Senator NELSON. Thank you very much, Mr. Richter. (The full text of Mr. Richter's statement follows:)

STATEMENT OF GEORGE E. RICHTER, UNIVERSITY OF MINNESOTA

With your permision, I would like to background the history of some of Northern States Power Co.'s actions and statements leading up to and including their decision in proposing a steam-generating plant at Oak Park Heights.

NSP is a public utility owned by individual investors and, as such, we assume that this corporation has a peculiar responsibility to the public: consumers; communities they serve; and, probably above all, their shareholders. They have in the past, apparently, as a responsibly managed company, recognized this obligation. We quote from the 1957 annual report of NSP to its stockholders, page 17:

"The company considers its reputation for fairness and fine service as one of its most valuable assets and continually endeavors to keep its customers, employees, and shareholders informed of its activities."

Each annual report of the corporation, in addition to the usual corporate financial statements, usually has other sections devoted to legal matters, labor relations, finance, current building and expansion projects, plus a section telling of construction planned years in advance.

In reviewing NSP reports to stockholders from early 1950, we find first mention made of proposed steam-generating plants was on the inside cover of the 1956 annual report:

"The company has acquired two parcels of land for future steamplants along the Mississippi River. One is near Red Wing and the other at Newport, Minn., where barge coal and adequate cooling water are available."

The next reference to proposed plants was in the 1959 annual report, page 16, in a section titled, "Building for the Future."

"To keep ahead of the ever-increasing demands for electricity and gas, the company plans far ahead and builds with an eye to the future. It is estimated the installed generating capability of the NSP system will exceed 3 million kilowatts by 1969. The company has already acquired the land for two steamplants that will be built along the Mississippi River within the next 10 to 12 years. Eventually, these may total over 1 million kilowatts each. One is near Red Wing and the other at Newport, Minn."

This was a full-page statement with a map showing the proposed locations. We now submit the attached copy of two newspapers' stories. One, November 19, 1958, St. Paul Dispatch headlined, "$200 Million NSP Plant Planned,” and a second, dated November 20, 1958, St. Paul Pioneer Press. A map illustrating the Prairie Island site across from Diamond Bluff, Wis., accompanied the following statement:

"A million kilowatt steam-electric-generating station is planned by Northern States Power Co. in the Prairie Island area between Red Wing and Hastings. Arrow shows the approximate location 8 miles northwest of Red Wing. Construction will begin in the late 1960's or the early 1970's, and the complete installation will cost about $200 million at today's prices."

The 1960 annual report under legal section, page 11, concluded: “* * * and the necessary proceedings to obtain transmission outlets for the company's proposed Red Rock generating station and for the expansion of the company's transmission system."

Nowhere do we find any evidence of any sort that NSP has ever planned a steam-generating plant on Lake St. Croix. The property they owned at Oak Park Heights was purchased and used as a substation.

Out of a clear sky, on May 6 and 7, 1964, both Twin City papers carried press releases about NSP building a steam generating plant at Oak Park Heights. April 1964 Shareholders Bulletin (specific date not included, apparently published in May) tells of the May 6 shareholders' meeting:

"Plans to construct a 500.000-kilowatt-electric generating unit at an estimated cost of $60 million were announced by Earl Ewald, executive vice president. It will be located on a site near Bayport, Minn., on the St. Croix River. The new unit will be of the most advanced engineering design and will be the largest and most efficient in the upper Midwest."

Why this sudden change of plans from Red Rock to Oak Park Heights? Northern States did not give a ready answer, and on July 10, Mayor Vavoulis and the St. Paul City Council asked the president of NSP to meet with them to reconsider their decision.

One month later, August 10, the St. Paul papers reported that Mr. Earl Ewald met informally with the St. Paul council. We quote from the St. Paul Dispatch:

"During the information session, Mayor George Vavoulis asked NSP officials why a new $63 million generating plant would not be located at Red Rock, a site on the St. Paul-Newport border.

"He [Mayor Vavoulis] criticized the company's public relations, saying he has heard much rumored information about NSP's proposal to locate the plant on the St. Croix River.

"Earl Ewald, NSP president, presented the company's plans, and in an obvious reference to the Save the St. Croix Committee which opposes the plant on that river, said, 'We are finding out that there is a great deal of public opinion on this and that it is loaded with dynamite.'"

