133 



seen or used by BPA as a vehicle for charging "what the market 



will bear" for one service in order to subsidize another 



service. BPA should not use its monopoly power in 



transmission or other markets to subsidize BPA's firm power 



service. 



F. Direct Service Industries Can and Should Provide 

 Important Reserves Under Their BPA Power Sales 

 Contracts 



Under Section 5(d) of the Northwest Power Act, sales to 



the direct service industrial (DSI) customers of BPA are to 



provide a portion of BPA's reserves for firm power loads 



within the region.^ The reserves provided by the DSIs 



encompass short-term stability reserves (under which a DSI 



load in its entirety may be interrupted on little or no notice 



when necessary to preserve system integrity and to protect 



against unanticipated system outages) and longer-term energy 



reserves (under which various quartiles of a DSI load may be 



interrupted for various reasons related to the absence of 



hydroelectric generation or the failure of resources to be 



available and operate as planned) . The region has experienced 



low streamflows this year, and the first quartile of BPA 



service to DSI loads has been interrupted for a significant 



^"Reserves" under the Northwest Power Act are "the electric power 

 needed to avert particular planning or operating shortages for the benefit 

 of firm power customers . . . ." Northwest Power Act § 3(17), 16 U.S.C. 

 S 839a(17) . 



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