of Rates and Corporate Regulation on matters dealing with

the operation of electric systems. In addition, it performs

the technical work of the Bureau of Power and cooperates

with other agencies in matters pertaining to electric power

aspects of national defense. Also, it performs all functions

and prepares engineering and statistical reports relating

to power production and capacity, fuel consumption and

stocks, and electric utility system loads. | |

Q. What are the functions of the Section of.Transmission

and Coordination of the Division of Electric Resources and

Requirements? A. The Section of Transmission and Coor-

dination prepares interconnection and coordination studies

involving two or more électric svstems and also supervises

this activity of the regional offices. It prepares performance

data as well as construction and operating cost estimates

for transmission lines and substations for use in power

value estimates, in power market surveys, and in licensed

project matters. It prepares memorandum reports on

26

5 AER MR OI I GR IRE SER SIE

7 —

(125)

124

transmission facilities which may be subject to inclusion

in licensed hydroelectric projects. It supervises the prepara-

tion of maps of principal electric facilities. It directs the

collection and compilation as well as analysis of informa-

tion on the transmission of electric power and on transmis-

sion facilities. It supplies expert witnesses in formal pro--

ceedings before hearing examiners of the Commission. It

coordinates the work involving two or more: Divisions of. -

the Bureau and does the work on national defense matters.

Q. What activities did you supervise in vour capacity as

Chief of the Division of Electric Resources and Require-

ments? A. I supervised the engineering activities of the

Section of Transmission and Coordination, the Section of

Power Requirements and Supply, the Section of Costs Es-

timates, and Special Studies technical staff: The work of

these units was under my supervision and control. At times,

I delegated some of such supervision to an assistant, |

Q. When did you become Chief of the Division of Electric

Resources and Requirements? A. I was appointed Chief

of the Division of Electric Resources and Requirements on

May 27, 1962.

Q. What position did vou have before you became Chief

of the Division of Electric Resources and Requirements? ‘

A. I was Head of the Section of Transmission and Coor-

dination. When the Chief of the Division was absent, T

acted as Chief.

Q. Are you an engineer? A. Yes, Iam an electrical en-

gineer. |

Q. Do vou have a formal education in electrical engineer-

ing? <A. I do.

125 -

Q. What engineering school did you attend? A. T at.

tended the Harvard Engineering School, Harvard Univer.

sity, Cambridge, Massachusetts. |

27

(125)

Q. What, if any, degree or degrees did vou receive from

Harvard? <A. I received the Degree of Bachelor of Science

(S.B.) in Electric Engineering magna cum laude in 1931,

Master of Science (S.M.) Degree-in Electrical Engineering

in 1932, and a Doctor of Science (Se. D)° Degree in 1954.

Q. Do vou belong to any engineering societies? A. I do.

Q. Would you state what engineering societies vou belong

to and what grade of membership you hold? A. I am Fel-

low of the Institute of Eleetrie and Electronic Engineers,

a member of the Washington Society of Kngineers, a mem-

ber of the Harvard Engineering Society, a member of the

National Society of Professional Engineers, and Chairman

of the Nominating Committee of the District of Columbia

Council of Engineering and Architectural Societies. J was

Chairman of the Council from June 1968 to June 1964. The

Council has 34 member organizations. [ am also a member

of Tau Beta Pi, an honorary engineering society.

Q. Are youa registered professional engineer? A. Tam.

Q. Where are vou registered? A. I am registered in

the District of Columbia and the State of California.

126

Q. Do vou do any teaching? A. I do.

Q. Where do vou teach? A. I teach at the Graduate

School of the Department of Agriculture.

Q. How long have vou been teaching at that school? A,

I have been a member of the faculty since 1942.

Q. What courses have vou taught? A. IT have taught a

course called “Electric Utility Engineering” for many years

and am now teaching a review course for the Professional -

Engineers Examination in Electrical Engineering for use

in examinations given in the District of Columbia and

neighboring states. .

Q. When did vou join the staff of the Federal Power

Commission? <A. I joined the staff of the Federal Power

Commission in October, 1934. .

28

(127)

Q. At what offices were you stationed while a member of

the staff of the Federal Power Commission? A. I was a

member of the Washington, D.C. staff of the Commission

from October 1934 -to August 1936. Then I was transferred

to the San Francisco Regional Office where I worked until

March 1942 except for a ten month tour of duty in Wash-

ington during 1941. I have been at the Washington, D.C.

office from 1942 to date. .

Q. Did you have any experience in electrical engineering

before joining the staff of the Federal Power Commission

in October 1934? A. I did.

Q. Would vou describe briefly such experience prior to

October 19342 A. From June 1928 to October 1928, ]

worked as Assistant Engineer for the Edison Electrie Hlum.

inating Company of Boston. My activities included research

on underground cable heating, and general power and ecé-

nomic studies.

127

From June 1929 to October 1929, I worked as Associate

I;ngineer for the Boston Elevated Railway on research on

rail bonds, contact potentials and ground conductivity.

From October 1929 to August 1933, I worked intermit-

tently for the Harvard Engineering School in the design

and construction of equipment for a high voltage laboratory.

I also did independent consulting work on electric power

matters.

Q. Would you summarize your experience from October

_ 1934 to August 1936 while vou were a member of the Wash-

ington, D.C. staff of the Federal Power Commission? A.

I conducted and supervised work on electrie power trans-

mission and also had technical supervision of review of

power system statements. I was responsible for electric

transmission phase of several] comprehensive. power reports,

such as to the President on Western potential water power

projects and a comprehensive interconnection and coordina-

29

m

a aS he at Se ee

(127)

tion report on the Southeastern Region. I also took part in

the first National Power Survey. I] was on several special

assignments to study operations of power networks.

Q. Would you summarize your experience from August

1936 to March 1942 while at the San Francisco Regional

Office of the Federal Power Commission? <A. I supervised

as well as made electric transmission studies and power

market surveys, including those required for license proj-

ect applications. I was in charge of the electric transmission

phases of the report made by the Federal Power Commis-

sion on the Bonneville project. I directed and supervised

staff on the ‘first headwater benefit study for projects of

Pacific Gas and Electric Company and Southern California

Kdison Company.

128

I prepared reports on all aspects of license project applica-

tions. I supervised power supply studies and property pro-

tection surveys in cooperation with the War Department.

I was in charge of the technical aspects of the San Diego

Power Market Survey. I prepared or supervised all of the’

electric phases of the staff report on the Bridge Canyon

Project. I prepared special reports as required on trans-

‘ mission matters relating to costs and network performances.

I worked with the National Resources Committee.and was

~ a member of the Subcommittee on Electric and Gas Utili-

ties of the State Council of Defense for Colifornia.

I was assigned temporarily to the National Defense War

Power Staff in Washington, D.C. during 1941. I was placed

in charge of electrical transmission and operating work.

I was a member of the Commission’s Southeastern Power

Shortage Committee in charge of electric transmission and

operating problems at time of the 1941 power shortage. I

took part in field work in connection with this power short-

age, and in some cases I directed that operating practices

and procedures of the electric utilities be revised.

30

CY EERE LEA. BAB EE nn sine BUTE,

(129)

Q. Would you summarize your experience from March

1942 to date while stationed in the Washington D.C. offices

of the Federal Power Commission? A. During the 1942-

1945 period, I was in charge of the ‘engineering work on

War Power Contracts. ] Was a consultant to the War Pro-

duction Board. I was in charge of studies on intereonnec-

tions required to supply war loads. I made studiés of ma-

terial requirements for transmission facilities to serve new

war industries. I became Chief of the

129

Transmission Section of the Kleetrical Division in charge

of all work relating to transmission and electric operations.

During 1945-1951, as Chief of the Section of Transmission

and Coordination, I supervised and conducted power market

surveys incliiding economic studies of industries, inter-

connection and coordination studies, and technical’ and

economic studies of. power system operations: I prepared

economic and operating studies of transmission networks

and power supply systems. I supervised studies of technica]

and economic factors of power using industries, and’ su-

pervised studics of EGU: I supervised pro-

Jections of regional and nationa economic patterns. I su-

Pervised electric facility: mapping, cost studies and electric

operating studies. I also testified as an expert.witness at

Congressional and Commission hearings.

From 1951 to May 1962, I was responsible for the tech-

nical review of transmission and operating studies made

in the Regional Offices of the Commission. ] recommended

interconnections between two or more electric systems based

on staff studies. T was responsible for and supervised re-

views of cost estimates and of construction. programs of

transmission facilities required for contemplated hydroelee-

trie and fuel-electrie plants for ful] utilization’ of existing

and prospective hydroelectric facilities. T directed and gu.

pervised studies for determining transmission facilities

31

Ibe ncamecconary eo sserirnte HE

(129) 7 _

‘to be included in licensed hydroelectrie projects. I was a

consultant to and supplied advice to other °

130

divisions, offices and bureaus of the Commission and. to

other governmental Federal agencies including defense

agencies. I represented the Commission on civil defense

and defense mobilization matters. ‘

During this period, I testified as an expert witness at

many formal hearings before Hearing HMxaminers of the

(‘ommission.

* * * * * * * ® * @

135 |

Q. What-.amount does FPL report in FPC Form No,

2 for 1964 as-the required reserve capacity for system?

A. 404,000 kilowatts.

Q. Of the total amount of 404,000 kilowatts of reserve

eapacity required, how much did FPL provide in 1964 and

how much came from other sources? A. FPL supplied

172,000 kilowatts of reserve capacity and 232,000 kilowatts

were reported as available from four Florida systems,

namely 80,000 kilowatts from Florida Pojyver Corporation,

63,000 kilowatts from Tampa Electric Company, 46,000 kilo-

Ww atts from City of Jacksonville and 43,000 kilowatts from

Orlando Utilities Commission.

136

Q. What is vour understanding, if anv, of the. reasons

for the differences between scheduled quantities and

metered quantities of FPL? <A. Scheduled transactions

reflect the amounts of electric power and energy provided °

bv one electric system for the account of another system

and they represent the amounts for which payments are

made regardless of whether the amounts of electrie power

32

‘\

NS EM ADE ER SOME

(139)

—s 2

are actually taken as, scheduled. Metered transactions re-

flect the conditions at points of interconnection because of

the electrical characteristics of the electrical network, the

locations and amounts of generation dy all power plants

connected to the transmission network, and the locations

and moment to moment magnitudes of loads supplied from

the network.

* * ~* * * *- a * * e

138

Q. Why do electric utilities such as FPL carry on busi-

ness in terms of scheduled transactions? A. Electric SVs-

tems, such as FPL and others, have no control over the

actual transfers of electric power and energy over any

particular transmision interconnection with another electric

system if there is more than one interconnection. Similarly

electric utilities, such as FPL and others, have no control

over the actual transfers of electric power and energy with

any particular electric system. if there aré interconnections

with two or more electric systems, which are also directly

or indirectly connected. In each instance this is due to: the

free flow characteristics of the electric networks. However,

all systems operating together on an interconnected basis,

schedule the amounts of power and energy transactions

among themselves on an hour to hour basis and each sets

on its own net interchange controller the net amount of

scheduled transactions. Fach system measures the actual

transfers at each point of connection with another electric

system and the differences between scheduled transactions

and actual transfers are balarfced out as soon as

139

practical. In order. that the method may work efficiently all —

interconnected systems must do their share in adhering

to schedules as closely as possible.