We further attach and submit for your evaluation Mr. Ewald's statement of August 10, 1964, "Generating Station Site Location, Northern States Power Co." We quote from paragraph 2:

"The location of large, efficient, centralized generating units is the most important element in the whole power system planning problem. These plans are developed on a preliminary basis over 20 years into the future and as conditions develop and changes in the art occur, the plans are modified so that the system development plans reaching 10 years into the future are fairly definitely established. Because the construction of a major generating plant requires about 4 years' time for engineering and construction, it is essential that the plans be firmly established about 5 years in advance.”

We again submit that nowhere in any public statement or report has NSP indicated that the Oak Park Heights location was planned or considered for any purpose other than as a substation.

We refer to page 3, paragraph 1:

"In our preliminary studies of the site at Newport we had worked with the aviation authorities and received conditional approval for a stack about 400 feet high. When the new studies developed the need for an 800-foot stack, we rechecked with the aviation authorities and we found that new developments were being planned at the Holman Airport which would place this site directly in the path of a landing pattern. This made an 800-foot stack an impossible hazard and it even cast doubts on the advisability of a 400-foot stack. These studies then made it apparent that the location of the plant at this site was impossible if the Holman Airport were to be developed."

We have checked with the offices of the Federal Aviation Authority, Metropolitan Airports Commission and the State aeronautical commission and find no record of a formal application for such a smokestack. In the words of the aviation officials the contacts were cursory and no determination was asked for or arrived at.

We further refer to Mr. Ewald's statement of August 10, page 4, paragraph 1: "Although our preliminary studies indicate that this generating unit would cause a very reasonable temperature rise, it is not clear at this stage whether such a temperature rise would be considered acceptable at this site by the water pollution control commission." (We have been unable, however, to find evidence of any formal request made to the water pollution commission for a generating plant.)

We further quote from Mr. Ewald, page 4, paragraph 3:

"It was the coincidence of these developments which lead us to our decision to locate the plant at Bayport. It was obvious to us that the airport problem was one that would require time for its solution. It was obvious that the cooling water problem was critical and that a definite answer on that would not be available until further results of our studies were available. These factors together with the electrical operating considerations made it clearly desirable to install the 1968 unit at Bayport and delay the development of the Newport site until the other problems had been resolved."

We wish to call your attention that the only reference to any public authority on the Red Rock and Prairie Island sites were some informal inquiries to the water pollution control commission. Also when NSP was talking to the water pollution commission, they were talking about a 2-million-kilowatt plant at Red Rock. This is four times as large as the proposed first unit on the St. Croix. Until August 1964, there were no references to any studies of water conditions on the St. Croix.

Nowhere in any statement has Northern States said it considered other locations in its considerations for plant site. Nowhere has it documented its possible

consideration of other sources of fuel such as gas, lignite, or atomic energy. Are we as consumers, stockholders, and citizens not entitled to know what considerations, if any, have been given to alternate sites and fuel? Also, are we not entitled to know if other plants are being planned; and if so, are others being planned for the St. Croix area? Do they plan to use Red Rock, Prairie Island, and Monticello in the future along with the St. Croix?

We submit the attached press release, dated September 21, 1964, page 108, Electrical World, "MAPP Study Plans 5,956 Mw by 1980."

Are these coal-fired plants necessary just because NSP joined Mid-Continent Area Power Planners?

Do we as consumers, stockholders and citizens have to give up other natural resources and put up with all the disadvantages of coal-fired plants in the metropolitan area just because NSP has made a decision?

Again, who can help us? Who can answer these questions? What "orderly procedure" is there other than asking for a permit to use water? Who is there to evaluate the need, economic feasability, and the impact upon recreational and esthic aspects of these plants in our two States?

At present we are asked to take NSP's word for everything and are told not ever to raise a question.

Now to get back to the current St. Croix controversy. We wish further to call to your attention another statement of Northern States Power Co. In all their formal statements to stockholders and people writing about St. Croix and at the three public meetings that NSP attended, NSP's statements started with the following:

"Northern States Power Co. welcomes inquiries about all aspects of the steam electric plants it plans to build at Oak Park Heights on the Minnesota side of the St. Croix River."

We know of eight organizations that contacted NSP to have them present their side at a public meeting. All were turned down with NSP giving the excuse that this is not an issue for public discussion; that it is in the hands of commissions and should be settled in an orderly fashion.

Also, NSP has repeatedly stated that they are not arbitrary and they wish to abide by the wishes of the communities they serve.

