established criteria would result in inappropriate uniformity and the imposition of costly and unnecessary burdens on all regions.

Third, we are convinced that criteria embedded in formally established regulations would tend to be inflexible in a fleld in which flexibility is of the essence. All of us know, for example, how difficult it has been to get acceptance of new materials and new methods under established building codes and how obsolete code provisions can make construction much more expensive. Our industry is infinitely more complex, and the pace of technological change is perhaps faster than that in any other industry in the nation.

We believe the question of standards should be left to the process of regional planning which can deal much more rapidly and flexibly with new developments than can the Federal Power Commission sitting in Washington. An advisory body at the federal level might well be helpful; mandatory standards would not. Provisions for approval for extra-high-voltage lines would impair rather than improve reliability

H.R. 489, 1253 and 5841 provide, in proposed Section 409, that no EHV line can be built without notice to the FPC two years in advance of construction and approval of the line by the FPC, H.R. 7016, 7052 and 7186 require six months notice to the FPC but apply the notice requirement to modifications or extensions as well as new construction of EHV lines and also to the construction of generating units.

In either case, permission to proceed would depend on meeting all of the ambitious legislative purposes spelled out in the bills. In the light of the issues that this would open up, the determination of whether such objectives had been met could cause endless delays. Indeed, while the procedural provisions of H.R. 489 and companion bills indicate an intention to complete proceedings on proposals within 18 months, H.R. 7016 and companion bills provide only that a hearing must be scheduled within 19 months after a proposal has been filed. Neither set of bills provides any time limit within which the Commission must act to permit construction.

Instead of accelerating construction of new EHV facilities required to improve reliability, the bill would delay the installation of such facilities. The dangers of delay are indicated by the fact that an estimated 6,000 to 8,000 miles of EHV lines are planned for each of the next several years and the industry must place more than 30,000,000 kilowatts of capacity in service every year for the foreseeable future.

Some of the problems the requirements would create are suggested by the delays in the granting of certificates of convenience and necessity for gas pipelines in contested cases. But when a gas pipeline is delayed, the gas distributors can simply avoid increases in sales; an electric utility must be prepared to meet every demand placed upon it and has no means of controlling expansion of customers' requirements.

Further, the longer in advance that planning is done, the less likely it is that plans will accurately forecast actual needs. Today the decision to build a generating station must be taken five to seven years before its service date; the proposed legislation might lengthen the period to nine or ten years. By greatly increasing the lead time for planning, the proposal would increase planning errors and adversely affect the ability of the utilities to provide reliable service as actual loads develop at different speeds or different locations from those envisaged in the planning process.

Quasi-judicial proceedings are not appropriate to solve reliability problems

Although the FPC stresses the urgency of increased reliability, the proposed bill as a whole undertakes a brand new experiment in reliability planning. The FPC functions in the framework of adversary proceedings with decisions made on a formal written record shaped by opposing counsel through the examination of witnesses. This is an appropriate form for the adjudication of individus) disputes.*

*The degree to which the proposed legislation would apply such adjudicatory technique to utility facility construction is strikingly illustrated by proposed Section 411(e) of HR 7016 and parallel bills. If an applicant proposed to use eminent domain proceedings, stat or federal, to acquire land for any EHV line or generating station and any aggrieved perso had filed an objection with the FPC, the applicant utility could get relief only if "the Com mission's record shall show that the proponent sustained the burden of proof that the par of the approved proposal to which said objection was raised is the best of all feasible an prudent alternatives." [Emphasis supplied.]

Reliability, however, depends on the effective implementation of continuously changing engineering plans affecting many utilities and dealing with a host of varying alternatives rather than the narrow question of whether a particular party is right or wrong on a particular closed record. Making a quasi-judicial agency like the FPC an instrument of long-range planning both with respect to technological matters and social and economic ones is an unprecedented and undesirable step.

Utilities in the Middle West have, for many years, been developing a network f interconnections. The scope of these interconnections has grown as oportunities to improve service reliability and economy of operation have appeared.