Q. Would you describe how scheduled transactions are

‘ conducted? A. An electric system, such as FPL, agrees to

33

(139)

purchase an amount of electric energy during certain hoiy's

of a particular day. Upon such agreement, it is committed

to pay for such electric energy regardless of whether or not

the amount is actually taken by FPL. To assure to the

extent possible that the purchased amount is received, the

receiving system, such as FPL, sets its interchange con-

trols at the proper magnitude and usually the net amount

received corresponds closely, with that scheduled, even

though the energy transfer over a particular connection

may be as much as three times or-as little as one-third of

the scheduled amount. _

Q. Would you illustrate vour answer by an example?

A. To illustrate: my answer, assume that FPL schedules

a receipt of 50 average meg: awatts, or 50 megawatt-hour's

per hour, of electric power from Florida Power Corpora-

tion during the hours 10 a.m. to 12 noon, and makes no

schedules for transfers of energy with any of the other

electric systems to which FPL is connected. FPL-sets 50

megawatts on its system net interchange dial and operates

its own generating units automatically in the most economi-

cal manner such that the net of transfers at all points of

interconnection with' other electric systems corresponds

as closely as possible, moment to moment, to a 50. average

megawatt net input to the system

140

of FPL. The 50 megawatt schedule is for 60 ‘evcie opera-

tion. With deviations in frequency from 60 eveles the net

interchange differs from 50 megawatts. The Company’s

system has a regulating characteristic represented by a

tie-line bias curve. It is a curve of area (or system) net in-

terchange plotted against frequency, and is approximated

as a straight line. The slope of, the tie-line bias curve is

a negative quantity. The slope is expressed as the standard

frequency of 60 cycles minus the prevailing frequency di-

vided hy system net interchange . t the pr vailing frequeney

"34

Se

(141)

minus the system net interchange that would obtain at 60

cycles which is the scheduled interchange, in this example,

00 megawatts. The reciprocal of the slope of-the tie line

bias curve is called bias setting and it is given in terms of

megawatts per one-tenth evcle. When the deviation from

the normal 60 cycle schedule is matched hy the schedule

shift, the operation is along the tie-line bias regulating

curve, and the actual net interchange in kilowatts corre-.

sponds to the scheduled transactions and the system’ does

its.share of frequency regulation.

Q. Would you explain what you mean by bias as you

used it?) A. As [I use it in my testimony, bias is the auto-

matie shift of FPL’s net interchange schedule with fre-

queney. It is usually expresséd in megawatts per one-tenth

eyele, or percent of rotating capacity per one-tenth evele.

Q. Would vou testate vour explanation of the technique

of and reason for tie-line bias control in ternis more familiar

to the layman? ;

141

A. Yes. The modern electric system is an ever-varying

dynamic one; loads and gencration ate cOnstanny changing

moment to moment.

For any particular loading on an electric -svstem all of

the electric energy produced by all the gencrating units is

delivered to the common coordinated and integrated modern

transmission.system from which all of the eustomers are

supplied. This interdependence of generating sourees for

supplying varying loads accounts for the ever- changing

conditions found on electric systems. All generating units

connected to.a common network experience the same changes

in frequeney, and all clocks connected to sneh a network

experience these-changes in frequeney and maintain the

same time.

No attempt usually is made to control flows on ‘individual

lines because the electric energy flows are determined by

35

Ee ee rt rte Se

(141)

the electrical characteristics of the network. Only the net

of flows over all interconnections is controlled by increasing

or decreasing generation so as to maintain interconnection

schedules and to maintain frequency as closely as possible

at 60 eyeles. ,

Frequeney never remains at 60 evcles—it is always a

bit above or a bit below, because the loads always dict ate

and the generation follows to keep the system load and

generation in balance and as close to 60 cycles as possible.

Although, as noted, deviations in frequency almost al-

ways occur due to the impossibility of matching instantane-

ous load variations with rapid changes in generation, it is

important, for system operation,

142

to keep these frequency deviations as small as possible

for at least the following reasons:

Most contracts for the sale of electric energy call for

delivery of 60 evele current. Furthermore, the smaller the

deviation in frequency, the less will be the transfer of non-

scheduled net energy between systems; unnecessary speed-

up or slow down in generating equipment will be minimized,

and clocks will keep more perfect time; and finally, many

precision electrical instruments and industrial operations

require that frequency be kept as close to 60 eveles as pos-

sible, This is no small matter on the FPL system with its

important loads and service at 60 cycles to its municipal

and cooperative electric system customers.

Tie line control with frequency bias is the technique used

to maintain frequency at 60 cycles on interconnected elec-

trie systems operating in synchronism, such as FPL, and

is also used to match generation with net system load.

It is important to note that in matching system genera-

tion to total system load (including scheduled transfers

over interconnections) and in regulating frequency, all 140

electric systems in the Interconnected Svstem Group (in-

36

as

(143)

cluding FPL), a Voluntary association of operating mem-

bers from electric utility systems, depend in part on each

other. It is generally known that each important generating |

station in the Interconnected System Group is assigned an

appropriate share or “hand” of generating capacity to be

raised or lowered in the event of a system frequency devia-

tion above or below a normal frequency band. The basic

143

function of modern frequency and tie line control is, of

course, that of regulating the total. generating output in

each individual system or contro] area in such a way that

the total generation will match continuous and as closely

as possible the total svstem load, including scheduled loads

on interconnection ties. |

Q. Assume for purposes of my question that the opera-

tion of the génerating units of FPL is such as not to have

the svstem net interchange along the tie line bias regulat-

ing characteristic curve of the FPL’s electric system.

Would you describe what takes place under such a situa-

tion? A. For an operating condition such as described,

the situation may be considered as ‘being a point below the.

area-net-interchange vs. frequency curve. For such a point

not on the curve, the system generation error, also some-

times called area or system requirement, consists of two

components, the first is the amount of deviation of net in-

terchange from the 60 cycle schedule and the second is the

amount of automatie shift of net interchange schedule with

frequency. The algebraic sum of these two quantities, some-

times called regulating need of the area or svstem, is the

amount by which system generation must be changed for

the system of FPI/t6 correct its net interchange and do

its share of frequency regulation.

Q. Would you explain why such a difference could. exist

between scheduled and actual transactions? A. None of

the connected electric svstems including that of FPL has

any control over the actual transfers of power at each

37

- (143)

point of interconnection because of the free flow character-

istics of electric networks.

144

All that can be controlled on each system having more than

one interconnection with other electric systems is the net

of transfers into or out of its own svstem or area. This is

particularly so with respect to the electric system of FPL

because some of the electric systems to which it is connected,

have connections among themselves.

Q. Would-vou indicate wnat connections and transactions

these other systems have? A. There are substantial trans-

fers of electric power and energy between the electric svs-

tems of FPL and Florida Power Corporation, Tampa [lee-

trie Company, City of Jacksonyille and Orlando Utilities

Commission; Florida Power Corporation is also connected

to Tampa Electric Company, Orlando Utilities Commission,

Georgia Power Company, Gulf Power Company, and South-

eastern Power Administration, with each of which it: has

substantial energy and power transfers.

There also are transfers of electric energy among the

following systems: |

(1) Tampa Electric Company with Florida Power &

Light Company. and Florida Power Corporation.

(2) Orlando Utilities Commission with Florida Power &

Light Company and Florida Power Corporation.

(3) Georgia Power Company with Alahama Power Coni-

pany, Gulf Power Company, Duke Power Company, Ten-

nessee Valley Authority, Southeastern Power Administra-

tion and others. | |

Q. What is the natyre of electric utility systems?

145

A.- An electric utilitv system, such as FPL, is essentially

an electromechanical system to which all operating genera-

38

(146)

tors on the interconnected network are interlocked clectro-

magnetically. This means that electric generators, under

ordinary operating conditions, run either at exactly the

same speed or at a speed ratio such as 1800 or 3600 revolu-

tions per minute for a frequency of 60 evcles. No operating

generator can change its speed by itself as long as it oper-

ates connected to the network. Al] generators connected

to the same network must follow each other as to speed

and frequeney whenever there is a change in frequeney,

and the frequency of all. interlocked generators is always

exactly the same.

Q. Are all electric systems essentially alike as to electri-

cal, electromagnetic and electromechanical characteristics?

A. Yes. Beeause they are alike, it is possible to have pres-

ently existing interconnected operations on a very large

scale, extending from the Rocky Mountains to the Atlantic

Ocean and from the Canadian to the Mexican border.

Q. Would vou detail some of the electric characteristies

of electric systems such as FPL and others to which it is

connected? A. For all yrractical purposes and for opera-

tion at 60 cycles, electric energy is generated as needed

because it cannot be stored in electrical form. Electric

energy is delivered where needed ata speed of about 186,600

miles per second. An electric system such as that of FPL

and others automatically. requires at constant frequency

that at every . |

146

moment total generation always be equal to total load plus

losses; otherwise, there is an unbalance cauging a change

in frequency. An electric system cannot supply one econ-

nected load and not supply another connected load. For

any particular loading on an electric system, all of the elec-

tric energy produced by all of the generating units is de-

livered to the common transmission network which acts as

a single unit from which all of the customers are supplied.

For any change in a load or generation, there is an elee-

39

(146)

trical effect through a change in voltage and current at all

generators and at all loads.

Q. Would you detail some of the electromagnetic charac-

teristics of electric system such as FPL and those to which

it is connected? A. All stators of the generators are cou-

pled: electromagnetically to the prime mover-rotor com-

ponents of the generating units. As the power output of

a generator is increased, there is an angular displacement

between a point on the stator and a point on the rotor which

initially are opposite to each other electrically at no genera-

tion. As the power output on a generator is increased, this

angular displacement increases until a spread between these

two points of 90 electrical degrees is reached. Further load-

ing on a generator would cause a break in the electromag- °

netic link between the rotor and stator of the generator and

the electric network, and result in a condition called out-of-

step. During actual operations this angular displacement

may be limited to about 40 electrical degrees because of the

swings on the rotors caused by load changes and disturb-

ances on the networks. For each moment to moment change

in electric.

147

joad on an electric system, there is a change in frequency

and an oscillation and change ; in the angular displacement

among the rotors of the generators; and, this causes a

swapping of loads among the generators for each change:

in load.

Q. Would you detail some of the pisetroiesianionl char-

acteristics of electric systems such as FPL and those to

which it is connected? A. Each generating unit when op-

erating at a speed corresponding to 60 cycles has mechanical

energy of rotation stored in its rotating components, which

is automatically convertible to electric energy when there

is a decrease in frequency and corresponding drop in revo-

lutions per minute. Thus, when a load is added suddenly

to an electric system or a genérator is taken suddenly out

40

(148)

of service, every generating unit operating on the entice

system of FPL and connected systems almost instantly

‘experiences a loss in speed, so that the mechanical energy

of rotation of every generator is converted to electric en-

ergy. The sum total of the electric energy so obtained

through conversion from mechanical energy of rotation,

supplies part of the new load or takes the place of some

of the lost generation. The amount of assistance from this

rotational energy source depends on the mass of the rotat-

ing equipment and the difference between the squares of

the speeds for the conditions just prior to and just after

the change in frequency. This conversion of mechanical

energy of rotation has a stabilizing effect such that the

frequency reduction is relatively small. If there were no

energy of rotation in the generators and other equipment,

and if a relatively large power unbalance were suddenly

148

to take place, the drop in frequency would be large and

the electric systems could fall apart electrically before ¢ any

action could be taken to restore the balance.

