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6. Should the irrigation discount be eliminated or modified? Please provide an estimate of 

 the cost and/or benefit to regional ratepayers of continuing to provide this discount? 



The irrigation discount was incorporated into the Northwest Power Act at a time of regional 

 electric surplus. Much like the DSI rate, the discount clearly made sense when BPA's choice 

 was to run water through its dams and capture no revenue or run water through its dams and 

 capture modest revenues from agriculture. Currently, the discount provides rates that are 80 

 percent of the priority firm rate. As the surplus has evaporated, the value of the discount to the 

 power system has been called into question. 



Agriculture is an important part of the Washington economy. For example, the food processing 

 industry is our state's second largest employer. The irrigation discount has provided some 

 certainty in an otherwise volatile business. We believe it is important that BPA consider the 

 vulnerability of this industry to changing electricity prices as it reviews its own products and 

 services. For these reasons, the state of Washington believes the irrigation discount should not 

 be automatically eliminated, but could be modified to reflect the new realities of the Northwest 

 electricity marketplace and the role of a restructured BPA. 



10. How should the long-term power contracts that BPA is currently negotiating Mfferfrom 

 the current contracts? What, if any, environmental issues should be addressed in these 

 contracts? 



The negotiation of power sales contracts should not be a process by which regional electricity 

 priorities and policies are set; it should be a process by which regional policies and priorities are 

 implemented. Long term power sales contracts must reinforce regional responsibility for those 

 customers who take advantage of the energy and capacity services of the federal base system. 



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