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<br />Remaininq Issues <br /> <br />The issues that remain to be litigated are as follows: <br /> <br />1. the appropriate credit for O&M cost savings provided by UG facilities, e.g., reduced tree- <br />trimming costs - FPL's position is that O&M costs of UG facilities, other than storm restoration costs, are <br />greater than for OH facilities, vs. our position that O&M cost savings should produce a saving of an <br />additional 25% off the otherwise applicable CIAC charges; <br /> <br />2. FPL's proposal to divide the credits for Avoided Storm Restoration Costs into 3 "tiers" <br />with credits of 5%, 10%, and 25% based on size of the project - this could be worth an additional credit <br />up to 20% or 15% of the CIAC charge for a UG project that was just under the minimum size threshold to <br />qualify for the full 25% GAF credit; <br /> <br />3. the "contiguous new and converted UG issue" for qualifying for the full 25% credit - this <br />could also be worth 15% of the otherwise applicable CIAC; <br /> <br />4. the "DESS Costs" issue, i.e., the way that FPL allocates its common engineering and <br />other costs where the Applicant performs the work - this is worth at least 40% of the otherwise applicable <br />CIAC charge for work performed by city/town-hired contractors or internal forces; and <br /> <br />5. potentially the issue of getting FPL' tariff amended so that a municipality would not lose <br />the GAF credit if it were otherwise able to obtain federal economic stimulus funding for a UG conversion <br />project - this could be worth the entire GAF credit. <br /> <br />In a memo to the MUUC membership on December 16, Schef Wright estimated the value of each <br />of these issues (except the "federal stimulus funding" issue) and described how we would go about <br />proving our positions in a formal hearing before the PSC. <br /> <br />Costs of Further Efforts <br /> <br />To pursue all remaining issues, including the "federal stimulus funding" issue mentioned above, <br />including negotiations, if pursued, and litigating all issues, Young van Assenderp has proposed a Not To <br />Exceed price of $140,000 in fees, plus normal out-of-pocket costs, and Power Services offered a Not To <br />Exceed price of $56,000 in fees, plus normal out-of-pocket costs, which I am estimating at 10% of the fee <br />amounts: This produces a grand total for which we are invoicing the MUUC's members of $215,600. <br /> <br />I look forward to talking with you in our next conference call at 2:00 P.M. on Wednesday, <br />February 4. <br /> <br />2 <br />