Q. Does FPL receive any benefits because of its econnec-

tions to a large electrical network, through its ties to neigh-

boring systems? A. Yes it does. By being part of such

network, FPL automatically benefits through better fre-

quency and assistance during emergencies, and also realizes

savings in spinning reserves and in generating reserve

requirements.

Q. Is it important in FPL operations to have as tial

as possible the deviations in frequency from 60 eyeles per

second? A. Yes. - FR

Q. Would vou explain why it is important to -have small

deviation in frequency from 60 evcles per second? A. The

smaller the deviation in frequency the less will be the trans-.

fer of non-scheduled energy between systems; unnecessary

speed-up or slow down in generating equipment will be

41

(148)

nununized; clocks will keep more perfect time; many preci-’

sion industrial operations will be improved; and oscillations

between generators will be reduced .

Q. What happens under an abnormal operating condi-

tion such as that caused by a sudden loss of a large amount

of generating capacity, a short circuit or other operating

difficulty? A. Under abnormal conditions there is a signi-

ficant unbalance between generation and load, which some-

times causes a break in interlocked operations. During

usual system unbalanees there are relatively large

149 |

angular swings between generators which stay interlocked,

causing a substantial swapping of loads between them.

Q. What is the usual relation, on an electric system dh

as that of FPL, between slectrie load and power supply?

_In your answer assume that power supply consists of own

generation plus gross receipts less gross deliveries over

interconnections with other electrie systems. <A. The elee-

tric loads are placed on and taken off the electric system of

FPL at the control of the customers. The FPL power re-

sources, consisting of own generation plus gross receipts

_less gross deliveries, attempt to supply .such loads at a

frequeney of 60 evcles. At a constant frequency of 60 cycles,

power supply equals total load plus losses. When the fre-

quency is increasing, power supply almost equals total load

plus losses plus energy being stored in the rotating equip-

ment. When the frequeney is decreasing, power supply

plus energy being received from the rotating equipment al-

most equals total load plus losses. Total pow er supply serves

total load. There is no practical way of determining the

total electric load, hour by hour, from the customers’ end.

The total hourly load plus losses is determined from a

summation of the Company’s system hourly generation plus

gross hourly receipts from, less gross deliveries s to, other

electric systems.

Q. What type of system does FPL opersiot A. FPL

tS NE.

(151)

operates a three phase system as do all other electric utilj-

. ties to which it is directly and indirectly connected.

Q. How is electric power transmitted in a three phase

system?

| 150 ;

A. Electric power is transmitted by each phase of the three

phase system.

-Q. In what form is electric power transmitted by each

phase of a three phase system? A. Electtfic power is trans-

mittedeby each phase in the form of pulses, there being 120

positive pulses per second for a 60 eycle per second system

or 120 positive pulses and 120 negative pulses per second

per phase for a 60 cycle system. Each of these pulses has

a shape that can be represented by a smooth curve that

can be closely approximated by the square of a sine curve.

Q. What is the relation of the electric power transmitted

by each phase to the total for the three phases?. A. If the

amount of electric power-being transmitted by each phase

of'a three phase circuit is the same, that is, if the phases

are balanced and 120 electrical degrees apart, and the power

pulses have the same magnitudes and shapes, the addition

of the. instantaneous magnitudes of th@® power pulses of

each phase, instant by instant, gives a @pnstant arithmeti-

cal magnitude. This is the basis for the usual expression

that the numerical magnitude of three phase power is a

constant for a balanced three phase circuit. - ;

Q. What is the situation if the three phases are not bal-

anced? A. If the three phases are not balanced, the total

of their power instantaneous magnitudes, if plotted as a

curve against time, would be represented by.a wavy line.

_~ Q. Do three phase generating units have the types of

‘power pulses which von have been describing?

151

A. They do for each phase.

Q. Do three phase loads have the types of power pulses

. that you have been describing? A. They do for each phase,

43

NERY CERIN IW Rte ee

nas SARE A OTAGO NS LEE PS DEERE ODE BPI I ay

(151)

Q. Do three phase and single phase loads of customers

of FPL ha the types of power pulses that vou have been

describing? A. They do for each phase.

Q. What isa wattmeter? A. A wattmeter is an electrical

instrument which measures electric power. The usual watt-

meter is an indicating meter which is relatively sluggish

and it reads the average power during a short time interval.

The hourly average power measurement may be obtained

from an attachment to a watt-hour meter or by taking the

difference between two successive watt-hour readings, one’

hour apart.

Q. Does a wattmeter record the positive and negative

power pulses? A. No. A wattmeter: records the average

of the positive ‘and negative power pulses. ;

- Q. Does a watt-hour meter record the positive and nega-

tive power pulses? A. No.

~ Q. Do electric power system operators have records

which show the ever-varyving dynamic phenomena, charac-

teristics, and operations of electric systems which you de-

scribed in your testimony? A. No. The frequeney chart

‘ shows only the net effect of the events which occur in an

actual 60 eycele electric system; the net! interchange .meter

only \ NJ

152

indlieated short term average effects; and the telemeters on

_the tie lines with other systems-indicate only short term

average effects of actual system operations; other meters

also give onlv averages.

Q. What type of meters are usually installed on electric

systems such as FPL? A. The types of meters usually in-

stalled on electric systems include: indicating ammeters

which measure the short term average electric eurrent of

each phase in terms of the equivalent direct ieurrent; indi-

eating voltmeters which measure the short !term average

voltage in terms of the equivalent voltage of direct current

aa

44

cee yias path sv Sea

™ - "

cf

. (153)

circuits; indicating wattmeters Which measure the short

term average of the’ three phase power which is equitalent

to direct current } power; indicating varmeters which meas-

ure the short term average of the product of the voltage,

current and sine of the angle between the voltage and cur-

rent of each phase—usually summed for all three phases;

watt-hour meters which measure, integrate and add together

the average energy of each of the three phases—iifferences

between hourly readings being used to obtain integrated

hourly power or average hourly power; varhour meters

which measure the hourly reactive power of each phase and

add them together, hour by hour; and three phase watt

recorders. |

Q. Are studies made for electric s¥stems using records

obtained by the types

153

of meters which you described? A.»Yes.

Q. What kind of studies gre usually made using such

records? A. Such records are used to make power flow

‘Studies using either the “steady-state method” or the

, commingled method” of analysis. _

~ Q In making power flow studies using either the “steady-

state method” or the “commingled method” are there ‘any

engineering, technical and other assumptions which under-

line each method? A. Yes, _ a

Q. Are there any methogs and procedures, which apply

toeach method? Yes. —

~ Q..Do you have an understanding of the engineering,

‘technical and other assumptions underlying each method?

A. Yes. 7 .

Q. Do you have an understanding of the methods and-

procedures used in each method? A. Yes.

Q. Would you state the engineering, technical and other

hases on which the “steady-state method” is founded? A.

The “steady-state method”’ is based on certain fundamental.

-

45 '

Vy

(153)

concepts, key assumptions, essential data requirements and

specific procedures. ”_—,

Q. Dr. Jessel, would you please state the basie concepts

_ on which the Genie. state method” is founded? A. The

“steady-state ‘method” is founded on the following basic

engineering concepts: :

\

. + 154

1. Wlien a conductor is carrying electric energy in one

direction at any instant there can be no flow in. the same

conductor in the reverse direction at the same instant:

The electric energy entering any section of a circuit,

except for losses in that ciréuit, must be equal to the elec-

.trie energy leaving that section of the circuit.

3. When energy’ frem different sources is sppplied,

through a common point to two or more loads, the Mative’

proportion from each source in the supplies and in the

deliveries to each load i is the same.

Q. W ould vou state the baste as sumptions which under-

lie the “steady-staté method”? A. The basic assumptions

which underlie.the “steady-state method” are as follows:

1: A dynamie electro-mechanical three-phase electric svs-

tem with ever varving loads, varying generating station

outputs and varving frequency is: replaced by a static, con-

stant frequency, electric network in which the electric loads,

the line loadings and amounts of electric generation are

eonstant during each hour or other time interval under

study.

2. Mach three-phase alternating current cirewit is re-

placed by a single conductor circuit, with a gronnd return.

3 Pach three-phase alternating current bus structure is

replaced by a single conductor bus.

4. A three-phase integrated average hourly kilowatt

rateheted meter

46

(159)

155 |

reading or in lieu thereof a three phase indicating watt-

meter reading is equivalent to the average hourly kilowatt

. 2 . . . °,* @ .

reading for a single condvetor circuit, :

D. Power flow may be tracked through each single con-

ductor bus of the static, constant frequency, electric net-

work, using the point to point tracing principles of direct

current circuits with statie power sources and with steady

power flows. -

6. All kilowatt data are for unity. power factor loads and

sources of power supply.

. * * * + * * a *

158

“Q. Has the “commingled inethod” been used in any power

flow studies Presented at formal proceedings before Hear.

ing Examiners of tlie Commission? A, Yes,

Q. Would vou identify the proceedings in which the “com.

mingled method” has been used in power flow studies? A.

The “commingled method”? has heen used in power. flow

studies in the Penn Water proceeding, Docket No. IT-5915;

reported ine FP@ Reports, Volume 8, page 1: and in the

Wisconsin-Michigan procecd ime, Docket. No. E-6268. pe.

ported in FPC Reports, Volume 10, page 170.

Q. Would vou state on what the “éommingled method”

is founded? A. The “commingled method” js based on

certain fundamental concepts, key assumptions, essential]

data requirements and specific procedures. ; a

~ Q. Dr. Jessel, would you please state the hasie concepts

on which the “commingled method” is founded?

159

A. The “commingled method” is founded on the following

hasie engineering concepts: |

}. When a conductor is carrying electrie energy and

power in one direction at any instant there can be no flow

47

EN

(159)

in the same conductor in the reverse direction at the same

instant.

. The electric energy and power entering any section of

, the circuit, must be equal to the electric energy and power

leaving that section of the circuit.

3. When energy and power from different sources is

supplied through a common point to two or more loads, the -

relative proportion from each source in the supplies and

in the deliveries to each load will be the same.

Q. Would vou state the bast¢ assumptions whtch underlie -

the “commingled method”? A. The basic «assumptions

‘which underlie the “commingled method” are as follows:.

1. A dynamic electro-mechanical three-phase electric svs-

tem with ever varying loads, varying generating station

-outputs and varying frequency is replaced by a static, con-

stant frequency, electric network in which the electric loads,

the line loadings and amounts of electric generation are

constant during each hour or other time intervals under

study.

2. Each three-phase alternating current circuit is re-

placed by a single conductor circuit, with a ground return.

160

3. Each three:phase alternating current bus structure is _.

replaced by a point connecting all incoming and outgoing

single conductor circuits.

4. A three-phase integrated average hourly kilowatt

ratcheted mieter reading, or in lieu thereof a three-phase

indicating wattmeter reading, is equivalent to the average

hourly kilowatt reading for a single conductor circuit. .

