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reasonableness and appropriateness. BPA can continue to administer the program 

 effectively without revisions to the exchange agreements or ASCM. Also, there is 

 significant risk in initiating a reconsultation to make such revisions. BPA would 

 be required to conduct a public process and consider input from customers and 

 other parties. Many issues and alternative revisions would be brought forward. A 

 reconsultation process could result in allowing additional costs to be exchanged. 



Since the basic intent of the program is to provide equitable access to the benefits 

 of BPA power for the residential and irrigation customers of all exchanging 

 utilities, it is true that utilities with higher costs will receive higher benefits per 

 kWh. However, competitive pressures and regulatory and BPA scrutiny ensure 

 that costs are minimized, and that inefficiency is not rewarded. 



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