There are other rate cases pending and this requires the Council to request a deficiency appropriation which may not be approved by either Administration and Finance or the General Court. This situation raises an interesting legal point. Are not the people of the Commonwealth being deprived of their property without due process of law as there is lack of proper representation of their interest before the Department of Public Utilities which is a quasi judicial body. This makes an interesting constitutional question about which more will be heard in the future. It is because of these factors the Council filed this bill. This proposed act permits a proper funding of the Consumers' Council by charging the cost of such representation or investigation to the public utility involved. Certainly if the public utility companies can charge the cost of a rate case to expense, which means to the consumer, it is only equitable, to say the least, that the consumer also be permitted to charge the expense which would be charged to the consumer rate base anyway. It is time to redress the balance. The policy of "benign neglect" of the consumers' interests by regulatory bodies must be abolished. Good government must insist that the consumers' interest be properly represented in any proceeding before the Department of Public Utilities.

Mr. DERMOT SHEA,

Executive Secretary, Consumers Council,
Boston, Mass.

R. W. BECK AND ASSOCIATES,
Boston, Mass., February 17, 1970.

DEAR MR. SHEA: This is in reply to your letter of February 17th regarding the effects of voltage variation and specifically voltage reduction to electric appliances and equipment normally found in homes and modernized commercial establishments.

Electric utilities have, in the past, been identified as maintaining a high level of service to their customers, and normally have been guided by two main criteria: service continuity and voltage level. Service continuity being identified as always having power available without even momentary interruption, and voltage level being identified as a voltage whch had very little fluctuation.

The power companies in the New England area have recently found themselves in a very changed condition because of insufficient generating and transmission capacity to supply the electric power requirements of their consumers. Various articles have appeared in recent months, pointing out this critical power supply situation, and the industry itself is more than just a little concerned as to how they can meet these power supply demands. It has been interesting to note that very little information has been included in these articles on the effects the ultimate power consumer will see as a result of the power companies' failure to supply their consumers' requirements. Therefore, it was of great interest to me to see that your organization is investigating this area and pointing out some of the effects which will be felt by the individual home owner and business operator.

This lack of available electrical capacity has led to the electric utility companies' adoption of a program of voltage reduction which, in some areas of the country, is now being referred to as "load conservation". This, in effect, is a reduction in the voltage level of the power supply facilities which, in turn, reduces the overall load the companies are required to supply. Remembering our high school physics formula, power is the product of voltage potential and current flow, the power companies have utilized this basic formula to reduce their loads by reducing the voltage levels in amounts which have been identified to range up to 10 percent. Normally, the voltage regulation equipment located throughout the utilities' service area reinstate the desired voltage level when normal load variations cause this voltage to fluctuate and, in the past, this equipment has always provided a fairly constant voltage supply to each consumer. However, the present practice of the utilities of reducing this voltage during high load periods is amplified by the inability of this normally used voltage control equipment to handle these planned variations, and in some cases, can cause voltage variations at individual consumer homes in the range of 15 percent.

Some of the effects that the consumer will feel when the voltage level to his residence or business is reduced by 10 percent is (1) a 30 percent reduction in

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the light intensity from his incandescent lights, (2) heating equipment will have a near 20 percent reduction in output, (3) induction motors utilized in many types of appliances will have a near 20 percent reduction in their starting ability and an approximate 12 percent rise in their operating temperature, (4) fluorescent lamps now found in many homes and most commercial establishments will have their life cut by 20 percent besides having unsatisfactory starting and (5) electronic devices such as radios and television sets which are very sensitive to voltage fluctuation, will have a noticeable reduction in picture brilliance and sensitivity.

In summary, it can be said that the individual customer will receive a much less satisfactory operation of his electrical appliances under low voltage con ditions and will be subject to earlier replacement because of shortened life.

The industrial consumer who has a large investment in automatic control equipment of the computer type and who utilizes electrical and automatic equipment to produce his product sees the effect of voltage reduction quickly and in some cases dramatically, when a substantial voltage variation occurs. Most of his equipment probably would have protective features to adjust for slight or, what can be considered in the past, normal variations in power supply voltage, but many of these facilities were not designed to handle large voltage variations. A momentary outage or severe voltage change causes most electrical equipment to either shut down or otherwise become inoperable. It is quite common for industries with highly mechanized equipment to look closely at the dependability and continuity of power supply service before locating their facilities. Many of the industries that are in the New England area can be identified as this type of industry.

I hope this information will be helpful to you and I would be happy to supply you with a list of references of publications and documents which substantiate the information discussed above.

If there is any other information which I can supply you in this regard, please contact me.

Very truly yours,

ROBERT G. TAYLOR, Partner and Manager, Northeast Regional Office.

APPENDIX B

THE COMMONWEALTH OF MASSACHUSETTS CONSUMERS' COUNCIL

MEMORANDUM

Re: R. W. Beck Report on Low Voltage.

Date: June 10, 1970.

To: Dr. Edward R. Willett, chairman.

