HomeMy WebLinkAboutRESOLUTIONS-1991-100-R-9112-12-91
• 100-R-91
A RESOLUTION
Affirmation of City's Intent to Explore all
Opportunities for Electric Energy Service
WHEREAS, the City of Evanston had undertaken a
Preliminary Study of the Feasibility of Establishing a Municipal
Electric System; and
WHEREAS, the Preliminary Study. determined that a
Municipal Electric System was a feasible option for the City of
Evanston; and
WHEREAS, the City .Council concurred with the Energy
Alternatives Task Force's recommendations to:
1. Prepare a Request for Proposal for a second study
to determine the available power supply; and
• 2. Appoint a Negotiating Team to initiate discussions with
Commonwealth Edison regarding the renewal of the
franchise agreement; and
3. Support the work of the Northwest Municipal Conference
in their efforts to develop a model franchise
agreement.
and
WHEREAS, a
negotiating team
has been
appointed
to
initiate discussions
with Commonwealth
Edison
regarding
the
franchise agreement; and
WHEREAS, the Northwest Municipal Conference endorsed
the model franchise and it is available for use by member
communities;
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF
µ ,THE* -CITY OF EVANSTON, COOK COUNTY, ILLINOIS :
H
100-R-91
• SECTION 1: The City of Evanston affirms that it is
exploring all viable options and
opportunities to maintain the most efficient and cost effective
power supply alternatives for the business and residential
citizens of Evanston.
SECTION 2: That Exhibit A, the Duncan Allen response
to the Commonwealth Edison letter of
November 22, 1991, become a part of the public record of the City
and that it be released to the media and the concerned citizens
of Evanston.
SECTION 3: This resolution shall be in full force
and effect following its passage and
approval in the manner provided by law.
•
44-e-t-aMayor
TES
C' Clerk
Adopted: 1991
,
F-439 T-926 P-002/007 DEC 09 191 11:54
Duncan
& Allen
COMMELLM AT LAW
1575 Eye Street, Northwest
Washington. AC 20005-1175
Telephone (202) 289-8400
FAX (202) 289-8450
December 9, 1991
Ms. Judith A. Aiello
City of Evanston
2100 Ridge Avenue
Evanston, Ohio 60204
Re: Resnonse to Commonwealth Edison
..Dear Judy:
This is our response to Commonwealth Edison's "Dear
Evanston Customer" letter of November 22, and to comments by
Commonwealth Edison that appeared in a newspaper article on
November 26. We disagree with Commonwealth Edison's criti-
cisms of our Preliminary Feasibility Report and we stand by
its assumptions and conclusions.
• Initially, we note that criticisms such as Common-
wealth Edison's are to be expected whenever a city considers
the option of establishing a municipal electric system. We
have encountered them before and, as here, found them to be
without merit. In each case, moreover, Commonwealth Edison's
comments appear to indicate a failure to read the study
carefully rather than to reveal flaws in the study itself.
Commonwealth Edison provided specific criticism on
three aspects of our Preliminary Feasibility Report. It
claims the study is flawed by:
(1) Understatement of the cost of
acquiring facilities due to failure
to include the acquisition cost
associated with Substation TSS 47;
(2) Understatement
electricity due
consider losses
transmission of
tourers located
of the cost of
to failure to
associated with
power to the cus-
in the City; and
-439 T-926 P-003/007 DEC 09 191 11:��
Duncan
& Allen
- 2 -
(3) Unrealistic assumption of a start-up
date of January, 1993.
in addition to these issues, Commonwealth Edison also offered
less specific arguments in opposition to the establishment of
a municipal electric system.
Exclusion of Substation TSS 47
Commonwealth Edison claims that our study fails to
include the cost associated with acquiring Substation TSS 47.
This claim is incorrect. As was indicated on Page V-2 of our
report, we have included the cost associated with acquiring
the necessary portion of the facilities located in Substation
TSS 47. Specifically, our analysis included costs associated
with acquiring facilities located within Substation TSS 47 and
which are operated at and below 34.5 kV.
