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for an investor-owned utility to operate less efficiently 

 would be erroneous and unsupported by the facts. In any 

 event, investor-owned utilities in the region do least-cost 

 planning and their costs and plans are subject to extensive 

 review by state public service commissions. 



If the RPSAs are revised, it is important to note that 

 several categories of costs have been previously excluded from 

 exchangeable costs. Such exclusion does not appear to be 

 justified at this time. For example, BPA has limited the 

 conservation costs that may be exchanged with BPA; 

 accordingly, some of the utility's costs incurred to develop 

 conservation are in essence not treated as exchangeable 

 resources, which fails to encourage conservation and 

 efficiency in the use of electric power as envisioned by 

 Congress in enacting the Northwest Power Act. All of BPA's 

 production and transmission costs are included in BPA's costs, 

 but some of the exchanging utility's production and 

 transmission costs have been excluded by BPA. If the RPSA's 

 are revised, BPA should return to the original principle that 

 all production and transmission costs of the exchanging 

 utility are exchanged, just as all of BPA's production and 

 transmission costs are exchanged. 



Thank you for this opportunity to provide comments. 



l07772-(M98/BAyJ 1750.0571 



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