From: Dermot P. Shea, executive secretary.

Subject: Staff report on low voltage problems during the period from June 1 through June 5, 1970.

1. Because of the hot weather during the first week in June the effects of low voltage used by the Boston Edison Co. was particularly noticeable. This is a forerunner of what consumers might expect in the event of a Summer heat wave. What happened this past week confirms the Beck Report as to the consequences of low voltage. I suspect that the reduced voltage was more than 5% in some areas of Downtown Boston, as well as Waltham and other outlying areas.

2. A sampling was taken of the elevator companies as to their service complaints as a result of this low voltage from June 1 through June 5.

(A) One company reported that on Tuesday, June 2nd, it received 88 service calls as a result of a low voltage as compared to the usual 5 or 6. The complaints concerned the fact that the elevators were operating too slowly, if at all. Several of the complaints concerned passengers stuck in elevators that stopped between floors. A second company reports that an June 2nd they had 95 service calls, 77 on Wednesday, June 3rd, 31 on Thursday, June 4th, 27 on Friday, June 5th. That is again way above normal and concerned the same problem. Several other companies were checked and reported that the number of service calls was far above normal during this period and concerned slow or inoperative elevators.

(B) The sampling was taken at several air conditioning companies of their complaints during this period. The sampling indicates that heavy industrial installations were severely affected, including some major factories. Low voltage affects the transformers and controls on this type of industrial unit. One report was given that the motor was burnt out at the control bench due to low voltage. Beauty shops, hotels, restaurants and office buildings were among those reported affected by improperly operating air condition units. Some of these problems were noticeable in the Boylston St., State St., and Commonwealth Ave. areas. This is a composite only of the sampling of complaints received by air conditioning firms that were checked.

SUMMARY

The "happenings" of last week, June 1 through June 5, 1970, sustains the Beck Report made to the Consumers' Council on February 17, 1970, which outlined the consequences of low voltage. It is apparent that continual low voltage this Summer is bound to make expensive "Sauna baths" out of many new office buildings, not only in the Boston area but, also, in the other large cities of the Commonwealth.

In connection with the elevator complaints, it would appear that Boston Edison is trying to tell the consumers of Boston "walk don't ride". Furthermore, I am informed that Boston Edison has already advised Massachusetts Bay Transportation Authority this past week that it will have to cut off the M.B.T.A. power supply in the event of more serious power shortage. The M.B.T.A. needs 70,000 kilowatts. It has 35,000 kilowatts available through its own power supply; therefore, during a severe power shortage this Summer it is possible the M.B.T.A. may be shut down for intermittent periods.

Senator MUSKIE. I have similar but not identical views on what the "Big 11 Power Loop," is all about.

Mr. WILLETT. I don't know as we necessarily differ on that.
Senator MUSKIE. Mr. Shea, do you have a statement also?

Mr. SHEA. No, Senator, my chairman has made the comments. I am here only as a technical aide.

Senator MUSKIE. I see an appendix was attached to that statement and it has been included in the record.

Mr. WILLETT. And the Beck report is attached, too.

Senator MUSKIE. They both have been included in the record. Have you had an opportunity to analyze NEPOOL and its potential for effectiveness?

Mr. WILLETT. I haven't had a chance to go over them. The general conclusion that I have is that if it did what the claims say it should do, it would still be inadequate to supply the probable need when it finally arrives.

Senator MUSKIE. Let me ask you three or four questions to get your impression of its make-up and thrust. Is there, in your judgment, any assurance that its construction and system plans would be the best for New England? In other words, what inputs are made into its planning in both these areas? Is there any public oversight or approval for the work of NEPOOL?

Mr. WILLETT. No, Senator Muskie. We have as consumers' council in fact filed bills in our State legislature to try to acquire funds for our own State Department of Public Utilities to conduct planning studies, because we do not believe that these companies have properly planned the power sources with the best total interest of the consumers in mind. We will feel much better if we have some other agency make a full-scale study. We would be more assured. We have been unable to get such funds, however, for our Department of Public Utilities.

Senator MUSKIE. Would NEPOOL be independently staffed or would its staffing be provided by the member companies?

Mr. WILLETT. As far as I know, NEPOOL will be independently staffed but it will be staffed by private people and will be independent, of course, from the State.

Senator MUSKIE. What assurance is there that once the plans have been developed by NEPOOL that the plans will be carried out? Can it mandate the programs of the constituent utilities? It seems to me that each utility would be primarily concerned with its own interests. and not what is best for the region.

Mr. WILLETT. That is correct. One of the things that has bothered me is, I've been unable to find any evidence of any written agreement between any of the companies as to the sharing of power or what would go on between them.

Senator MUSKIE. So that the construction schedules themselves may not necessarily be carried out in accordance with whatever planning is done by NEPOOL?

Mr. WILLETT. That's correct.

Senator MUSKIE. Suppose that a company were interested in carrying out a project in accordance with NEPOOL's plans but lacks the resources or the capacity. Is there any provision in the arrangement of setting up NEPOOL for the pooling of economic resources to carry through the planning of NEPOOL?