Documented NSP statements and actions behind the Oak Park Heights site selection do not verify NSP's statements and concern about their long-range planning and concern for communities and conservation.

It is not my purpose to impugn here the motives and actions of NSP. However, it should be noted there is no authority to whom this company is accountable for any of its actions. There is no State regulatory body in Minnesota that has any control over power companies. There is no public service commission in the State of Minnesota. Likewise, there is no State, Federal, or local authority to whom anyone can appeal regarding the overall impact and affects of this plant on the surrounding area.

On behalf of the hundreds of thousands in this area who are accustomed to using the St. Croix Valley as a recreational and living area plus those who just appreciate its scenic beauty; we ask help, we need help. Please help us get answers to our questions.

Mr. Ewald, I believe, expressed the issue best, in a prepared TV statement: "The issue is whether or not the valley is going to be industrialized or kept for recreational uses."

[From the St. Paul Pioneer Press, Nov. 20, 1958]

TWO HUNDRED MILLION DOLLAR NSP PLANT PLANNED

Northern States Power Co. today announced plans for a million-kilowatt steamelectric generating station on the west bank of the Mississippi River in the Prairie Island area north of Red Wing.

Construction of the first unit will begin in the late 1960's or early 1970's, Allen S. King, Northern States Power president, said.

Northern States said the plant would cost around $200 million at today's costs but the figure could change considerably by the time construction starts.

King said the firm now is taking steps to buy the land for the plant and a substation as well as procuring right-of-way for transmission lines.

The plans call for four units, each with a capacity of 250,000 kilowatts. The largest units now in operation in the NSP system are 100,000 kilowatts.

King said use of electricity in this area has doubled every 10 years over the past few decades. The proposed plant, he said, will lie between the rapidly expanding areas served by the company in southeastern Minnesota and westcentral Wisconsin.

[From the Electrical World, Sept. 21, 1964]

MAPP STUDY PLANS 5,956 MEGAWATTS BY 1980

Preliminary expansion plans of members of Mid-Continent Area Power Planners envision the addition of 5,956 megawatts of new capacity in 11 new stations in the United States and Canada between 1968 and 1980 and supporting highvoltage transmission lines between Winnipeg and the Twin Cities area, plus transmission in North Dakota.

New generation would consist of 2,956 megawatts of fossil-fuel capacity, including two new 200-megawatt lignite-burning plants in North Dakota; 2,380 megawatts of hydrocapacity at three sites on the Nelson River in Manitoba; and 620 megawatts of nuclear capacity near the Twin Cities.

These projections were presented to a MAPP management meeting in Winnipeg July 23-24 by Stanley Mleczko of Sanderson & Porter.

They are contained in a preliminary report of five plans for the development of systems in the upper Midwest and Manitoba. According to Sanderson & Porter, the plan that appears best suited to the power needs of the MAPP area indicates maximum development of the hydropotential on the Nelson River as soon as possible.

Mleczko presented this timetable for the proposed stations: 1968: Coal-fired, 515-megawatt station, Twin Cities, currently authorized; 1969: Lignite-fueled, 200-megawatt station near Stanton, N. Dak., to be privately financed; 1970: Hydroplant of 630 megawatts at the Kettle site on the Nelson River; 1972: Coalfired, 627-megawatt station, Twin Cities area; 1974: Hydroplant of 540 megawatts at the Long Spruce site on the Nelson River; 1975: Coal-fired, 627-megawatt station, Twin Cities area; 1976: Lignite-fueled, 200-megawatt station near Stanton; 1977: Nuclear plant of 620 megawatts near the Twin Cities; 1978: Hydroplant of 1,210 megawatts at the Limestone site on the Nelson River; and 1980: Coal-fired, 787-megawatt station, Twin Cities area.

Results of the 3-month study, according to Mleczko, show that interchange of large blocks of power between MAPP members in the United States and Canada is feasible. The study recommends that a full-scale engineering study be made with a view toward beginning construction of the new generating facilities and transmission lines. Electrical World learned that consideration is being given to lines at 345 kilovolts initially but with 500 kilovolts a possibility.

The two 200-megawatt lignite-fuel stations were offered as a minimum generating requirement from North Dakota's lignite fields. They would be in addition to two plants already authorized for construction in the Stanton area. Mleczko noted that lower lignite costs might justify additional stations to be built under the MAPP plan in the Stanton area of North Dakota.