•
The remaining portion of the substation and the
costs associated with obtaining it were excluded for a reason: •
The City does not need them and would not need to acquire
them. Commonwealth Edison would continue to own them and use
them as it does today. Further, if the City were to acquire
all of the facilities at Substation TSS 47, the additional
cost should be offset by several factors explained below.
More technically, the reason we have not included
the cost associated with facilities located in Substation TSS
47 that are operated at voltages higher than 34.5 kV is be-
cause we assumed that the City would interconnect with Common-
wealth Edison's system at 34.5 kV. This is consistent with
our assumptions regarding the City's power supply. The City,
we assumed, will purchase power from Wisconsin Electric Power
Company ("WEPCO"). That power would be transmitted (or
"wheeled") across the Commonwealth Edison transmission system
and delivered to the City at 34.5 kV. Evanston would receive
the power at 34.5 kV and would have no need to acquire the
higher voltage facilities in the substation. This is not a
theoretical approach, but is in fact the practice that is in
use today in the City of Geneva, Illinois, which also pur-
chases power from WEPCO, wheels it across the Commonwealth
Edison system, and receives it at 34.5 kV.
If the City were to purchase the entire facilities
located in Substation TSS 47, the City would then be connected
to the Commonwealth Edison system at 138 kV and, as a result,
we would expect that it should pay a lower wheeling charge
•
P-439 T-926 P-004/007 DEC 09 '91 11:56
� Duncan
& Allen
- 3 -
than is paid by Geneva. Moreover, as Commonwealth Edison
would still need to use the 138 kV facilities to transmit its
own power to its electric load outside of Evanston, the City,
would be justified in charging the company a wheeling charge
if the City owned the 138 kV facilities. We have not analyzed
the specific costs associated with acquiring the additional
facilities located in Substation TSS 47 which are operated at
voltages higher than 34.5 kV, nor have we attempted to iden-
tify (a) the reduction in wheeling costs that would occur as a
result of the City interconnecting with Commonwealth Edison at
138 kV, or (b) the revenues that Commonwealth Edison would pay
to the City to use these facilities. It is apparent that
there would be some offsetting effect, however.
Overall, we believe the assumptions made with regard
to the facilities located in Substation TSS 47 are reasonable
and we do not believe that the facilities operated at voltages
higher than 34.5 kV need to be acquired by the City.
Transmission Losses
Commonwealth Edison also points out in its letter to
its customers that, although losses are mentioned in our
report, we failed to account for those losses in our analysis.
This is totally wrong and can only be explained by an apparent
failure to read the report carefully. As indicated on Exhibit
IV-2 of the report, we have included in our analysis an allow-
ance for losses associated with transmitting power from WEPCO
to the City. As indicated on Line 3 of Exhibit IV-2, we have
assumed a transmission loss adjustment of 5%, the same loss
adjustment that is identified in Commonwealth Edison's trans-
mission tariff that is utilized by Geneva to wheel power from
WEPCO to Geneva.
We have also included an allowance for losses in the
City's distribution system as discussed in Page IV-1 of the
report. As indicated on Lines 1 and 19 of Exhibit IV-1, we
have assumed a 10% and 5% loss adjustment for non -industrial
and industrial customers, respectively. These loss adjust-
ments are based on the experience of other municipally owned
electric systems which we represent.
Consequently, we believe that our analysis does pro-
perly reflect the losses associated with wheeling power from
WEPCO to the customers located in the City and that Common-
wealth Edison's observation is incorrect.