Now, increases in generator size and advances in EHV technology have made it possible to develop a 345,000 volt regional transmission grid which, by 1968, will provide continuous extra-high-voltage lines joining the electric power generation facilities of utilities serving major portions of Indiana, Illinois, Missouri, Iowa, Minnesota and Wisconsin. The regional grid also has high capacity ties to the east, principally to the American Electric Power system. Each of the signers of this memorandum is linked to the others by a variety of interconnections, including direct or indirect connections to the 345,000 volt grid. Most of them are also parts of formal or informal electric power pools which include a number of other utilities. In the aggregate, these utilities operate approximately 36,000,000 kilowatts of generating capacity located in 12 states. As a result, they have a major role in providing electric service to the public in the Middle West. As indicated in the formal provisions of this agreement with respect to its purpose, the Mid-America Interpool Network ("MAIN") was originally formed in 1964 to increase the already high degree of coordination existing in the area, and this revised agreement is entered into to carry forward its activities.

The organization and operation of MAIN will be covered by the provisions of this memorandum.

(1) Purpose

The purpose of MAIN will be to promote maximum coordination of planning, construction and utilization of generation and transmission facilities on a regional basis by MAIN members individually and as members of the power pools to which they belong, in order to improve the reliability of electric bulk power supply in the areas served by such members and pools.

(2) Membership

(a) Regular Members. Initial regular membership in the Mid-America Interpool Network shall consist of the utilities signing this memorandum as regular members. Regular membership is also open to any other power supplier who has a high capacity interconnection (115 kv or above) with a regular member, whose operations have a significant effect on the reliability of the interconnected system of the region, and who undertakes the obligations of regular membership. Each new member shall be assigned by the Executive Committee to one of the groups listed on the membership list attached to this memorandum or hereafter designated by the Executive Committee as appropriate for purposes of power coordination.

(b) Liaison Members. Members of coordinating groups similar to MAIN may participate in the MAIN organization through liaison membership. It is recognized that the responsibilities of such liaison members for active participation in the detail work of MAIN may be Imited, depending upon their activities in other coordinating groups.

(c) Any member may withdraw from membership at the end of any fiscal year upon notice in writing to the Chairman at least 60 days in advance.

(3) Obligations of members

The primary obligation of membership shall be the presentation to and review with MAIN of plans and operating practices affecting the reliability of the bulk power supply in the MAIN area, with the objective of maximizing the reliability of such supply. To further this objective, each regular member undertakes:

(a) To make available to any committee or task force approved by the Executive Committee such data as may reasonably be required to assist in achieving the purpose of the MAIN organization.

(b) To provide personnel, on a scale which takes into account the size and resources of the member and the relationship of the particular activity in question to its system.

(c) To pay any assessment levied by the Executive Committee to meet the expenses of MAIN within the limitations of the budget for the fiscal year in question. The expenses of MAIN shall be assessed to its members in proportion to their respective peak loads in magawatts in the fiscal year preceding that in which the expenses are incurred.

Liaison members shall provide personnel and financing as agreed upon from time to time between such liaison members and the Executive Committee. (4) Meetings of membership

(a) An annual meetingof all MAIN members shall be held during the month of June, at such time and place as the Chairman shall designate by notice in writ

ing, given as far in advance as practicable, but in any event at least 30 days in advance of the meeting, for the following purposes:

(i) To elect a Chairman and Vice-Chairman for the ensuing year.

(ii) To establish a budget for the fiscal year next following the meeting. (iii) To prescribe the general direction of the efforts of MAIN for the ensuing year.

(iv) To take such other action as may be necessary or appropriate to carry out the purpose of MAIN.

(b) Special meetings may be called by the Chairman or a majority of the Executive Committee at such time and place and for such purposes as shall be designated by notice in writing given at least 10 days in advance of the meeting. No action with respect to any matter not specified in the notice of meeting shall be taken at any special meeting.

(5) Officers

(a) Designation. The officers of MAIN shall be a Chairman and Vice-Chairman, who shall be elected at the annual meeting, and such other officers as the Executive Committee shall designate and appoint.

(b) Duties. The Chairman shall preside at all meetings of the membership and of the Executive Committee and, subject to the direction of the Executive Committee, shall have general supervision of the activities of the organization. The Vice-Chairman shall assume the responsibilities of the Chairman in the event of his absence or inability to act. The officers appointed by the Executive Committee shall have such duties as the Executive Committee shall assign from time to time.

(6) Committees

(a) Executive Committee.

(i) Membership. The Executive Committee shall consist of a representative of each group designated on the membership list attached to this memorandum or hereafter designated by the Executive Committee. In June of each year, beginning with the year 1967, each group shall select its Executive Committee representative by vote. The representative so selected shall serve from the close of the annual meeting in June and until the succeeding annual meeting or until a successor has been duly designated. In the event a representative is at any time unable or unwilling to serve, the vacancy thus created shall be filled by the group which initially selected the representative.