5. When two or more single conductor circuits are sup-

plying electric power to the same junction point, such power

is commingled uniformly and the outgoing amount of power

48

(163)

over each single conductor circuit has thesame proportions

of power as the incoming single conductor circuits: that is,

if circuit A contributes 60 percent of:the incoming power to

the junction point and circuit B contributes 40 percent of

the incoming power to the junction point, then the distribu-.

tion of power in each outgoing circuit is comprised of 60

percent A power and 40 ‘percent B power,.uniformly com-

‘mingled. , |

6. All loads and power supply sources do not have the

- same power factor.

oe * * * * * * * *

163

Q. How would you describe the “steady-state method”

and the “commingled method’? of representation of an

actual electric power system? A. Each method is a rough

approximation and simplification of an actual electrie pewer

system. .

Q. Which of the two methods, in your view, more nearly

represents an actual cleetrie power system? A. The “eom-

mingled method” wherein an actual three phase bus is

treated as a point, more. nearly represents an actual three

phase electrie power system because it, in effect, allows for

the differences, instant to instant, among the electrical

characteristics of sources of power supply and loads, and’

provides for power contributions to electric loads more

nearly as they actually take place.

Sd * * * * * * * * *-:

Las RI oo

(167)

sO 167

Rebuttal Testimony of Joseph J. A. Jessel

Q. Would you please state your name? As Joseph JA

Jessel.

2: Did you read the testimony of Mr. Ernest L. Bivans?

XN. Idid. ,

* * * *. * * * * * *

169

Q. Please refer to the first question and answer on page

38 of the prepared testimony of Mr. Bivans. Are you, fa-

miliar with the “system studies method”? A. Yes. It is

just another steady-state approximation of an actual ever-

varving, dvnamic electric system. It is used for system plan-

| nine purposes.

Q. Does the “system studies method” have any concepts

which are peculiar to it? A. Yes. This “system studies

method” includes the mathematie concept of dividing actual

electric power into real and reactive components.

Q. What type of data are recorded in the “system studies

method”? A. At each bus, the voltage and phase angle

are recorded. Also, for each cirenit connecting to the bus,

‘the real and reactive power is recorded. In this method, no

data are shown of real and reactive powerdlows through

the bus. In all studies that I have seen, the bus is treated

as a point because of. absence of data within the bus.

Q. Please. refer to the first question on page-40 of the

prepared testimony of Mr. Bivans and continue to an-

swer to the second: question on page 41. Are you familiar

with the MW and MVAR method of analysis discussed by

Mr. Bivans? A. Tam.

170

Q. Would you state vour views on this method as used

in the testimony to which vou have been referred? A. The

50

Sie

Og ance Se aia gen

é

ee (171)

MW and MVAR method is based on a mathematica} con-

cept of subdividing actual power into two average coin-

ponents. This method is not as representative of actual

system operating as is the “commingled method” wherein

the bus is treated as a point. . *

Q. Please refer now to -the third question and answer

on page 41 of the prepared testimony of Mr. Bivans—do

you have the reference? <A. I do.

Q. Do you agree with the statement of Mr. Bivans? A.

No. The system studies’ method has been used for system

planning and system operating purposes. To the best of

my knowledge, the “system studies method” has never been

used in any proceeding involving the jurisdictional ques-

tion under Part IT of the Federal Power Act.

Q. Please refer to the first question on page 43-and con-

tinue to the answer to the. third question of the prepared

testimony of Mr. Bivans. What types of data are used in

the power flows described by Mr. Bivans? ‘A. The data

used are average figures which are equivalent to direct cur-

rent values. These figures are merely steady-state approxi-

mations of actual alternating current power quantities.

-

171

Q. Would you refer to the first question on page 44 and

continue to the answer to the first question on page 45 of

the prepared testimony of Mr. Bivans. Do you have the

reference? A. I do. : | :

Q. What are your comments, if any, on the analysis to

which you are referred? A. This is merely an application

of the “steady-state method” cf analysis. It is a rough ap-

_ proximation of an actual ever-varying dynamic electric

svstem. This analysis does not prove that energy from

Deland West does not get to the Florida Power & Light

Company system. . :

he

(172)

172.

Rebuttal Testimony of Cleve R. J acobsen.

A. Please state yousname. A. My name is Cleve R. J acob-

‘sen. : .

‘ ‘

* < * * * * » : * . * . * *

: .

179

Q..Mr. Jacobsen. Is the definition of “power pool” as

defined in your Exhibit No. 29 necessarily.a FPC Staff

definition? A. No. It is a definition that in my opinion

described the “Florida Pool,” and is similar to the definition

of “power pool” listed in.a pamphlet published by the Edi-

son Electrie Institute, dated 1961, “Glossary of Eleetrie

Utility Terms”. There are many “Pool” categories. I will

briefly describe a few below. |

(1) Interconnected electric atility systems with tie-

in lines normally in operation so that spinning reserve

is automatically available during the first few seconds

following a disturbance.

180

-(2) Voluntary supply of: power to other systems to

meet. emergencies but with or without obligation to

deliver power within a fixed time after occurrence of

emergency. .

(3) Obligatory pool assistance to be made available

with no more delay than, say, five minutes.

(4) Power transactions contracted for in advance

and not dependent on daily or hourly fluctations in the

cost of producing power.

, (5) Occasional or regular daily or hourly interchange

of power for the purpose. of -reducing costs, whether

or not all areas in the pool are under control of cen-’

tral load dispatch office.

o2

(183)

(6) Free flowing ties with generating capacity under

control of a central load dispatch office.

(7) Joint planning of some or all of the major trans-

mission. lines and generating stations’in order to re-

duce overall costs by staggering of construction sched-

ules, sharing reserve capacity, coordinating mainte-

nance schedule, ete. _ |

The overall coordination of the “Florida Pool” is attained

by mutual and cooperative agreement. There is no central-

ized directorate or administrative nucleus to direct day-to-

_ day operations; however, the association ‘of the adjacent

power groups that comprise the “Florida Poo]” is, as the

case of many “pools” in the United States predicated upon

informal understandings and procedural arrangements.

~ a 181 ,

_ Q. Mr. Jacobsen. Does the definition of “power pool”

appear in the Federal Power Commission’s (FPC) “Glos-

sary of Important Power and Rate Terms Abbreviations,

and Units of Measurement”? A. Yes.

Q. Will vou State the definition of “power pool” as it ap-

pears in the FPC Glossary of abbreviations? A. Yes. It

is found on page 12 and states, “134. Power Pool, Electric—

two or more electric systems interconnected and operating

on a regional basis.” |

Q. Mr. Jacobsen. Do you know of any electric power pools

in the United States that function without a formal agree-

ment or contract but more or less operate on a cooperative

basis? A. Yes. Among others, the Northwest Power Pool

is such a power pool.

_* * * * * «* * * * +

183

Staff Counsel: Mr. Examiner. The Staff requests that

the exhibit as identified bv Mr. Jacobsen be marked for

identification as Staff Exhibit No. 32.

| 53

(183) . 7

Q. Mr. Jacobsen.\Please ‘describe the ‘diagram, page 1,

of this exhibit. A. This is a simplifiéd one line diagram

of a portion of the F.P. Corp. System that among other

things, shows transinission lines, substation buses, and_

direction of electric power flow. The purpose of the diagram

is to show the transmission lines and substation buses over

which power flowed from FPL, commingled with F.P. Corp.

generated electric power and flowed over F.P. Corp. 120kv

transmission lines into the Georgia Power Company ‘sys--

tem. The arrows adjacent tothe transmission lines indicate

the direction power flowed each*day and hour that was -

analyzed. The color of the arrow, as designated in the

legend, indicates whether. the power that flowed was FPL -

generated power flow, commingled (FPL and F.P. Corp.)

power flow or unidentified power flow.

Q. Mr. Jacobsen. Please describe the tabulated data

shown on page 2 of Staff Exhibit No. 32. A. This page

of tabuiated data indicates, among other things, the 3

days and hours of these days, that power flow was studied.

The data supports the conclusion that FPL generated

power and F.P. Corp. ,

184

generated power commingled at the F.P. Corp. Turner

Plant and flowed over the. F.P. Corp.’s 120 kv transmission

lines into the Georgia Power Company System. Page 2 also

shows the direction and magnitude of power flow over spe-

cific transmission lines of the F.P. Corp. and FPL Systems.

Q. What information did you use in preparing Staff

Exhibit No. 32? ‘A. The information that I used was ob-

tained from System maps in FPC Forms No. 12, Power

System Stateme nts, filed by FPL and P. P. Corp., and F.P,-

- Corp. daily operating reports.

Q. What F.P. Corp. daily operating reports did \ you use

in preparing Exhibit No. 32? A. I used copies of the

“Turner Plant-Daily Operation Report”; the “Jasper Sub-

o4 -

. ~

—_

Nu

e’

. sidered. These tié-line interconnections are the Kettle

Creek-Jasper and ‘Pine Grove-Jasper 120kv transmission

reports in detail beginning on page 4 of his testimony.

‘mission tie-line interconnections between Georgia Power

bm eset tne SRR Pcie PO LAP as PR

(185)

station-Daily Operating Report”;.the “Silver Springs Sub-

station-Daily Operating Report”: and the “Fort White Sub- _

station-Daily Operating Report” for July 8, August 12 and

August 17, 1964. There was a total of 12° reports studied.

Staff Counsel: Mr. Examiner, The Staff requests that the

12 daily operating reports described by. Mr. Jacobsen be

marked for identification as Staff Exhibit No. 33:

Q. Where did you obtain the F.P. Corp. daily operating

reports? A. These reports were obtained from F.P. Corp.

earliér*this vear for study in connection with the prepara-

tion of direct testimony filed in this proceeding with the

exception of the “Jasper Substation-Daily Operating Re-.

port” which was obtained from FP. Corp. during the week

of August 23, 1965.

185

Q. Mr. Jacobsen. Has the primary information shown

on the face of these reports of Exhibit No. 33 been dis-

cussed in testimony previously given in this proceeding ?

A. Yes. Mr. Clark, a FPC. Staff. witness, describes these

Q. Mr. Jacobsen. Referring to Staff Exhibits No. 32-and

33 will you deseribe your analysis of power flow? A. Yes.

For the purpose of this analysis, only the two 120kv trans-

Company and F.P. Corp.’s Jasper substation were con-— )

tie-lines. On days and hours as shown on Staff Exhibit No.

32 the “Turner Plant-Daily Operation Report” shows that

power flowed from the F.P. Corp. Sanford Plant bus to

the Turner Plant bus over the Sanford-Turner 120kv.trans-

mission line, reference Point 1. The “Turner Plant-Daily

Operation Report” shows for the same days and hours that \

(F.P. Corp. and FPL)}-commingled power flowed from the __

Turner Plant bus to, the Silver Springs substation bus over

a9)

(185)

the .Turner Plant-Silver Springs 120kv transmission line,

reference Point 2. The “Silver Springs Substation Daily

-. Operating Report” for the same days and hours show that .

(F.P: Corp.-FPL) commingled electric power was flowing

into the Silver Springs substation bus over the Turner

Plant-Silver Springs 120kv transmission line, reference

Point 3. It also shows that for the same days and hours.

186

(F.P. Corp.-FPL) commingled power flowed out of the

Silver Springs substation bus toward the Fort White sub-

station bus over the Silver Springs-Fort White 120kv trans-

mission line, reference Point 4.

The “Fort White Substation-Daily Operating Report”

shows for the samé days and hour that commingled (F.P.