0
F-439 T-926 P-005/007 DEC 09 '91 11:57
Duncan
& Allen
- 4 -
Timing
Commonwealth Edison further claims that a January
1993 start-up date is unrealistic. We believe this was a
realistic assumption to use at the time the study was com-
missioned, based on actual start-up times required by new
municipal utilities with which we have been associated. We
believe it remains a realistic start-up date if Commonwealth
Edison agrees to negotiate a sale of its distribution facili-
ties in Evanston. As noted below, however, the purpose of the
study was not to identify precise amounts that could be saved
and when, but instead to determine whether there were insur-
mountable obstacles to establishing a municipal system and, if
not, whether there appeared to be sufficient savings poten-
tially available to warrant more serious consideration by the
City.
Other Arcmments
•
In addition to the key issues discussed above, Com-
monwealth Edison also raised other less specific arguments
opposing the establishment of a municipal electric system. 0
One of those arguments is that some cities, such as Chicago
and Riverdale, recently rejected the idea of forming their own
municipal electric systems.
As we have pointed out to the Task Force, there are
many factors that affect the feasibility of establishing a
municipal electric system. These factors differ from city to
city, which is why each community must make its own evaluation
and determination of the feasibility of establishing its own
municipal electric system.
While it is true that some cities have recently
rejected the idea of a municipal electric system, several
cities also have recently elected to establish their own
municipal electric systems and are doing well. According to
the American Public Power Association, the national associa-
tion for municipal electric systems, 30 communities have
elected to establish their own electric systems since 1980.
One of those communities with which we have worked, Clyde,
Ohio, established its system in 1988 and now provides reliable
electric service to its customers at rates that are 20% - 40%
less than the rates of the investor -owned utility that pre-
viously served those customers.
•
r- �_ •-_moo ; -/rC, vVJr c. it >1 li:r=
Duncan
,10 &Allen
- 5 -
Commonwealth Edison also suggested that our report
did not fully discuss WEPCO's long-term capacity as a supplier
of power. However, the report relied on WEPCO's projections
of available power. Presumably, WEPCO is in a better position
to project its future availability of power than Commonwealth
Edison. More importantly, the report relied on the fact that
the terms of service offered under WEPCO's supply arrangement
obligate WEPCO to provide the capacity necessary to serve the
City's requirements.
Finally, the attachment to Commonwealth Edison's
November 22 letter questioned (without specific or quantified
criticism) the study's treatment of legal fees, financing
costs and municipal budget stability, and reserves. Again, it
appears the company has not read the report closely. our
estimated capital requirements included $2.5 million in legal,
engineering, and financing costs (pages VI-1 and VI-2). In
addition, we assumed that revenue bonds would be used to
finance the system (page VI-3), which means that only revenues
from electric sales will be used to pay off the bonds. Muni-
cipal taxes and municipal budget stability will not be
affected. Lastly, with regard to financial reserves, our
• study included significant funding (over $1 million per year)
for repairs and replacements (Exhibit VII-1) and $5.5 million
of debt service reserves (page VI-2). These figures are in
accord with accepted standards for reliable municipal electric
service.
summary and Conclusions
In summary, we did not find anything in Commonwealth
Edison's letter that requires us to alter the assumptions and
results provided in our report. The company has raised fewer
issues than is typically the case (which may indicate they do
not disagree with major portions of the report, although we do
not expect the company to concede that) and, where it has
raised issues, they are either groundless or based on lack of
detailed review of the study, rather than the assumptions or
conclusions contained in it.
Nevertheless, the citizens of Evanston should not
lose sight of the fact that our study was designed only to hit
the tops of the waves and to address key issues of feasibi-
lity. This was done so the City could avoid the cost of an
in-depth study if the preliminary report identified serious
problems. The report does not and was not intended to provide
a detailed answer to every question that might be asked. On
ri
U
F-439 T-926 P- r/007 DEC 09 '91 12:00
Duncan
& Allen
- 6 -
the other hand, in our view it does provide sufficient detail
to.conclude that there may be significant benefits available
to the businesses and residents of Evanston from a municipal
electric system.
sincere yours,
Gre tinger
cc: Jim Suhr
John Courtney
Jim Dittmer
•
•