The study by Sanderson & Porter was sponsored by these MAPP members: Minnkota Power Co-op.; Northern States Power Co.; Otter Tail Power Co.; Minnesota Power & Light Co.; and Manitoba Hydro-Electric Board.

GENERATING STATION SITE LOCATION, NORTHERN STATES POWER Co.

(By Earl Ewald, president, August 10, 1964)

Planning a power system is a tremendously complex engineering problem involving consideration of a great many engineering and economic factors. The Northern States Power Co. has a planning organization which has developed a great deal of experience and is utilizing the very latest techniques available to science and engineering. NSP's planning organization has been instrumental in the formation of Mid-Continent Area Power Planners which is coordinating the planning of utilities in the 10-State upper Midwest area. This accomplishment has attained national recognition and NSP is established as one of the leading planning organizations of our industry in the United States.

The location of large, efficient, centralized generating units is the most important element in the whole power system planning problem. These plans are

developed on a preliminary basis over 20 years into the future and, as conditions develop and changes in the art occur, the plans are modified so that the system development plans reaching 10 years into the future are fairly definitely established. Because the construction of a major generating plant requires about 4 years' time, for engineering and construction, it is essential that the plans be firmly established about 5 years in advance.

As a part of this planning program, NSP owns several future generating station sites. The ones located at Newport and Bayport, for example, have been owned by NSP for about 20 years. When we first considered the location of a generating station at the Newport site we anticipated that the total capacity of the station would be about 200,000 or 250,000 kilowatts. By the late 1950's, we realized that larger generating units would be more efficient and we expanded the plans for the site to include a million-kilowatt installation. We then bought more land to accommodate the larger plant size.

Beginning in 1961, when the first 500,000-kilowatt unit was successfully installed in the United States, it became evident that substantial economic advantages in first cost and efficiency would accrue for the very large sized units. At the same time, NSP had been expanding its interconnection program with adjacent utilities and developing plans for major transmission ties to other large metropolitan areas like Chicago and St. Louis. The requirements of reliability of service would not allow us to install generating units as large as 500,000 kilowatts without the high-capacity interconnecting lines to other large utilities which would make it possible for us to draw upon other power sources in the event of a shutdown of the large unit. Thus the developments of the art and the perfection of our plans very recently brought us to the conclusion that our 1968 installation would be a 500,000-kilowatt unit. This is a very much larger size than had been anticipated in the past and the change involved necessary modifications of our planning.

There are two aspects of the modern electric-generating plant which are very important to its immediate environment. One is the discharge of stack gases and the other is the temperature effect on the circulating water used to condense the steam coming through the turbines.

In the light of the present-day conditions at the Newport site, with its proximity to the downtown St. Paul area, where there is a high concentration of industry, automobile traffic, and other sources of air pollution, and considering the heavy industrial development in the immediate vicinity of the Newport plant site, preliminary studies indicated, without question, that a very high stack of about 800 feet would be necessary to adequately disperse the stack gases. A modern generating plant is equipped with electrostatic precipitators which remove virtually all the fly ash, soot, and other solid materials from the stack emission so there is no problem from those sources.

In our preliminary studies of the site at Newport we had worked with the aviation authorities and received conditional approval for a stack about 400 feet high. When the new studies developed the need for an 800-foot stack, we rechecked with the aviation authorities and we found that new developments were being planned at the Holman Airport which would place this site directly in the path of a landing pattern. This made an 800-foot stack an impossible hazard and it even cast doubts on the advisability of a 400-foot stack. One of the large components of stack emission is water vapor which under certain weather conditions causes a steam plume from the stack which can cause difficulties to aircraft. It should be remembered, also, that in addition to the stack causing hazards to the aircraft, we must consider the hazard the aircraft cause to the powerplant. One of our prime responsibilities is to avoid service interruptions in the community and we must, therefore, design to eliminate the hazard of a major accident such as an airplane crashing into the powerplant. These studies then made it apparent that the location of the plant at this site was impossible if the Holman Airport were to be developed.

The other major environmental problem involving circulating water was also found to be critical at the Newport site. Our modern generating station will remove great volumes of water from the river, pass them through our cooling condensers, and return it to the river without any pollution or damage to the water except that the water will be slightly increased in temperature. This increase in temperature of the river water becomes important in certain seasons of the year when the weather is hot and when the flow in the river is low, particularly if there are heavy concentrations of organic matter present in the water. We have been working with the water pollution control commission for several years studying the effects of temperature increases in the Mississippi