Corp.-FPL) electric power flowed into the Fort White

substation bus from Silver Springs substation over the

Fort White-Silver Springs 120kv transmission line, refer-.

ence Point 5. It also shows that commingled (F.P. Corp.-

FPL power flowed out of the Fort White substation bus

over both the east and west circuits to the Jasper substation

over the Fort White-Jasper 115kv transmission lines, refer-

ence Points 6.and 7.

The “Jasper Substation-Daily Operating Report” shows

for the samé days and hours that commingled (F.P. Corp.-

- FPL) power flowed from Fort White substation over both

the east and west circuits over the Fort White-Jasper 120kv

transmission lines, reference Points 8 and 9. It also shows

_ for the same days and hours that commingled (F.P. Corp.-

FPL) power flowed out of the Jasper substation bus to the

Georgia Power Company System over’ the Jasper-Pine

Grove and Jasper-Kettle Creek 120kv transmission tie-lines,

reference Points 11 and 12.

187

Q: Mr. Jacobsen. Have you read Mr. Bivans’ testimony

beginning on page 30 related to his Exhibit No. 4 which is

06

(188)

a diagram, entitled “Single Conductor. Diagram” and his

testimony beginning on page 32 describing his method of

making a power flow analysis? A. Yes.

Q. Do you concur in Mr. Bivans’ testimony? <A. No.

Q. Do you have any comments on his testimony?. A. Yes.

My analysis of electric power flows from Georgia Power

Company to FPL as shown on my Exhibits 18 and 19 and

electric power flows from FPL to Georgia Power Company

as shown on my Exhibits No. 32 and 33 does not require the

rigorous approach that Mr. Bivans has suggested. -Mr.

Bivans appears to be describing ‘a method of identifying |

power flow to each individual load. Whereas my analysis. is

concerned with elettric power flow from point to point.

One point being the tie-points on the Georgia Power Com-

pany tie lines to the Jasper substation and the other point

being the tie-point on the Turner-Sanford tie line.

My analysis involves ‘a straight through electric power

flow between Georgia Power Company and FPL over F.P.

. Corp. high voltage transmission lines. The magnitude of

these power flows, is large enough that the load taps from

the major substations used in my analysis do not affect

the results of the study. My analysis also considers the bus

as .a.point or reservoir and that electric power is com-

mingled on the buses.

In making my analysis I was aware of the flow of power _

from the Suwannee Plant bus to both the J asper substation

_bus and to the Fort White substation bus, where it com-

mingled with power on these buses. I have taken into con-

sideration this power flow and have indicated it on the

diagram in my Exhibit No. 18. I have shown the power flow

from the Suwannee Plant as unidentified; however there

are times that power flowed into the Suwannee Plant bus

from Scholz Plant bus which is often commingled out-of-

_ State electric power from Alabama Power Company.

o7

A rl

MCNGTINIS,

2 ta GRO KH

LAA RENIN RCSA EMR REA

ci aie dete

(188)

I have also studied and noted on the diagram in my

Exhibit No. 18 that power flow on the two lines from Fort

White substation to the Inglis Plant is always commingled

power flowing out of the Fort White substation bus toward

the Inglis Plant-for the days and hours studied. This now

does not affect the results of my analysis.

My analysis shows that Georgia Power Company out-of-

state electric power is commingled with the F.P. Corp.

Suwannee Plant generated power (which may be ‘com-

‘mingled with out-of-state power from the Scholz line or

the Pine Grove-Suwannee line) at the Jasper substation bus

and flows southward ‘at the speed of 186,000 miles per

second to the Turner Plant where it is further commingled

with F:P. Corp. generated power at Turner Plant, and

_ flows on to the FPL Sanford Plant over the Turner-Sanford

tie line.

Q. Mr. Jacobsen. Have you examined Mr. Bivans’ Ex-

hibit No. B-6 and studied his testimony pertaining to his

exhibit beginning with the last question on page 43?

189

“A. Yes.

Q. Do .y@u concur in his festinony’ A. No. Primarily

because he has considered the Turner Plant bus as a trans-

- mission line instead of a point or reservoir.

Q. Mr. Jacobsen. In your.study and analysis did you

consider the substation buses as a point or reservoir, or

did you treat the substation buses as a transmission line?

A. I considered the substation buses as a point or reser-

voir. | a |

Q. Do vou know of any eléctrical engineers besides -

Dr. Jessel who treat the bus as a point or reservoir and

have so testified in proceedings -before the Federal Power

Commission? A. Yes. Mr. Stanley W. Roland, FPC staff

witness in the Penn Water proceeding, FPC Docket No.

IT-5915 and Dr. William Lewis, a witness in the Jndiana &

-

08

(201)

Michigan Electric Company proceeding, FPC Docket No.

E-7089. Dr. Lewis was a professor of Klectrical Power

Systems at Illinois Institute of Technology in Chicago,

Illinois.

Q. Mr. Jacobsen. If the Turner Plant bus was treated

as a point or reservoir, would this treatment make Mr.

- Bivans’ analysis of power flow on this bus valid? A. His

analysis would not be valid if he.treated the bus as a

reservoir or point.

* * * * + _ * * * . *

200

Testimony of Ben H. Fuqua

Q. Please state your name and address. A. My name

is Ben H. Fuqua. I reside at 1530 San Rafael Avenue,

Coral Gables, Florida.

Q. What is your position with the Florida Power & Light

Company? A. Vice President.

Q. Please give your education and employment back-

ground. <A. I ama graduate of the University of Florida,

and received a Bachelor of Science degree with a Scientific

Group major in such subjects as mathematics, chemistry

and physics. I also attended Duke University and Florida

State University, specializing at the latter institution in

public administration. From 1933 until 1946, I was in the

investment banking business in Florida, except for the

years 1942-1945 inclusive, when I. served in the United

States Navy. Iwas a Member of the Florida Legislature

‘from Manatee County in the 1937 Session. I was elected

Chief Clerk of the Florida Legislature in 1938 and served

in that capacity during the 1939 and 1941 Sessions, con-

tinuing in that office until I entered the

201

United States Navy. From 1947 until 1949 I was Executive

Assistant and Legislative Secretary to The Honorable

og

(201)

Millard F. Caldwell, who was then the Governor of Florida.

I was employed by the Florida Power & Light Company

on January 1, 1949 and have been with that Company con-

tinuously since that date. I was elected a Vice President of

the Company in the spring of 1956 and have general

charge of what is known as the “Corporate” affairs of the

Company. These. duties would include such matters as

claims, taxes, right-of-way, the administration of damage

suits, condemnation suits, administration of relations and

contacts with various gov ernmental agencies, including reg-

ulatory bodies.

* * * * * * * * . *

a in

a

“2 202

Q. Will vou please recite the history of this matter lead-

‘ing up to the present Order of Investigation by the FPC.

A. During the vears 1941 and 1942, the FPC determined —

that certain emergencies existed under Section 202(c) of

the Federal Power Act and ordered on their own initiative

eertatn interconnections between Florida Power & Light

Company and other electric suppliers, notably the Florida -

Power Corporation. Chairman Leland Olds wrote at the

time that such interconnection “will not in and of itself

bring the Florida Power & Light Company within the

jurisdiction of the Federal Power Commission.”

* * *. * * oo» * *. % *

A. This interconnection was in operation for more than

a decade, until in 1953 the FPC made a finding that the

emergency no longer existed and stated that they intended

to

203 .

terminate the interconnection orders.

Prior to such termination, however, the Florida Power

& Light Company was given an opportunity to appear be-

fore the Commission Staff. At that time, representatives

60

(204)

of the Company, of which I was one, were able to demon-

strate to the satisfaction of the Staff that the intercon-

nections were operated in such a way so that there would:

be no occasion for the Staff to reeommend the initiation

of proceedings to have Florida Power & Light ‘Company

determined to be a public utility under the Federal Power

Act by reason of the maintenance of the interconnections,

so long as the stated operating conditions existed. Ac-

tually the issue of the possible interstate flow of- power

revolved around only one interconnection, viz. between

Florida Power & Light Company and the Florida. Power

Corporation at White Springs, Florida. This emergency

- interconnection has since been dismantled as testified to by

Mr. Bivans.:The intereonnection near Sanford was not

considered a factor since it is lecated between two large

-generating plants, one belong: ~¢ to Florida Power & Light

Company and the other ownea dy the Florida Power Cor-

poration, and it is more than 150 miles from the Georgia

’ state line.

The meeting between representatives of Florida Power

& Light Company and members of the FPC Staff occurred

in

204

January 1954. On January 25, 1954, I wrote to the FPC

setting: forth Florida Power & Light Company’s under-

standing of that meeting, and on February 24, 1954, the

Secretary of the FPC replied:

“Your letter implies that the staff had agreed that

the continued operation of the interconnections would

not make Floride Power & Light Company a ‘public

utility’ under the Federal Power Act. This, the staff

feels, is not quite accurate. Its understanding was that

you felt from the data that you then had for the opera-

tions during the month of December, 1953, that no

energy flowed overethe White Springs interconnection

61

(204)

in interstate commerce, with the possible exception of

very infrequent occasions in which very minor amounts

of energy might conceivably be tracéable interstate,

and that such flows would be even more trivial on an

annual basis. The staff’s position was that if that were

true, and so long as that condition continued, there

would be no occasion for the staff to recommend the

initiation of proceedings to have Florida Power &

. Light Company determined to be a ‘public utility’

under the Federal Power Act by reason of the mainte-

nance of this interconnection. Of course, as you were

advised, the staff’s position is in no way binding upon

the Commission.”

‘In July 1954, the EPC issued an order terminating the

prior emergency orders requiring interconnection of fa-

_eilities.

# * * * * * * * * 2

205

A. Nothing more transpired concerning these intercon-

nections or the matter of FPC jurisdiction until a letter

was received from the FPC by Florida Power & Light

Company dated October 3, 1963. This letter stated that

reports made by the Company. to the FPC indicated that

it “currently transmits or interchanges and sells electric

energy in interstate commerce at wholesale for resale,”

and that there were no rate schedules on file with the Com- |

mission. It was stated that the matter was being brought

up prior to Staff recommendations for possible Commis-

sion action so that the Company could file its appropriate

rate schedules or within 30 days give the legal and factual

bases why the Company did not agree with the Commis-

sion Staff’s conclusions. The Florida Power & Light Com-

pany stated that it did not agree with the Staff’s conclu-

sions, and after some postponement, two conferences were

62

' -

(214).

held with the Staff concerning this issue, in which I par-

ticipated. | |

* * * *- * - €£ ~~ «* * * *

— 209

Q. Mr. Fuqua, you stated that Florida Power & Light

Company undertakes to stand on its own feet with regard

to its energy requirements and reserves.” Why is this done?

A. Normal weather peaks occur usually in the period Au-

gust to October. each year. Historically, these are the

months which show the largest incidence of. severe hurri-

canes during all of the time that records are available.

y

* * * * * * * * k *

210

A. It can, therefore, be readily seen that with our peak

loads and the peak of the hurricane Season occurring simul-

taneously, it becomes a matter of dire necessity for us to

be able to stand on our own feet with regard to our energy

requirements and reserves. Hurricanes are unpredictable

in their behavior. As a matter of fact, it is possible for us,

in dire necessity, to segment or sectionalize our Company

so that each segment or section could be self sufficient and

stand on its own resources. These segments or sections

generally would he the west coast, the southeast coast,

which accounts for approximately 75 percent of our load,

and, finally, the northern region.

ba ~ * * * * * * * *

214

Q. Have you an estimate of what it would cost Florida

Power & Light Company initially and on an annual basis

_afterward if it became subject to FPC jurisdiction under

the Federal Power Act? (A. Yes, T have.

