SECURITIES AND EXCHANGE COMMISSION

                                Washington, D.C.

                          Three year period ending 2002

                      FORM U-12(I)-B (THREE-YEAR STATEMENT)

   Statement Pursuant to Section 12(i) of Public Utility Holding Company Act of
1935 by a Person Regularly Employed or Retained by a Registered Holding Company
or a Subsidiary Thereof and Whose Employment Contemplates Only Routine Expenses
as Specified in Rule 71(b)

         1.  Name and business address of person filing statement.
                    Eugene P. Byars, Southern Company Services
                    600 North 18th Street, P.O. Box 2641 Birmingham, AL 35291

         2.  Names and business addresses of any persons through whom the
undersigned proposes to act in matters included within the exemption provided
by paragraph (b) of Rule U-71.

                    None

         3.  Registered holding companies and subsidiary companies by which
the undersigned is regularly employed or retained.

                    Alabama Power Company, Southern Company and all
                    its subsidiaries.

         4.  Position or relationship in which the undersigned is employed
or retained by each of the companies named in item 3, and brief description of
nature of services to be rendered in each such position or relationship.

                    Director, System EMS

         5.  (a) Compensation received during the prior reporting period and
estimated to be received over the next two calendar years by the undersigned or
others, directly or indirectly, for services rendered by the undersigned, from
each of the companies designated in item 3. (Use column (a) as supplemental
statement only.)

                           Salary or other
                            Compensations
Name of                          to be           Person or company from whom
recipient     received         received          received or to be received

                 (a)               (b)
Eugene P.     $220,000       to be included      Alabama Power Company
Byars                        in supplemental
                             statement


             (b) Basis for compensation if other than salary. None

         6.  (To be answered in supplementary statement only.) Expenses
incurred by the undersigned or any person named in item 2, above, during the
calendar year in connection with the activities described in item 4, above,
and the source or sources of reimbursement for same.

             (a) Total amount of routine expenses charged to client:  $3,500

             (b) Itemized list of all other expenses: None




Date  January 10, 2000               /s/ Eugene P. Byars
                                         Eugene P. Byars