195 



j , Attachment to NCAC Testimony: Scoping Comments 



jOrtnWCSl for power Saies Contracts 



Jonsen'auon 



' VcmiK'i lie Fd-^r Administration 

 Public Involverifnt (•'■anager 

 P.O. F)c>:.12S?S 

 Portland, OB 97212 



Deer Ns. Lynn Baker: 



The following is a suppletnerit to oral coifrents presented at the Comnercial 

 Services and Rates Sccpinc ineeting on Aug. 24th in Portland. 



The Kbrthfc-est Conservation Act Coalition (NCAC), 217 Fine St.. Suite 1C2C, 

 Seattle, KA 98101, founc3ed in 1981, is a recion-wide alliance of conserva- 

 tion and consumer advocate organizations, utilities, businesses and citiien 

 activists reeking a clean, affordable energy future for the Pacific North- 

 west and British Colunbia,. We appreciate the opportunity to caiment on 

 EPA's proposed ccanraercial services and rates. 



The purpose cf these ccnsrents, queuing frowiBPA's annbuncenient,; is; 

 "The. EIS will help BPA choose the best; methods for providing electrical 

 service to its Pacific Northwest customers, utilities and industries , that 

 buy wholesale power, frora EPA. " To .judge which icethod is "best," we must 

 knov; vrfiat thestandard is ve arG.conparirK) against. Does 5PA mean ; 

 cheapest? Cleanest? ..Most reliable? Exactly what-:are BPACs coals and 

 cbjectiyes-for providing electrical service? _ - , • 



This question points to a major failing of the current ciscusision of 

 alternatives. That is the mixing of two logical constructs:: the goals of 

 the contracts, rand the means of achieving tliese goals. , It is. extremely 

 inportant to separate these two discussions, .but' BPA, and many of : the 

 custoners, -have blurred them together. The. former: is a value-lad«n deci- 

 sion while the latter is £ value-free discussion. ', For exanple, the Market- 

 based alterrKj^iyeis viewed by .rany-as a goal ^^as ifciell as an itpleirfiritation 

 measure. These parties see the promise of low rates and customer indepen- 