Q. Please state what_the estimates are. and how they

were made. A. I hae. ga documents on these subjects.

' The first one is entitld “Ksta ated Initial Costs of Making

63

— PIT DIAS

(214)

Minute Property Evaluations. and Setting Up New Ac-

counting Techniques Under Federal Power Commission

Jurisdiction.” This estimate was prepared by our staff, -

based on the experience of other companies with whom we

- have been in contact. It is obviously an expensive require-

ment. In fact; in the case of our neighboring ‘utility, the

Florida Power Corporation in St. Petersburg, Florida, it

is our understanding that at the time they made an inven-

tory of the then $40 million plant account to carry out the

accounting refinements required by the FPC, it took the

equivalent of 50 people a |

215

period of three years to accomplish this. Thus, you can

see that with our plant account in service of about $840

million as of June 1965, such an undertaking would be

very costly. Based on the estimation and information

gathered by our staff, we conclude that this figure could

amount to as much as $4 million to $6 million.

‘The second document is entitled “Estimated Annual

Costs of Maintaining Accounting Records Under FPC

Regulation.” This document sets forth in detail the break-

down of: these estimated costs if we are forced to follow

the present refinements in accounting required by the FPC.

This estimated amount is $516,750. This total. annual cost

would cover only the salaries and fringe benefits of addi-

tional personnel needed to carry on the necessary ac-

counting records.

In addition, we are advised that the FPC ‘has now

issued even newer procedures and schedules of audit pro-

grams. We have seen some of the outlines of the scope

and character of these examinations. They are most minute

and exhaustive in nature, and serve only to duplicate

and overlap similar examinations and audits of the Florida

Public Service Commission. They obviously will require

several FPC Staff members, tying up a large number of

64

(222).

*

_ Florida Power & Light Company personnel and will:

require .

216

several months to complete. There is no indication as to.

how often these audits will be made. The tying up of

our key personnel in order to supply data, in any event,

is a great additiona] burden of expense, the amount. of

which we are unable to estimate.

Mr. Meriman: Mr. Examiner, I ask that there be marked

for identification as Exhibit No. 40.and Exhibit No. 41

the documents identified by Mr. Fuqua, the first relating

to estimated initial costs and the second relating to esti-

mated annual cost.

° * * * * *. * * * *

222

Testimony of Ernest L. Bivans

Q. Please state your name and address. A. Ernest L.

Bivans, 380 Glenridge Road, Key Biscayne, Florida.

Q. What is vour position with the Florida Pow er & Light

Company? A. Assistant Chief Engineer.

Q. Please give us your education and employment back-

ground. <A. |] graduated from the University of Florida

in May, 1942 with a-Degree of Bachelor of Electrical En-

gineering. Upon graduation, I entered the service of the

U.S. Army Signal Corps. In the service.I attended radar

schools at Camp Murphy, Florida; Radiation Laboratory

M.I.T. in Boston; and at Camp Evans in Belmar, New

Jersey. I served one year in. Panama where I wasin charge

of operating several radar units. I also served one and

one-half vears in Kurope operating various types of radar.

In November, 1945 I was employed by the Florida Power

& Light Company as a Junior Engineer. During the next

several years I progressed to Assistant Engineer, Engi-

neer, Senior Kngineer and Section Head of System Plan-

65

(222)

ning. During this pettod- I performed various phases of

engineering which included system planning for distribu-

tion, transmission and generation facilities, preparation of

construction budgets, underground engineering, distribu-

tion, transmission and substation engineering, relay engi-

neering, preparation

223

and maintenance of construction standards for transmis-

sion, distribution and substation facilities and preparation

and maintenance of the Standard Material Catalog.

In 1951 I attended in Schenectady, New York, the Gen-

eral Electric Company’s one-year course in “Advanced

Power System Engineering.” In March 1960 I was pro-

moted to my present position of Assistant Chief Engineer.

Q. Do you belong to any engineering societies, and, if

/so, please name them and the grade of membership you

hold? A. I ama registered Professional Engineer in the

State of Florida, a member of the National Society of Pro-

fessional Engineers, ‘a senior member of the Florida Engi-

neering Society, and a senior member of the Institute of

Electrical and Electronic Engineers,

A, As pointed out by Mr. Jacobsen, FPL operates solely .

within the State of Florida. All of the dispatching of FPL’s

generation is done by FPL in Florida and FPL cgntrols

no generation owned or operated by anyone else. Further,

FPL has no firm power contracts to bity ‘or sell either

directly or indirectly from. or to any company ‘in or

outside the State of Florida. FPL is interconnected only

with Florida Power .

224

Corporation (F. P. Corp.), Tampa Elecrtic Company |

(TEC), the Orlando Utilities Commission (Orlando), and

the City of Jacksonville (Jacksonville).

66

(226)

To aid the Examiner in understanding the FPL system

and the points at which it is interconnected with the above-

-mentioned systems, I will refer to.a map entitled “Sub-

station and Transmission System, Florida Power & Light

Company,” dated April 21, 1965. .

Mr. Meriman: Mr. Examiner, I ask that there be marked -

for identification as Exhibit No. 42 (B-1). the map identi-

fied by Mr. Bivans.

Q. Mr. Bivans, please describe this map A. The legend

appearing in the lower middle part of the map identifies

the facilities shown. The points of interconnection are

' shown in green tircles, The two interconnections with

Jacksonville are shown in the upper right portion of

the map. The two interconnections with F. P. Corp. at

Sanford and Brevard appear on the right side of the

map at about the middle of the page. The sole inter-

connection with Orlanda is shown on the map above

and slightly. to the right of Brévard, and the sole inter-

connection with TEC is on the west side of the State at the

Hillsborough- Manatee County line above Bradenton. This

appears in about the center of the map.

Q. How far from the Georgia-Florida State line is the

Sanford interconnection between FPL and F. P. Corp.? .

A. Approximately 180 miles, calculated from transmission

line mileages.

Q. Do F. P. Corp., TEC, ‘Orlando or Jaeksonville own or

- operate any electric facilities of any sort outside of. the

State of Florida? A. Not to the best of my knowledge.

*' * :* * * * * * + *

226

Q. Mr. Bivans, in his testimony Mr. Jacobsen referred

to the Florida Operating Committee. Who are the mem-

bers and what is the function of .that Committee?

67

Baha ay ee —F> ae “pty See ee ee ee ee eee Se oes Ti ee ~~ ews Le AS UREN HOSE + —

. *

(227)

227

A. The Florida Operating Committee is comprised of FPL,

F. P. Corp., and TEC. The Committee was set up in 1959

as an informal group to consider mutual operating prob-

lems relating to the interconnected operation of the three

systems. Representatives from Orlando and Jacksonville

have attended meetings of the Committee. The Committee

does not have any authority to make contracts, supervise

the operations of the systems of any of the members, or to

implement its recommendations or studies.

Q. On page. 7 of his testimony, Mr. Jacobsen defined

“electric system.” Please read that definition. A. He de-

fines “electric system” as “the. physically connected gen-

eration, transmission, distribution, and other facilities op-

erated as an integral unit under one control, management,

or operating supervision.” —_~

- Q. On page 80 of his testimony Mr. Jacobsen described

Staff Exhibit No. 29, a 5-page document entitled “Defini-

tion of Terms Electric Power Systems.” Are you familiar

with this exhibit? A. Yes, I have read the document.

Q. Please read the definition P2 covering “Power Sys-

a tem.” <A. “A power system is a group of one or more

generating sources and/or connecting transmission lines

operated under common management or supervision to

supply a load.” |

Q. Now, would you read definition 17 covering “Inter-.

connected System”. “A. “An interconnected: system con-

sists of two or more individual power systems normally —,

operating in synchronism.”

Q. Now read definition Pl covering “Power Pool”. A.

“A power pool is two or more electric systems intercon-

nected and coordinated to supply power in the most eco-

nomical manner for their

228

combined load requirements and maintenance program.”

Q. Now, Mr. Bivans, which of these definitions describes

68

(229)

the FPL system? A. Power system, or what Mr. Jacobsen

calls an “electric system”.

Q. Which of these definitions describes the ‘operations

of the systems comprising the Florida Operating Commit-

tee? A. Interconnected System.

Q. Why do you say this? -A. By definition P1 referred

to above, a power pool is “two or more electric systems in-

terconnected and coordinated to supply power in the most

economical manner for their combined load requirements

and maintenance program”, whereas , an interconnected sys-

tem consists of two or more individusl power systems nor-

mally operated in synchronism. FPL, F. P. Corp., TEC,

Orlando and Jacksonville each operate their own individual

system in the mosf economical manner consistent with their

own individual requirements and policies and not under t

supervision or direction of the Florida Operating Com-

mittee. All that the Florida Operating Committee does,

that in any way falls within the definition of “Power Pool”,

is to coordinate spinning reserves among the five intercon-

nected systems, and to coordinate overhaul schedules of the

five systems so that too many large units are not out of

service at the same time. This is on a voluntary basis with

the Committee having no enforcement power.

Q. At page.25 Mr. Jacobsen discusses transactions be-

twen FPL and TEC, and FPL and F: P. Corp. Does FPL

buy firm power from, or sell firm power to, cither of these -

companies or Orlando or Jacksonville? A. No, all sched-

uled power transactions are on a So- called “when, as and

if basis”.

229

Q. Does FPL buy economy energy from, or sell economy

energy to, F. P. Corp.,: TEC, Orlando or Jacksonville?

A. No, it does not.

Q. Mr. Bivans, at numerous places in his testimony,

commencing at page 7, Mr. Jacobsen refers to the. Florida

69

(229)

Operating Committee as the “Florida Pool”, which he

states is comprised of FPL, F. P. Corp., TEC, Orlando

and Jacksonville. He also notes that in some minutes of

meetings of the Florida Operating Committee included in

Exhibit No. 3, the’ term ‘‘Florida: Pool’’ is used. - Please

comment on this, and just so thére will be no misunder-

standing, please define the term “Florida Pool”. <A. Al-

though neither the Florida Operating Committee nor the

five interconnected electric systems fits Mr. Jacobsen’s defi-

nition of “power pool” set forth in Staff Exhibit No. 29 and

quoted above by me, I am aware that some people have

referred to the five interconnected electric systems—FPL,

F. P. Corp., TEC, Orlando and Jacksonville—as the “Flor-

ida Pool”. There are no “pooling” or multiparty contracts

or commitments among these systems. It is an informal

arrangement for the purpose of helping each other in

eases of emergency. Our participation in the so-called

“Florida Pool” does not imply or mean that we have any

firm power contracts to buy from, or sell to, either directly

or indirectly from or to anv company in or outside the

State, or that we are dependent upon other companies

for our requirements, or that our system is dispatched

from a central office with other systems. Any difference

of opinion depends upon the definition used. It is clear that

the Florida interconnected system is only that and ean-

not -be a ‘‘pool’’ under the Staff’s own PI’ definition of

“nower pool”. °

230

* * * * * * * * * *

Q. How is such inadvertent aceounted for? A. Each

svstem is responsible for the accounting of its own inad-

‘vertent energy flow to and from other systems. This is

made evident insofar as FPL is concerned by Exhibit No.

