199 



substantial change in the purposes for which BPA is supposed to run the 

 power system, ihus, until the Act is changed, BPA's goals, which it irost 

 seek' to inplement through its rates end contracts, are not negoticible. In 

 practice this would mean that BPA would ask of every actio n it takes: Does 

 this action further the goals of the Act? And EPA would ask of every 

 service it provides: How can we structure and price this service so that 

 those using this service will be encouraged to further those goals?) 



At this stage of the EIS we are not required to choose between the 

 alternative goals, hov^-ever. BPA's next task is to evauate each cf the 

 implementation option's impacts on each of the above three coals. Thus the 

 Market-Based cption might do very well achieving goals nuiriber 2 and 3, but 

 badly on number 1. 



Itiis is the logical place to begin analyzing BPA's scoping alterna- 

 tives. Ihe rest of our coirjnents will be specif ic inplenentation options 

 which we feel are missing from the current analysis. 



OOP REOOMMENEIATICW: Evaluate each inplementation option — Central 

 Plan, Market-Based, Minimum BPA, etc. — against each of the three goals 

 described above. 



(We would like to start with one complaint. The very term "Central Plan- 

 ning" is perjorative, suggesting the worst sort of Coinnunist bureaucracy 

 which brought dov.-n the Soviet Union. Perhaps the label, "Regional 

 Coordination" would be less value-laden.) 



RESOURCE DEVEIDPMENT 



rost tiered rate options have a goal of encouraging/allcv/inc customers 

 to do what used to be Bonneville's "job" of resource acquisition. Under 

 the "Regional Goals" alternative, BPA ha.s certain mandates under the Act in 

 this ares. They must do planning, including e.xternalities, follow the 