Mr. WILLETT. No, I know of no such agreement. I would assume it would depend entirely on the good will of the members.

Senator MUSKIE. Is there any assurance of coordinated engineering and construction capabilities from the smaller members of NEPOOL? Mr. WILLETT. I have seen no assurance of any cooperation in writing. When I have asked any questions concerning such agreements, the answer has always been, in effect, that, "We have been getting along with oral agreements for years, I'm sure it will continue to be fine." I wish I had as much faith in this type of oral agreement as the private companies seem to have. I don't.

Senator MUSKIE. In other words, there is nothing which the public can evaluate.

Mr. WILLETT. No.

Senator MUSKIE. Thank you very much, gentlemen, for your excellent testimony.

Mr. WILLETT. Thank you.

Senator MUSKIE. We have received a statement from the former Governor of New Hampshire, now chairman of the New England River Basins Commission, Hugh Gregg, and we will include that letter in the record of these hearings this morning.

(The statement follows:)

Hon. EDMUND S. MUSKIE,

NEW ENGLAND RIVER BASINS COMMISSION,

Boston, Mass., June 11, 1970.

Chairman, Subcommittee on Intergovernmental Relations, Committee on Government Operations, U.S. Senate, Washington, D.C.

DEAR MR. CHAIRMAN: Thank you very much for your letter of June 4 inviting me to testify before the Subcommittee on S. 2752 in Boston on June 15. Because the Commission is meeting next week, it is unlikely that I will be able to appear. I thought it might be useful, however, to offer some comments by letter.

The Administration, as you know, is working intensely now on issues dealt with by S. 2752. My comments, therefore, will not run specifically to the provisions of S. 2752. I will report on efforts of this Commission to help reconcile power/environment conflicts, and offer some general observations based on our experience. I will not comment on questions of reliability.

The Commission, as you know, is an intergovernmental (Federal-State) body charged with planning and coordinating planning for use and management of water and related land resources, under authority of the Water Resources Planning Act of 1965. It is interagency at the Federal level-nine Federal agencies are members; and it is interstate, with members designated by the Governors of the six New England States and the State of New York.

Shortly after the Commission was established in 1967, it became clear that siting of electric power generation and transmission facilities posed one of the most difficult questions of land and water use facing the region. The Commission recognized a dual responsibility relative to power plant siting: to help see that suitable sites are available for meeting energy requirements; to protect and enhance the use and value of water and related land resources as these are affected by power facilities.

It was clear to the Commission that the existing decision-making process was inadequate in several respects.

At that time, of course, there was no explicit method for consideration of thermal effects in Federal licensing procedures for thermal plants (since reconciled).

At that point, none of the New England States had an adequate basis of law and procedures for influencing or controlling siting decisions.

And there was no systematic way of linking State and Federal review and permit-granting procedures, especially in connection with environmental impacts. Accordingly, the Commission approved a three-phase program designed to:

Assist State and Federal agencies-both regulatory and resource management agencies-to work together in evaluating currently-proposed electric power plants;

Assist in strengthening State authorities and procedures for influencing site location and plant operations; and

Develop a process for assuring consideration of environmental factors in long-range planning of regional power systems.

The Commission undertook, at the request of Governor Curtis of Maine, a staff evaluation of environmental controls imposed by the State in connection with the Maine Yankee Nuclear Power Plant at Wiscasset. The study concluded that the controls imposed by the State pollution control agency provided adequately for correction of problems that might occur. The study further convinced us that Maine, and other States, needed to strentghen both laws and institutions to protect the public interest in electric power plant siting decisions. In 1969, we began-at the request of Governor Peterson of New Hampshire— an evaluation of the proposed nuclear power plant on Hampton Harbor near Seabrook, New Hampshire. A report on this evaluation is now in the final stages of review. Using an ad hoc team of Federal and State agency officials, including representatives of AEC, and FPC, and both Federal and State agencies with responsibility in water pollution, outdoor recreation, fish and wildlife, public health, etc., the task force evaluated the plant against criteria suggested by the Energy Policy Staff of the Office of Science and Technology. Based on these evaluations, a summary evaluation reflecting all points of view is being prepared under the leadership of the Commission's staff.

The final report, as approved by the Commission, will be transmitted to the Governor, to State and Federal regulatory agencies, to the utility, and to the public.

Within the last few weeks, Governor Sargent of Massachusetts has designated a committee of State agency heads to sort out the public interest in a possible pumped storage project of Northeast Utilities in the Housatonic Basin and an addition to a thermal plant at Braden Point. The Governor has asked the Commission to work with the group to assure that regional factors (including alternate sites) are considered, and to help coordinate Federal and State reviews. Northeast Utilities has asked the Commission to consider both the Massachusetts pumped, storage site, and an alternate in Connecticut. Northeast has also agreed to fund an evaluation by citizens and local interests of the two sites, through the New England Natural Resources Center.