26, “System Dispatchers Interchange Log”, which covers all

interchange transactions hour by hour between FPL and

70

(231)

other systems both scheduled and inadvertent. It also shows

FPL’s cumulative inadvertent balance.

Q. What does F. P. Corp. do with regard to accounting

for daily inadvertent energy flow? A. In order to elimi-

nate the necessity of each of. the five dispatchers having

to check with the dispatchers of the other systems to verify

that the inadvertent balances for all systems totals zero,

F. P. Corp. agreed to coordinate the reporting of inad-

vertent for all systems. Each of the system dispatchers re-

ports to the F. P. Corp. system dispatcher three times daily °

(S a.m., 10 p.m. and 12 Midnight) the following balances:

net. interchange, scheduled interchange and inadvertent

interchange, | |

231

F. P. Corp. records these balances and then checks to see

that the total of the inadvertent balances for all five SVS-

tems is zero. If it is not, F. P. Corp. contacts the other

systems in order that the error can be located and cor-

rected.

ee as * * * * * * *

_ FPL generating expansion has always been planned and

installed solely by FPL to serve its own load. All transmis-

sion lines which have been constructed by: FPL that do

not connect with facilities of a neighbor are planned and

constructed solely by FPL without consultation with any

member of the Florida Operating Committee. Any new tie

line FPL has constructed connecting with a neighbor has

been built pursuant to-an agreement solely between the

two companies, independent of the Florida Operating Com-

mittee. An informational report on construction status of

new plants and transmission lines is made at meetings of*

the Florida Operating Committee.

232

* * * . * * * * * *

A. LT have prepared a curve showing FPL system load as

compared to FPL generating capability for the 10-year pe-

riod 1960 through 1969, which shows the past history as

well as our forecast of loads and generating capability

for the immediate future.

Mr. Merriman. Mr. Examiner, I ask that there be marked

for identification as Exhibit No. 483 (B-2) the one-page

curve entitled “Florida Power & Light Company—Compar-

ison of Generating Capability and Peak Loads (1960-1969) ”,

identified hy Mr. Bivans. |

Q. Mr. Bivans, what does this curve show with regard

to the relationship of svstem load and generating capa- —

bilitv? A. Tt shows that I'PL has projected its generating

capability to meet its loads without dependence upon

other electric systems in the State of Florida or systems

outside the State of Florida. For example, in the spring

‘of 1965, FPL added two 482,000 kw units, one at Port

Everglades and the other at Cape Kennedy. Therefore, the

present capability is about 850,00 kw in excess of the fore-

casted Summer peak load for 1965 and about 600,000 kw

in excess of the forecasted cold weather peak for the coming

winter. FPL also has under construction two 432,000 kw

units at Turkey Point, south of Miami, one unit of which

is scheduled to be in operation November, 1966 and the ,

second of which is scheduled

233

to. be in operation in November, 1967. A 432,000 kw unit .

is under consideration for operation in the fall of 1968

to meet the 1969 loads. As vot ean see, FPL plans-to have

installed sufficient capacity to give firm capacity for its

summer and normal winter weather peak loads and to have

total capacity for short time extreme cold weather peaks

(which do not occur every year). It is clear from: Exhibit

No. 43 (B-2), the FPL has had adequate capacity for all

loads that have been experienced.

~l

bo

(241)

Q. Mr. Bivans, how does FPL design its system generat-

_ Ing capacity to meet cold weather peaks? A. On page 26

of FPL’s Form 12 for 1964, there is a statement that

“Our system peak usually occurs \in winter and is influ-

enced to a considerable extent by ‘temperature. No re-

serve capacity is provided to meet peaks caused by extreme

cold weather.’’

| 239

Q. In the case of the loss of about 580 mw of genera-

tion by a midwestern utility on February 17, 1965, discussed

by Mr. Jacobsen on page 60 of his testunony, what was

FPL’s biased scheduled net interchange approximately 30

seconds after the initial frequency drop? A. As shown in

Iixhibit No. SA, the FPL frequency was 59.98 evcles im-

mediately following the momentary drop. FPL’s biased’

- scheduled net interchange was thus & mw.

Q. Now, Mr. Bivans, was it possible for any: part of

IPL ’s biased scheduled net interchange of 8 mw to flow

through F: P. Corp.'s system and across the state line

into Georgia? <A. No.

240

Q. Is FPL interconnected with the facilities of Georgia

Power or any other electric system in another State? A.

No, it is not.

Q. Does FPL buy power from or sell power to Georgia

Power or any other electric system in another State?

_ A. No, it does not.

Q. Does FPL have any arrangement with F. P. Corp.

and Southern Company? A. No, it does not.

241

Q. Was FPL invited to participate in the seasonal power

interchange between F. P. Corp. ¢ » “‘outhern Company?

A. No, it was not. |

Q. Does FPL derive any benef... n the seasonal in-

terchange between F. P. Corp. an. - Southern Company?

73

the Sib BOERNE AOL OED NG, PIEPER Le EAN? SES BRE A IO

”@

.

(241) .

A. No, because as I stated previously FPL’s own genera- |

tion is planned to meet its own load without regard to this

or any other external source of. power, either within or

outside the State of Florida.

Q. Why does FPL plan its generation this way? A.

About 75% of F'PL’s load is along the South Florida coast

from West Palm Beach.to Miami. It is approximately 400

miles from Miami to the Georgia-Florida State line, plus

several hundred additional miles further north or west

to the nearest major source of low cost fuel for generation.

Therefore, due to the distances involved and the transmis-

sion lines that would be. required, it is neither practical

nor economical for FPL to purchase energy generated by

others at these remote locations in order to supply FPL’s

load or any part thereof. Furthermore, due to high fre-

queney of lightning’ storms and hurricanes in Florida,

transmission of large blocks of power over great distances

would not be dependable. Mr. Fuqua’s testimony covers

the history of hurricanes that affected Florida.

245

Second, FPL does not depend on any other member of the

ISG in order to match its system generation and system

load. Neither does the FPL operate in such a manner

as to be dependent on the ISG or any out-of-state member

thereof. FPL’s only contribution to the ISG is to operate

in synchronism and assist its neighbors in the event of

emergencies. The amount of aid that FPL can contribute

by displacement through our neighbors to out-of-state -

members of the ISG who might be in trouble is negligible.

This is true because FPL’s response to loss of generation

by out-of-state members of ISG is approximately the ratio

of FPL’@peak load to the total peak load of all members

of ISG.

°

74

(250)

Furthermore this small contribution would be absorbed

by neighboring systems in Florida and would never reach

the state line some 180 miles away.

For example, as I previously testified, for the loss of the

080 mw of generation by a midwestekn utility system as

mentioned by Mr. Jacobsen on page 60 of his testimony,

FPL’s biased scheduled net interchange was 8 mw, which

hy no stretch of anyone’s imagination, could be eotisidered

to have crossed the state line let alone travel all the way

to the Midwest. Electric companies have operated in syn-

chronism or in parallel for many years. However, it does

not follow that all transfers of power and energy between

interconnected systems are interstate in nature.

-_-

* * * * * * * * @ *

250

Q. At pages 46-53, 80, 81 and in Exhibits 18 and 19,

Mr. Jacobsen discusses and purports to show that energy .

from Georgia was transmitted through part of F. P. Corp.’s

' System and was delivered to FPL at a point between F. P.

Corp.’s Turner Plant and FPL’s Sanford Plant. Have you

studied this testimony and exhibits? <A. Yes, I have.

Q. Mr. Bivens, Dr. Jessel has also testified with regard

to two tracing methods. Are you familiar with this testi

mony? <A. Yes, I am.

@. What. data did Dr. Jessel describe as the second

“essential informational requirement” for his so-called

“steady-state method” for tracing power? <A. Dr. Jessel,

on page 33 and 34 of his testimony describes the second

“essential informational requirement” for his “steady-state

method” as follows:

_ “2. Maps and one-line diagrams of sufficient accuracy

must be available from which a single conductor

diagram may be prepared showing actual physical

Poemions of each electric line at each generating

(6)

(250)

station bus, at each substation bus, at each switch-

ing :

251

station bus, at each place where braneh circuits

are connected, and at each point of connection to

every investor-owned, municipal and cooperative

electric svstem included in the study.”

Q. What data did Dr. Jessel describe as the second “es-

sential informational requirement” for his so-called “com-

mingled method” for tracing power? A. On page 39 of

his testimony Dr. Jessel describes the second “essential in-

formational requirement” for his “commingled method” as

follows:

“2. Maps and one-line diagrams of sufficient accuracy

must be available from which a single conductor

diagram may be prepared showing points of con-

nection of single conductor circuit segments at all

junction points and at each point of connection to

every investor-owned, municipal and cooperative

electric system include lin the study.”

Q. What would.a single conductor diagram look like that

shows the information which Dr. Jessel said was necessary

under ‘both his “steady-state” and “commingled” methods

of tracing power? A. I have prepared such a diagram

entitled “Single Conductor Diagram”

Mr. Merriman. Mr. Examiner, I ask that this diagram

identified by Mr. Bivans be marked for identification as

Exhibit No. 45 {(B-4). .

Q. What is the essential difference between your Exhibit

No. 45 (B-4) and Mr. Jacobsen’s Exhibit No. 18. A. By

comparing these exhibits you will see that Staff Exhibit

No. 18 omits the following busses or junction points which

Dr. Jessel said were necessary: High Springs, Gainesville,

Archer, Silver Springs, Leesburg, Eustis, Deland West,

Brooksville and Inglis Power Plant. In addition, my dia-

76 2? ;

(252)

©

gram shows the relative physical positions of each electric

line at each generating station bus, at each substation bus, at

each switching station bus and at each place where branch

circuits are connected. This ,

252

information has been described as essential by Dr. Jessel

for his so-called “steady-state method.” Exhibit No. 18

omits the busses T described above and also fails to show

all of the circuits connected to the busses. For the circuits

that are shown the relative physical positions of the lines.

on the busses are not in accordance with fact. Neither does

Staff Exhibit 18 show the individual generators and their

relative physical location of connection to the busses at

Suwannee River and Turner.

Q. Dr. Jessel testified on page 33 that in order to trace

kw or kwh flows using his “steady-state method” the first

essential informational requirement is: ,

“I. Average kilowatt data must be available in tabu-

lated or other form for each hour of each year

for each generating unit and for ‘each line seg-

ment at each point of connection at each substa-

tion and switching station, at each branch loca-

tion, and at each point of connection with ev ery

investor-owner, municipal and cooperative electric

xystem included in the study.”

Also, Dr. Jessel testified on pages JS and 39 that using

his “commingled method” the first essential informational

requirements +

“IT. Average kilowatt data must be asailaiile in tabu-

lated or other form for each hour of each vear

for each generation station, for each end of each

line segment, at each branch location, and at each

point of connection with every investor- owned,

municipal and cooperative electric system included

in the study.”

77

(252)

Q. Do Mr. Jacobsen’s testimony and exhibits show that

he has complied with Dr. Jessel’s first essential informa-

tional requirement, using either tracing method? ‘A. No,

they do not. = |

253

Q. On page 46 thru 49, Mr. Jacobsen testified to the data

he used and presented Exhibit No. 18, to support his effort

to trace interstate power to Sanford. Do you agree with

his method? A. No, I do not. In my opinion, Exhibit No. .