(ii) Meetings. Meetings of the Executive Committee shall be held on the call of the Chairman or any three members of the Committee, upon at least 5 days written notice to each of the members of the Committee.

(iii) Duties of Executive Committee. The Executive Committee shall admit new members and assign them to membership groups, creating new groups when, in its judgment, such groups are appropriate for power planning purposes. It shall name the members of the Engineering and Operating Committees, and shall designate and appoint such officers, other than the Chairman and Vice-Chairman, and such ad hoc committees as it shall deem appropriate to carry out the work of MAIN. Subject to the general direction of the membership, the Executive Committee shall establish, assign to committees and supervise all MAIN projects, and authorize the expenditure of funds, by the committees or otherwise, within the limitations of the budget. It shall also adopt such rules, consistent with the provisions of this agreement, as may be necessary or appropriate for the conduct of the affairs of MAIN. It may fill any vacancies occurring in officer positions between annual meetings.

(iv) Additional Duties of Members of Executive Committee. Each member of the Executive Committee shall be responsible for initiating such communication within the group that he represents, including the convening of any necessary meetings, as shall be appropriate to coordinate the information the members of such group are to provide to MAIN, to inform such group of the data developed by and the activities of MAIN, and to carry out the purpose of the MAIN organization.

(b) Engineering Committee. The Engineering Committee shall be the planning rm of MAIN. Subject to the direction of the Executive Committee, it shall ndertake such activities as will contribute to improving the already high egree of electric service reliability through more complete coordination of

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long-range plans of the members of MAIN. Such activities shall include studies of coordination of generating and transmission facilities in the area, such as: (i) Regional grid load flow studies for normal and emergency system conditions.

(ii) Studies of system stability.

(iii) Determination of maximum credible incidents.

(iv) Studies of required reserve generating capacity in the region.

In addition, the Engineering Committee shall provide to the Operating Committee such data and information as may be required for assuring reliable system operation.

(c) Operating Committee. The Operating Committee shall be the operating arm of MAIN. Subject to the direction of the Executive Committee, it shall undertake such activities as will aid in coordinating the operating activities of the members of MAIN to maintain reliable electric service. Such activities shall include:

(i) Coordination of maintenance for EHV transmission equipment and generating equipment.

(ii) Review of operating practices, as required, for normal and emergency situations.

(iii) Liaison among the several coordination and operating centers in the Midwest region.

(d) Liaison Activities. The Engineering Committee and the Operating Committee shall establish and maintain adequate liaison with their counterparts in contiguous coordination groups, using, to the extent practicable, the assistance of the liaison members of MAIN.

(7) Planning and operation for economy

This agreement deals only with reliability of electric service in the Midwest region. It is expected, however, that groups of MAIN members will develop planning and operating arrangements to achieve increasing economies in bulk power supply, such as:

(a) Joint scheduling of capacity, arrangements for economic dispatch of generation, and coordinated use of transmission facilities.

(b) Making maximum use of the generating capacity that is available because of seasonal diversity characteristics.

(c) Interchange of energy for economy reasons.

(8) Fiscal year

The fiscal year of MAIN shall be the period from July 1 of any calendar year to and including June 30 of the succeeding year.

(9) Voting; quorum

(a) In any matter on which a vote of the membership is necessary or appropriate and in voting in each group for the group's Executive Committee representative, each regular member shall have one vote plus one additional vote for each 100 megawatts by which its peak load in the preceding fiscal year exceeded 100 megawatts, provided, however, that no member shall have more than 40 votes. Members shall be entitled to vote by proxy. Except as provided in (10) below, a majority of the votes cast on any proposal presented to a membership meeting at which a quorum is present shall be sufficient for adoption of the proposal. A quorum shall be deemed to be present at such a meeting when there are present or represented regular members having a majority of the voting power in MAIN.

(b) A majority vote of the members attending an Executive Committee, an Engineering Committee, or Operating Committee meeting at which a quorum is present shall be sufficient for adoption of any proposal which is before such com mittee. A quorum shall be deemed present when a majority of the members of such committee is present at a meeting.

(10) Amendment

This agreement may be amended by the affirmative vote of two-thirds of the votes cast at any regular or special meeting of the membership at which a quorum is present, provided that, in the case of a special meeting, due notice has been given that an amendment of the agreement is to be considered.

(11) General

No party hereto shall be liable for the failure of any other party to perform its obligations hereunder, and each party shall retain sole control over its own facilities and the use thereof.