18 is grossly over-simplified and tabulates incomplete line

readings of ‘kw flows at two substations and only two line

/readings at one generating plant. Exhibit No. 18 does not

“ show kw data (which is required in order to comply with

the requirements laid down by Dr. Jessel) for the transmis-

sion lines and transformer banks for the following trans-

mission substations and switching stations which lie be-

tween Ft. White and Turner:

1. Archer 2__115 kv line terminals

1—115-69 kv autotransformer bank

1—69 kv line terminal

2. Silver Springs 2—115 kv line terminals

5—69 kv lines

. 1—115-69 kv autotransformer bank

2. Deland West 9-115 kv line terminals

Oo 969 kv line terminals

1—115-69 kv autotransformer bank

4. High Springs . 3—69 kv line terminals

5. Gainesville 5—69 kv line terminals

6. Lake Weir 369 kv line terminals

7. Leesburg 4-69 kv line terminals

8. Eustis °__69 kv line terminals

78

pis i en mene . is

’ ; .

| (254)

9. Perry 1—240 kv line terminal

| 3—69 kv line terminals ©

10. Brooksville 2-115 kv line terminals

4 69 kv line terminals

1—115-69 kv autotransformer bank

254

Mr. Jacobsen also failed to show kw data for the Suwannee

Power Plant and the 115 kv lines between Sfwannee and

Jasper and between Suwanee and Ft. White. He failed to

show kw data for the Inglis Power Plant and for ‘the two

115 kv lines to Ft. White; for the four 69 kv lines, one of

which goes to Silver Springs; and for the two 115 kv lines

south to the Higgins Power Plant. He also failed to show

kw data and energy consumption for the many loads served

from 63 substations connected to the transmission lines

between the Turner Power Plant and oe Georgia State

Line:

Jennings ~ Luraville Webster REA

Alapaha LuravilleREA -, Sumterville —,

Jasper O’Brien REA Coleman

White Springs Trenton . Camps

Live Oak REA Trenton REA Dunnellon Town

Ft. White Old Town REA Ocala REA

Ft. White REA — Cross City City of Ocala —

_ High Springs Otter Creek REA Silver Springs

Alachua REA , Lebanon Lake Weir

Alachua Inglis Central Tower

General Electric | Red Level Dallas

Gainesville Inverness - Leesburg

Rochelle Inverness REA Leesburg East

University of ; |

Florida Withlacoochee REA Tavares

79

PED EB PRET EDEN ERP TTS RIN DRS So RATER Panay ae ~ SR AAR nL

.

(254)

Williston Inglis REA Eustis

Proctor ~ Brooksville Umatilla

ae a 255 .

Reddick Consolidated Rock Umatilla REA

Blichton Croom REA St. Johns

Perry ~ Bushnell REA Barberville

Tri-County REA Bushnell’ Deland

Archer Archer REA Turner

Q. Mr. Bivans, in a study to trace the flow of power from

Georgia to Turner, why are all of these readings required ?.

A. Without knowing the power flows from all sources and

at major switching stations, both as to magnitude and

direction. it is the rashest kind of an assumption to say.

that anytime power is flowing into Jasper from Georgia,

and power is flowing into the Turner 115 kv bus over the

Turner-Silver Springs 115 kv line, that the latter power

includes power from Georgia. :

Q. From what other source or possible sources could

this power originate? A. There are five other sources.

One is the Suwannee Power Plant feeding directly into

Jasper and Ft. White at 115 kv, or to It. White. at 69

kv by way of the Perry 240 kv line. A second source is

from the Inglis: Power Plant, which normally feeds power

into Silver Springs via a 69 ky line. A third source is from

Brooksville Switching Station, which normally feeds power

toward Silver Springs and Deland West over 69 kv lines.

The fourth souree is from the Orlando ties in the Woods-

mere-Orlando area and the fiftd is the Turner Plant itself.

The combination of these sources can deliver power into

the Turner 15 kv bus from Deland West. Therefore, with-

out a complete set of readings as described above it is im-

possible to determine how far into the F. P. Corp. system

any interstate power flows. In

80

(257)

256

other words, it is impossible to determine that power from

Georgia flows through the large, complex network of 115

-and 69 kv lines of F. P. Corp. into its Turner Power Plant.

Q. Is this also true of Mr. Jacobsen’s findings and con-

clusions concerning the Staff Exhibit No. 19? A. Even

more so, because by Mr. Jacobsen’s own testimony on page

92, the line flow data contained in Exhibit 19 is even

less complete than the inadequate data in Exhibit 18.

Q. Would you take the Single Conductor Diagram, Ex-

hibit No. 45 (B-4) and describe to the best of your

knowledge the availability of readings on F. P. Corp.’s

system. A. Suwannee River and Inglis Power Plants—

These stations are manned 24 hours each day and line flows

and generator loadings are recorded each hour.

Silver Springs, Leesburg, and Brooksville Switch Sta-

ttons—These stations are manned, generally, from 9 AM to

5 PM daily. Line flows are recorded hourly during the hours

the stations are manned.

High Springs, Trenton, Eustis, Deland West, Archer,

Perry and Gainesville Switching Slations—Uhexe stations

are unattended and, consequently, no usable data are avail-

able.

Woodsmere and I’'t. White Switching Stations—These

‘stations are manned, generaly, from 7 AM to 9 PM daily.

Line flows are recorded hourly dtiring the hours the stations

are manned.

Jasper Switching Station—This station is manned, gen-

erally, from 7 AM to about 9 PM cach day. Hourly readings

are taken on each line during

A 257

the hours that the station is manned. Line flows are recorded

by charts for 24 hours on interstate tie lines.

81

PRT Ser A DERMOT

t

aE SAS LS EARLE LTE LE LALO LA BEN

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Distribution Substations—36 of the 63 substations have

recording kw demand meters and kwh meters. The remain-

ing substations have maximum indicating kw demand

meters and kwh meters, read generally once a month.

Q. In view of the foregoing, in Your opinion, are ade-

quate readings ‘available on the F. P. Corp. system to-

make a valid tracing study of power from Georgia through |

the F. P. Corp. system to FPL? A. No, there are not.

To make such a study it would be necessary to read méters

at certain key points on the F. P. Corp. system where read-

ings are not now taken in the normal course of business.

Q. What are the significant differences, if any, hetween

the “basic’assumptions” stated by Dr. Jessel for his two

tracing methods? A. One of the significant differences

is that in his “steady-state method” Dr. Jessel assumes

that a bus has electrical dimensions whereas in his “com-

mingled method” he assumes a bus to be a point. A second

difference is that in his “steady-state method” Dr. Jessel

assumes that all kilowatt data are for unity power factor

loads ‘and sourees.of power supply, whereas in his “com-

mingled method” he assumes that all loads and power

supply sources do not have the same power factor.

Q. What are the significant differences, if any, between

the “essential informational requirements” stated by Dr.

Jessel for his two methods? A. Insofar as kilowatt data

and power factors are concerned there are none. In his

“steady-state method” generation data are required for

each unit within a generating station; whereas in his

“eommingled method” only the

258

total generation of all units within a generating®station

is required. Further, in his “steady-state method” data

are necessary to show the actual physical positions of each.

electric line at each bus and each point of connection. The

82

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actual physical positions of lines are not used in his

“eommingled method”. ,

Q. Mr. Bivans, you noted that in his “steady-state

method” Dr. Jessel assumes that all.loads and sources are

at unity power factor. Do you know any reason for such

an assumption? A. No, I know of no engineering or sci-

entific reason why such an assumption Should be made.

Q. Did Dr. Jessel anywhere in his testimony say, with

regard to his two methods, that it was necesary or required

to obtain, record or plot the power faetor of the various

loads or sources? A. No,he did not.

Q. Are you familiar with Dr. Jessel’s Exhibit No. 34

(J-1) and his discussion with regard to that exhibit? A.

Yes, Iam.

Q. Please comment on this testimony and exhibit. A.

Dr. Jessel uses Exhibit No. 34 (J-1) and his discussion

thereof as the basis for his view that his “commingled

method” more nearly represents an actual three phase

electric power system.

(). Is it possible to retain the identity of the actual physi-

eal arrangements of a bus using other than unity power

factors for loads and generation and plot power flows that

will provide a more accurate representation of the per-

formance of an electric power system, and fully describe

all ;

259

of the actual electrical characteristics of all of the power

sources and loads as they exist? A. Yes, as is commonly

done in power system studies. a

Q. Please describe the system studies method. A. Elee-

tric companies are continually making system power flow

studies. These are a very necessary part of any system

planning. The technique for. making a power flow study

is somewhat similar to the tracing methods described by

Dr. Jessel. However, rather than make the study by re-

83

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cording actual kw or kwh on the many line terminals

of every generating station and every substation, the sys-

tem in its entirety, including all lines, loads, generators,

and substations, is set up on.either an analog ‘or’ digital

computer. From the system as set up on the computer, it

is possible to obtain power flows, both real and reactive,

voltages, current flows, and other data on every line, load,

junction point, and every bus of every generating plant,

substation and switching station. This same procedure,

without the use of a computer, is valid for making a tracing

study of ‘kw or kwh flows, plotting actual recorded data,

regardless of power factor of loads and generation.

s * * * * * 2 * * *

262

Q. Which of the three methods, the two described by Dr.

Jessel and the one described by you, has the greatest ac-

ceptance and usage within the utility industry? A. The

method I describe has universal acceptance in-the industry.

Q. Why is this? A. Because this system most accurately

describes an electric power system both in its electrical and

physical characteristics. It permits retaining the identity

and physical arrangement. of all busses of substations,

switching stations and power plant switchyards. It permits

determination of the . y

263

‘magnitude and direction of power flow in the various bus

sections. This4s an important consideration in the design

of substation bus for proper selection of current carrying

capacity and adequate strength under short eireuit con-

ditions. —

Q. What are some of the companies that have used the

“system studies method”? A. I have a list of companies

which have used Westinghouse Klectrie Corporation’s com-

puting facilities for making this type of study and a letter

from General Flectrie Company which indicates the extent

84

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of visage of their computing facilities for system. study

load flows. .

Mr. Merriman. Mr. Examiner, I ask that there be marked

for identificationzas Exhibit Nos. 49 (B-8) and 50 (B-9),

respectively, the list with accompanying transmittal letter

from Westinghouse.and the letter from General Electric.

Q. Are these the documents you mentioned? <A. Yes,

they are.

Q. What is wrong with considering a substation bus or

generating station bus as a point? A. Primarily because

it is-contrary to fact. It is an over-simplification of the

system and does not permit determination of power flows

which actually exist on busses of generating stations and

subtations. This is obviously what Dr. Jessel and Mr. Jacob-

sen failed to consider. A bus, whether it is in a substation,

generating station or switching station is not an electrical

or a physical point but rather has dimensions. A bus, with

its set of three conductors, supported by insulators, is,

in fact, a short transmission line to which transmission

lines, generators .

264

and transformers are connected at regular intervals, meas-

urable in feet, along its length. Furthermore, a bus has the

same electrical properties, that is, resistance, inductive

reactance aid capacitive reactance, just as a transmission

line. —

Q. How can power flow in the various bus sections be

determined? A. The power flow in any bus section can

be measured using the same type of metering equipment

that is used for transmission lines. Or the bus section flows

can be determined by using the flows as metered on the

various lines, generators, and transformér banks

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